# bankruptcylawyerreview.org -- Full Content > Last updated: 2026-09-25 This file contains the full text content of all pages on bankruptcylawyerreview.org. Part of the Open Bankruptcy Project (openbankruptcyproject.org). --- ## Reviewing Your Bankruptcy Attorney's Bill [2026]: Rule 2016(a), Section 329(b), and Fee Disclosures Source: https://bankruptcylawyerreview.org/billing-review.html bankruptcylawyerreview.org ☰ Home Understanding Your Bankruptcy Case How to Review Your Common Issues in Bankruptcy Your Rights as a How to Read Your Part of the Open Bankruptcy Project - 210+ free domains, 49,000+ pages, $0 hosting Reviewing Your Attorney's Billing Home›How to Review Your Bankruptcy Attorney's Billing | bankruptcylawyerreview.org›Reviewing Your Attorney's Billing Understanding bankruptcy attorney billing Bankruptcy attorney fees are subject to court oversight. Understanding how fees work and how to review them protects your interests. Fee disclosure requirements Under 11 U.S.C. Section 329, your attorney must file a disclosure statement with the court detailing all compensation received or agreed to be received in connection with your case. This is public record and appears on the court docket. What to check Does the fee match your agreement? - Compare the court disclosure to your retainer agreement Were additional fees charged? - Some work may be billed separately. Check if these were disclosed Payment timing - In Chapter 7, most fees are paid before filing. In Chapter 13, fees may be paid through the plan Fee applications - In Chapter 13, attorneys may file fee applications for additional work. These require court approval Court oversight of fees Bankruptcy courts have the authority to review attorney fees and order disgorgement (return) of excessive fees under Section 329(b). Fees must be reasonable considering the nature, extent, and value of services provided. 11 U.S.C. Section 329(b): "If [the] compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive." Note: If you believe your attorney's fees were excessive, you can raise this issue with the court or the U.S. Trustee's office. The U.S. Trustee monitors attorney fees in bankruptcy cases as part of their oversight role. ← Back to bankruptcylawyerreview.org Related Topics 1328(f) Discharge Screener Automatic Stay Guide Means Test Calculator Chapter 7 vs 13 How to File Bankruptcy Affordable Legal Help This site is free and open-source. Donations support the Open Bankruptcy Project, a 501(c)(3) public charity (EIN 41-5159631), funding PACER access fees and bankruptcy court transparency research. Part of the Bankruptcy Transparency Network Real information, no strings. Discharge Screener Open Bankruptcy Project Ch.7 vs Ch.13 Bankruptcy Cost Automatic Stay 341 Meeting Exemptions by State Means Test File Without a Lawyer Rebuild Credit 1099cdebt.com Free bankruptcy education for the public interest. Not legal advice. If you need legal help, contact a licensed attorney in your state. A project of the Open Bankruptcy Project, a 501(c)(3) nonprofit (EIN 41-5159631). Privacy | Terms Our research was cited by the federal judiciary as Suggestion 26-BK-3 This site provides general information, not legal advice. Consult a qualified attorney for your specific situation. You May Also Find Helpful Bankruptcy Means Test by State -- bankruptcymeanstest.org 1099-C Cancellation of Debt Tax Guide -- 1099cdebt.com Open Bankruptcy Project -- openbankruptcyproject.org --- ## Reading Your Bankruptcy Case File [2026]: PACER, Docket Entries, and Client File Rights Source: https://bankruptcylawyerreview.org/case-file.html bankruptcylawyerreview.org ☰ Home Understanding Your Bankruptcy Case How to Review Your Common Issues in Bankruptcy Your Rights as a How to Read Your Part of the Open Bankruptcy Project - 210+ free domains, 49,000+ pages, $0 hosting Understanding Your Bankruptcy Case File Home›Understanding Your Bankruptcy Case File | bankruptcylawyerreview.org›Understanding Your Bankruptcy Case File What is in your bankruptcy case file Your bankruptcy case file contains every document filed with the court on your behalf. Understanding these documents helps you verify that your case was handled correctly. The petition and schedules Voluntary Petition - The document that officially starts your case. Verify your name, address, and selected chapter are correct Schedule A/B - Lists all your property. Make sure nothing is missing or incorrectly valued Schedule C - Lists the exemptions that protect your property. Verify the correct exemption scheme was used Schedule D - Secured creditors (mortgage, car loans). Check amounts and collateral descriptions Schedule E/F - Priority and unsecured creditors. Verify all debts are listed Schedule I/J - Your income and expenses. These should accurately reflect your financial situation The Statement of Financial Affairs (SOFA) This is a detailed questionnaire about your financial history - income, transfers, lawsuits, payments to creditors, and more. Inaccuracies here can lead to serious problems, including denial of discharge. Accessing your file You can access the court-docket portion of your case through PACER at pacer.uscourts.gov (fees apply, typically $0.10 per page) or by visiting the bankruptcy court clerk's office in person. PACER gives you anything filed with the court. But your complete client file is broader than what's on PACER. It includes everything the firm holds: drafts and worksheets, intake notes, internal memos, fee records, correspondence with you and creditors and the trustee. PACER won't show any of that. For the complete file, you have to ask the firm. Your right to your file: Under ABA Model Rule 1.16(d), when representation ends, your attorney must surrender the client's file on request. The file is your property - not the firm's. If the firm won't give you your file Sometimes the firm refuses, stalls, or claims the file does not exist in the form you are asking for. That refusal is itself meaningful - and there are remedies. Why some firms refuse The reason a high-volume bankruptcy firm sometimes can't produce a unified client file isn't malice - it's that the workflow never built one. In a true mill operation, intake lives in a CRM, the petition was auto-populated by software, "attorney review" was a paralegal forwarding an e-signature page, and communications are scattered across separate systems with nothing tying them together under a single client matter. There is no central folder to hand over. That refusal is the diagnostic. Volume practice that can't reconstruct an individual client's file on demand is the operational definition of a mill. For a deeper read on the workflow tell, see bankruptcymill.org/case-file. Why refusal is a stand-alone disciplinary violation Failure to surrender a client file is a violation of Model Rule 1.16(d) (or its state equivalent) independent of any other complaint about the underlying representation. That matters because: Lower proof burden. You don't have to prove malpractice or harm. You only show: (a) you requested the file, (b) the firm refused or did not produce it within a reasonable time. Separable from fee disputes. The Rule 1.16(d) duty is independent of any fee dispute - the firm cannot hold the file hostage over disputed fees. How to make the request and what to do if it fails Make the request in writing. Email is fine. Be specific: "I am requesting my complete client file in [matter name / case number], including all documents, correspondence, internal notes, and electronic records, pursuant to Model Rule 1.16(d)." Keep a copy. Set a 14-30 day deadline and follow up in writing if it passes. If still no production, file a bar complaint with your state's disciplinary body. For step-by-step guidance, see bankruptcymalpractice.org/client-file. If your case is still active, also notify the U.S. Trustee assigned to your case. The USTP has independent authority to investigate professional conduct. If your attorney has already withdrawn, see firedbymybankruptcylawyer.com/client-file for the post-withdrawal action plan. Pre-hire diligence: If you haven't hired yet, you can pre-empt this entire problem by asking the firm during the consultation: "Will you give me my complete client file on request, in writing, within [N] days?" A firm that hedges is telling you about its workflow. See bankruptcyattorneyratings.org/client-file for the full pre-hire framework. ← Back to bankruptcylawyerreview.org Related Topics 1328(f) Discharge Screener Automatic Stay Guide Means Test Calculator Chapter 7 vs 13 How to File Bankruptcy Affordable Legal Help This site is free and open-source. Donations support the Open Bankruptcy Project, a 501(c)(3) public charity (EIN 41-5159631), funding PACER access fees and bankruptcy court transparency research. Part of the Bankruptcy Transparency Network Real information, no strings. Discharge Screener Open Bankruptcy Project Ch.7 vs Ch.13 Bankruptcy Cost Automatic Stay 341 Meeting Exemptions by State Means Test File Without a Lawyer Rebuild Credit 1099cdebt.com Free bankruptcy education for the public interest. Not legal advice. If you need legal help, contact a licensed attorney in your state. A project of the Open Bankruptcy Project, a 501(c)(3) nonprofit (EIN 41-5159631). Privacy | Terms Our research was cited by the federal judiciary as Suggestion 26-BK-3 This site provides general information, not legal advice. Consult a qualified attorney for your specific situation. You May Also Find Helpful Bankruptcy Means Test by State -- bankruptcymeanstest.org 1099-C Cancellation of Debt Tax Guide -- 1099cdebt.com Open Bankruptcy Project -- openbankruptcyproject.org --- ## Common Bankruptcy Representation Issues [2026]: Communication Gaps, Fee Disputes, and Missed Deadlines Source: https://bankruptcylawyerreview.org/common-issues.html bankruptcylawyerreview.org ☰ Home Understanding Your Bankruptcy Case How to Review Your Common Issues in Bankruptcy Your Rights as a How to Read Your Part of the Open Bankruptcy Project - 210+ free domains, 49,000+ pages, $0 hosting Common Issues in Bankruptcy Representation Home›Common Issues in Bankruptcy Representation | bankruptcylawyerreview.org›Common Issues in Bankruptcy Representation Issues that arise in bankruptcy cases Most bankruptcy cases proceed smoothly. When problems do occur, they often follow recognizable patterns. Filing accuracy problems Missing creditors - If a creditor is not listed in your schedules, that debt may not be discharged Incorrect asset values - Undervaluing assets can lead to trustee objections; overvaluing can reduce available exemptions Wrong exemptions - Each state has different exemption laws. Using the wrong scheme can put assets at risk Income miscalculations - Errors on the means test can result in case dismissal or forced conversion Communication breakdowns Unreturned calls - Attorneys must keep clients reasonably informed under Model Rule 1.4 No explanation of court orders - You should understand what every court order means for your case Surprises at the 341 meeting - Your attorney should prepare you for the trustee's questions Deadline issues Missed filing deadlines - Tax returns, pay stubs, and certificates must be filed within specific timeframes Late plan payments - In Chapter 13, failing to make timely payments can result in dismissal Failure to respond to trustee requests - The trustee can move to dismiss if document requests go unanswered If you spot a problem: First, raise the issue directly with your attorney in writing (email creates a record). If the attorney does not respond or resolve the issue, you can contact the U.S. Trustee's office or your state bar association. ← Back to bankruptcylawyerreview.org Related Topics 1328(f) Discharge Screener Automatic Stay Guide Means Test Calculator Chapter 7 vs 13 How to File Bankruptcy Affordable Legal Help This site is free and open-source. Donations support the Open Bankruptcy Project, a 501(c)(3) public charity (EIN 41-5159631), funding PACER access fees and bankruptcy court transparency research. Part of the Bankruptcy Transparency Network Real information, no strings. Discharge Screener Open Bankruptcy Project Ch.7 vs Ch.13 Bankruptcy Cost Automatic Stay 341 Meeting Exemptions by State Means Test File Without a Lawyer Rebuild Credit 1099cdebt.com Free bankruptcy education for the public interest. Not legal advice. If you need legal help, contact a licensed attorney in your state. A project of the Open Bankruptcy Project, a 501(c)(3) nonprofit (EIN 41-5159631). Privacy | Terms Our research was cited by the federal judiciary as Suggestion 26-BK-3 This site provides general information, not legal advice. Consult a qualified attorney for your specific situation. You May Also Find Helpful Bankruptcy Means Test by State -- bankruptcymeanstest.org 1099-C Cancellation of Debt Tax Guide -- 1099cdebt.com Open Bankruptcy Project -- openbankruptcyproject.org --- ## How to Read Your Bankruptcy Docket [2026]: PACER Entries, BNC Notices, and Critical Filings Source: https://bankruptcylawyerreview.org/docket-reading.html bankruptcylawyerreview.org ☰ Home Understanding Your Bankruptcy Case How to Review Your Common Issues in Bankruptcy Your Rights as a How to Read Your Part of the Open Bankruptcy Project - 210+ free domains, 49,000+ pages, $0 hosting How to Read Your Bankruptcy Docket Home›How to Read Your Bankruptcy Docket | bankruptcylawyerreview.org›How to Read Your Bankruptcy Docket Petition and schedules - Your initial filing documents Proofs of claim - Claims filed by your creditors Court orders - Every order entered by the judge Motions - Requests filed by any party (your attorney, creditors, the trustee) Notices - Meeting dates, deadlines, discharge notices Fee... Understanding the court docket in your case The docket is the court's official record of everything that has happened in your case. Learning to read it gives you direct access to your case status without relying solely on your attorney. What is on the docket Petition and schedules - Your initial filing documents Proofs of claim - Claims filed by your creditors Court orders - Every order entered by the judge Motions - Requests filed by any party (your attorney, creditors, the trustee) Notices - Meeting dates, deadlines, discharge notices Fee disclosures - Your attorney's disclosed compensation How to access the docket PACER (pacer.uscourts.gov) provides online access to bankruptcy court dockets. You need a free PACER account. Documents cost $0.10 per page with a $3.00 cap per document. You can also visit the clerk's office in person. Key docket entries to look for Claims filed vs. claims scheduled - Compare what creditors claim against what your schedules list Deadlines - The claims bar date, discharge deadline, and plan confirmation date Trustee reports - The trustee's report of no distribution (Chapter 7) or plan progress (Chapter 13) Attorney fee disclosures - Compare to what you actually paid Free alternative: The RECAP Archive at courtlistener.com/recap provides free access to millions of PACER documents that have been previously purchased and donated to the public domain. ← Back to bankruptcylawyerreview.org Related Topics 1328(f) Discharge Screener Automatic Stay Guide Means Test Calculator Chapter 7 vs 13 How to File Bankruptcy Affordable Legal Help This site is free and open-source. Donations support the Open Bankruptcy Project, a 501(c)(3) public charity (EIN 41-5159631), funding PACER access fees and bankruptcy court transparency research. Part of the Bankruptcy Transparency Network Real information, no strings. Discharge Screener Open Bankruptcy Project Ch.7 vs Ch.13 Bankruptcy Cost Automatic Stay 341 Meeting Exemptions by State Means Test File Without a Lawyer Rebuild Credit 1099cdebt.com Free bankruptcy education for the public interest. Not legal advice. If you need legal help, contact a licensed attorney in your state. A project of the Open Bankruptcy Project, a 501(c)(3) nonprofit (EIN 41-5159631). Privacy | Terms Our research was cited by the federal judiciary as Suggestion 26-BK-3 This site provides general information, not legal advice. Consult a qualified attorney for your specific situation. You May Also Find Helpful Bankruptcy Means Test by State -- bankruptcymeanstest.org 1099-C Cancellation of Debt Tax Guide -- 1099cdebt.com Open Bankruptcy Project -- openbankruptcyproject.org --- ## How to Review Your Bankruptcy Case [2026 Guide] Source: https://bankruptcylawyerreview.org/ Skip to main content bankruptcylawyerreview.org ☰ Home Understanding Your Bankruptcy Case How to Review Your Common Issues in Bankruptcy Your Rights as a How to Read Your Part of the Open Bankruptcy Project - 210+ free domains, 49,000+ pages, $0 hosting Lawyerreview Bankruptcy - Your Complete Filing Guide for 2026 Understanding your bankruptcy case file, reviewing billing, spotting common issues, and knowing your rights as a client. Practical guidance for evaluating the representation you are receiving. Understanding Your Case File Billing Review You have the right to review every document filed on your behalf - and you should Yes. You have the right to review every document in your bankruptcy case file. You can access the court docket through PACER at pacer.uscourts.gov, visit the clerk's office in person, or request copies from your attorney. Under Model Rule 1.16(d), your attorney must surrender your file when representation ends. Explore this guide Understanding Your Bankruptcy Case File Read our guide on this topic. Read more → How to Review Your Bankruptcy Attorney's Read our guide on this topic. Read more → Common Issues in Bankruptcy Representation Read our guide on this topic. Read more → Your Rights as a Bankruptcy Client Read our guide on this topic. Read more → How to Read Your Bankruptcy Docket Read our guide on this topic. Read more → Frequently asked questions Can I review my bankruptcy case file? Yes. You have the right to review every document in your bankruptcy case file. You can access the court docket through PACER at pacer.uscourts.gov, visit the clerk's office in person, or request copies from your attorney. Under Model Rule 1.16(d), your attorney must surrender your file when representation ends. Before hiring replacement counsel, check bankruptcy attorney ratings and verify their disciplinary history with the state bar. How do I check if my bankruptcy attorney filed everything correctly? Access your case docket through PACER and review the filed schedules and statements. Verify that all creditors are listed, asset values are accurate, income and expenses are correct, and the right exemptions were claimed. Compare the filed documents against your actual financial situation. Can I get a refund if my bankruptcy attorney did a bad job? Possibly. Under 11 U.S.C. Section 329(b), bankruptcy courts can order disgorgement of excessive fees. If your attorney's fees exceed the reasonable value of services provided, you can ask the court to review the fees. You can also file a complaint with the U.S. Trustee's office or your state bar association. What is a bankruptcy attorney required to disclose about fees? Under 11 U.S.C. Section 329 and Bankruptcy Rule 2016, attorneys must file a statement disclosing all compensation paid or agreed to be paid in connection with your bankruptcy case. This disclosure is filed with the court and is part of the public record. How do I file a complaint against my bankruptcy attorney? Contact your state bar association's disciplinary authority to file a formal complaint. You can also raise concerns with the U.S. Trustee's office in your district. For fee-related issues, you can ask the bankruptcy court to review the attorney's compensation under Section 329. If your attorney was part of a bankruptcy mill operation, the U.S. Trustee may already be aware of the firm's patterns. Related Topics 1328(f) Discharge Screener Automatic Stay Guide Means Test Calculator Chapter 7 vs 13 How to File Bankruptcy Affordable Legal Help This site is free and open-source. Donations support the Open Bankruptcy Project, a 501(c)(3) public charity (EIN 41-5159631), funding PACER access fees and bankruptcy court transparency research. Related Guides What Is Mill Law? Understanding high-volume legal practice whatmilllaw.org → What Is a Bankruptcy Mill? Recognize high-volume bankruptcy mills bankruptcymill.org → My Lawyer Won't Call Back When your bankruptcy lawyer won't respond mybankruptcylawyerwontcallback.com → Fired by My Bankruptcy Lawyer What to do when your attorney withdraws firedbymybankruptcylawyer.com → Your Next Questions Real users ask these next - we built the answers. Chapter 7 vs Chapter 13 Understand your case before hiring chapter7vs13.org → How Much Does It Cost? What attorneys should charge by chapter and state howmuchdoesbankruptcycost.com → File Without a Lawyer? When pro se makes sense and when it does not filebankruptcywithoutlawyer.com → How to Find a Good Attorney Data-driven guide to evaluating bankruptcy lawyers 1328f.com → Filing in Your State? Exemptions vary dramatically by state. Check what you can protect. Browse Your State's Exemptions → Get Bankruptcy Updates Free updates from the Open Bankruptcy Project. No spam, unsubscribe anytime. Subscribe You're subscribed. Thank you! Privacy policy Part of the Bankruptcy Transparency Network Real information, no strings. Discharge Screener Open Bankruptcy Project Ch.7 vs Ch.13 Bankruptcy Cost Automatic Stay 341 Meeting Exemptions by State Means Test File Without a Lawyer Rebuild Credit 1099cdebt.com Free bankruptcy education for the public interest. Not legal advice. If you need legal help, contact a licensed attorney in your state. A project of the Open Bankruptcy Project, a 501(c)(3) nonprofit (EIN 41-5159631). Privacy | Terms Our research was cited by the federal judiciary as Suggestion 26-BK-3 This site provides general information, not legal advice. Consult a qualified attorney for your specific situation. Have a Question? Open Bankruptcy Project provides free educational information. We are not a law firm. Nothing on this site constitutes legal advice. For advice about your specific situation, consult a licensed attorney. Select your state... 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You May Also Find Helpful Bankruptcy Means Test by State -- bankruptcymeanstest.org 1099-C Cancellation of Debt Tax Guide -- 1099cdebt.com Open Bankruptcy Project -- openbankruptcyproject.org Most-read OBP guides Brunner Test (§523(a)(8)) 3-prong analysis for discharging student loans Car Loan After Bankruptcy Buy a car and get financing post-discharge Student Loans in Bankruptcy Can you discharge them? 2026 guide Federal Exemptions §522(d) Complete list of federal exemptions Nondischargeable Debts List Debts that survive bankruptcy discharge Site Map Additional resources on this site Index States: District Of Columbia --- ## Bankruptcy Client Rights [2026]: 11 USC 526, 528, and State Rules of Professional Conduct Source: https://bankruptcylawyerreview.org/your-rights.html bankruptcylawyerreview.org ☰ Home Understanding Your Bankruptcy Case How to Review Your Common Issues in Bankruptcy Your Rights as a How to Read Your Part of the Open Bankruptcy Project - 210+ free domains, 49,000+ pages, $0 hosting Your Rights as a Bankruptcy Client Home›Your Rights as a Bankruptcy Client | bankruptcylawyerreview.org›Your Rights as a Bankruptcy Client What you are entitled to as a client As a bankruptcy client, you have specific rights under the law and the Rules of Professional Conduct that govern attorney behavior. Right to competent representation Under Model Rule 1.1, your attorney must provide competent representation, which requires the legal knowledge, skill, thoroughness, and preparation reasonably necessary for your case. Right to communication Under Model Rule 1.4, your attorney must promptly inform you of anything requiring your informed consent, reasonably consult with you about the means of achieving your objectives, keep you reasonably informed about the status of your case, and promptly comply with reasonable requests for information. Right to your case file Your case file belongs to you. Under Model Rule 1.16(d), when representation ends, the attorney must take steps to protect your interests, including surrendering papers and property to which you are entitled. Right to reasonable fees Under Model Rule 1.5 and 11 U.S.C. Section 329, your fees must be reasonable. The bankruptcy court has the power to review fees and order refunds of any excessive amounts. Right to terminate representation You have the right to fire your attorney at any time. In bankruptcy, the attorney must file a motion to withdraw, which requires court approval. You may need to find replacement counsel or proceed pro se. Where to complain: If your attorney violates these obligations, you can file a complaint with your state bar association's disciplinary authority. You can also raise concerns with the U.S. Trustee's office, which oversees the bankruptcy system. ← Back to bankruptcylawyerreview.org Related Topics 1328(f) Discharge Screener Automatic Stay Guide Means Test Calculator Chapter 7 vs 13 How to File Bankruptcy Affordable Legal Help This site is free and open-source. Donations support the Open Bankruptcy Project, a 501(c)(3) public charity (EIN 41-5159631), funding PACER access fees and bankruptcy court transparency research. Part of the Bankruptcy Transparency Network Real information, no strings. Discharge Screener Open Bankruptcy Project Ch.7 vs Ch.13 Bankruptcy Cost Automatic Stay 341 Meeting Exemptions by State Means Test File Without a Lawyer Rebuild Credit 1099cdebt.com Free bankruptcy education for the public interest. Not legal advice. If you need legal help, contact a licensed attorney in your state. A project of the Open Bankruptcy Project, a 501(c)(3) nonprofit (EIN 41-5159631). Privacy | Terms Our research was cited by the federal judiciary as Suggestion 26-BK-3 This site provides general information, not legal advice. Consult a qualified attorney for your specific situation. You May Also Find Helpful Bankruptcy Means Test by State -- bankruptcymeanstest.org 1099-C Cancellation of Debt Tax Guide -- 1099cdebt.com Open Bankruptcy Project -- openbankruptcyproject.org --- ## Privacy Policy - bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/privacy.html bankruptcylawyerreview.org Home Privacy Privacy Policy How we handle your data. 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It's part of the Open Bankruptcy Project - a collection of free, public-interest sites that translate federal bankruptcy court data, statutes, and procedures into language ordinary people can use. The Open Bankruptcy Project The Open Bankruptcy Project builds free, open-source tools that make public bankruptcy court data accessible to the people it affects most - debtors, advocates, researchers, journalists, and policymakers. Every screening tool, analysis script, and dataset is published on GitHub. Anyone can audit, reproduce, or build upon the work without permission or payment. Our research is derived primarily from the Federal Judicial Center's Integrated Database covering all federal bankruptcy filings 2008 through 2024, cross-referenced with PACER docket data via the Free Law Project's RECAP archive and independent court-scraping tooling. Methodology and source code are public. What This Site Is Not This site is not a law firm. 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Home  ·  About  ·  Privacy  ·  Open Bankruptcy Project Part of the Open Bankruptcy Project. Educational information only - not legal advice. No ads. No affiliate links. No data sold. Supported by donations. --- ## Attorney Fee Review in Alabama - Middle (M.D. Ala.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/alabama-middle.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - M.D. Ala. Section 329(b) fee review framework for cases filed in the Alabama - Middle (M.D. Ala.) bankruptcy court. 11th Circuit authority and local practice context. Jurisdiction and Authority The M.D. Ala. bankruptcy court operates within the 11th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 11th Circuit Authority The 11th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for M.D. Ala. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Alabama - Northern (N.D. Ala.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/alabama-northern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - N.D. Ala. Section 329(b) fee review framework for cases filed in the Alabama - Northern (N.D. Ala.) bankruptcy court. 11th Circuit authority and local practice context. Jurisdiction and Authority The N.D. Ala. bankruptcy court operates within the 11th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 11th Circuit Authority The 11th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for N.D. Ala. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Alabama - Southern (S.D. Ala.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/alabama-southern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - S.D. Ala. Section 329(b) fee review framework for cases filed in the Alabama - Southern (S.D. Ala.) bankruptcy court. 11th Circuit authority and local practice context. Jurisdiction and Authority The S.D. Ala. bankruptcy court operates within the 11th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 11th Circuit Authority The 11th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for S.D. Ala. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Alaska (D. Alaska) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/alaska.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - D. Alaska Section 329(b) fee review framework for cases filed in the Alaska (D. Alaska) bankruptcy court. 9th Circuit authority and local practice context. Jurisdiction and Authority The D. Alaska bankruptcy court operates within the 9th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 9th Circuit Authority The 9th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for D. Alaska are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Arizona (D. Ariz.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/arizona.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - D. Ariz. Section 329(b) fee review framework for cases filed in the Arizona (D. Ariz.) bankruptcy court. 9th Circuit authority and local practice context. Jurisdiction and Authority The D. Ariz. bankruptcy court operates within the 9th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 9th Circuit Authority The 9th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for D. Ariz. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Arkansas - Eastern (E.D. Ark.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/arkansas-eastern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - E.D. Ark. Section 329(b) fee review framework for cases filed in the Arkansas - Eastern (E.D. Ark.) bankruptcy court. 8th Circuit authority and local practice context. Jurisdiction and Authority The E.D. Ark. bankruptcy court operates within the 8th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 8th Circuit Authority The 8th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for E.D. Ark. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Arkansas - Western (W.D. Ark.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/arkansas-western.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - W.D. Ark. Section 329(b) fee review framework for cases filed in the Arkansas - Western (W.D. Ark.) bankruptcy court. 8th Circuit authority and local practice context. Jurisdiction and Authority The W.D. Ark. bankruptcy court operates within the 8th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 8th Circuit Authority The 8th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for W.D. Ark. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in California - Central (C.D. Cal.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/california-central.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - C.D. Cal. Section 329(b) fee review framework for cases filed in the California - Central (C.D. Cal.) bankruptcy court. 9th Circuit authority and local practice context. Jurisdiction and Authority The C.D. Cal. bankruptcy court operates within the 9th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 9th Circuit Authority The 9th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for C.D. Cal. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in California - Eastern (E.D. Cal.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/california-eastern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - E.D. Cal. Section 329(b) fee review framework for cases filed in the California - Eastern (E.D. Cal.) bankruptcy court. 9th Circuit authority and local practice context. Jurisdiction and Authority The E.D. Cal. bankruptcy court operates within the 9th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 9th Circuit Authority The 9th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for E.D. Cal. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in California - Northern (N.D. Cal.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/california-northern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - N.D. Cal. Section 329(b) fee review framework for cases filed in the California - Northern (N.D. Cal.) bankruptcy court. 9th Circuit authority and local practice context. Jurisdiction and Authority The N.D. Cal. bankruptcy court operates within the 9th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 9th Circuit Authority The 9th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for N.D. Cal. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in California - Southern (S.D. Cal.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/california-southern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - S.D. Cal. Section 329(b) fee review framework for cases filed in the California - Southern (S.D. Cal.) bankruptcy court. 9th Circuit authority and local practice context. Jurisdiction and Authority The S.D. Cal. bankruptcy court operates within the 9th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 9th Circuit Authority The 9th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for S.D. Cal. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Colorado (D. Colo.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/colorado.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - D. Colo. Section 329(b) fee review framework for cases filed in the Colorado (D. Colo.) bankruptcy court. 10th Circuit authority and local practice context. Jurisdiction and Authority The D. Colo. bankruptcy court operates within the 10th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 10th Circuit Authority The 10th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for D. Colo. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Connecticut (D. Conn.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/connecticut.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - D. Conn. Section 329(b) fee review framework for cases filed in the Connecticut (D. Conn.) bankruptcy court. 2d Circuit authority and local practice context. Jurisdiction and Authority The D. Conn. bankruptcy court operates within the 2d Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 2d Circuit Authority The 2d Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for D. Conn. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in District of Columbia (D.D.C.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/dc.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - D.D.C. Section 329(b) fee review framework for cases filed in the District of Columbia (D.D.C.) bankruptcy court. D.C. Circuit authority and local practice context. Jurisdiction and Authority The D.D.C. bankruptcy court operates within the D.C. Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. D.C. Circuit Authority The D.C. Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for D.D.C. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Delaware (D. Del.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/delaware.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - D. Del. Section 329(b) fee review framework for cases filed in the Delaware (D. Del.) bankruptcy court. 3d Circuit authority and local practice context. Jurisdiction and Authority The D. Del. bankruptcy court operates within the 3d Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 3d Circuit Authority The 3d Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for D. Del. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Florida - Middle (M.D. Fla.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/florida-middle.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - M.D. Fla. Section 329(b) fee review framework for cases filed in the Florida - Middle (M.D. Fla.) bankruptcy court. 11th Circuit authority and local practice context. Jurisdiction and Authority The M.D. Fla. bankruptcy court operates within the 11th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 11th Circuit Authority The 11th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for M.D. Fla. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Florida - Northern (N.D. Fla.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/florida-northern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - N.D. Fla. Section 329(b) fee review framework for cases filed in the Florida - Northern (N.D. Fla.) bankruptcy court. 11th Circuit authority and local practice context. Jurisdiction and Authority The N.D. Fla. bankruptcy court operates within the 11th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 11th Circuit Authority The 11th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for N.D. Fla. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Florida - Southern (S.D. Fla.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/florida-southern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - S.D. Fla. Section 329(b) fee review framework for cases filed in the Florida - Southern (S.D. Fla.) bankruptcy court. 11th Circuit authority and local practice context. Jurisdiction and Authority The S.D. Fla. bankruptcy court operates within the 11th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 11th Circuit Authority The 11th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for S.D. Fla. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Georgia - Middle (M.D. Ga.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/georgia-middle.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - M.D. Ga. Section 329(b) fee review framework for cases filed in the Georgia - Middle (M.D. Ga.) bankruptcy court. 11th Circuit authority and local practice context. Jurisdiction and Authority The M.D. Ga. bankruptcy court operates within the 11th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 11th Circuit Authority The 11th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for M.D. Ga. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Georgia - Northern (N.D. Ga.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/georgia-northern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - N.D. Ga. Section 329(b) fee review framework for cases filed in the Georgia - Northern (N.D. Ga.) bankruptcy court. 11th Circuit authority and local practice context. Jurisdiction and Authority The N.D. Ga. bankruptcy court operates within the 11th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 11th Circuit Authority The 11th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for N.D. Ga. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Georgia - Southern (S.D. Ga.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/georgia-southern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - S.D. Ga. Section 329(b) fee review framework for cases filed in the Georgia - Southern (S.D. Ga.) bankruptcy court. 11th Circuit authority and local practice context. Jurisdiction and Authority The S.D. Ga. bankruptcy court operates within the 11th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 11th Circuit Authority The 11th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for S.D. Ga. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Hawaii (D. Haw.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/hawaii.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - D. Haw. Section 329(b) fee review framework for cases filed in the Hawaii (D. Haw.) bankruptcy court. 9th Circuit authority and local practice context. Jurisdiction and Authority The D. Haw. bankruptcy court operates within the 9th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 9th Circuit Authority The 9th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for D. Haw. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Idaho (D. Idaho) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/idaho.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - D. Idaho Section 329(b) fee review framework for cases filed in the Idaho (D. Idaho) bankruptcy court. 9th Circuit authority and local practice context. Jurisdiction and Authority The D. Idaho bankruptcy court operates within the 9th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 9th Circuit Authority The 9th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for D. Idaho are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Illinois - Central (C.D. Ill.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/illinois-central.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - C.D. Ill. Section 329(b) fee review framework for cases filed in the Illinois - Central (C.D. Ill.) bankruptcy court. 7th Circuit authority and local practice context. Jurisdiction and Authority The C.D. Ill. bankruptcy court operates within the 7th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 7th Circuit Authority The 7th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for C.D. Ill. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Illinois - Northern (N.D. Ill.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/illinois-northern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - N.D. Ill. Section 329(b) fee review framework for cases filed in the Illinois - Northern (N.D. Ill.) bankruptcy court. 7th Circuit authority and local practice context. Jurisdiction and Authority The N.D. Ill. bankruptcy court operates within the 7th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 7th Circuit Authority The 7th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for N.D. Ill. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Illinois - Southern (S.D. Ill.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/illinois-southern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - S.D. Ill. Section 329(b) fee review framework for cases filed in the Illinois - Southern (S.D. Ill.) bankruptcy court. 7th Circuit authority and local practice context. Jurisdiction and Authority The S.D. Ill. bankruptcy court operates within the 7th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 7th Circuit Authority The 7th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for S.D. Ill. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Federal Bankruptcy District Fee Review Guides | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/ bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains District Fee Review Guides All 94 federal bankruptcy districts - jurisdiction-specific fee review framework. Browse by District N.D. Ala. - Alabama - Northern M.D. Ala. - Alabama - Middle S.D. Ala. - Alabama - Southern D. Alaska - Alaska D. Ariz. - Arizona E.D. Ark. - Arkansas - Eastern W.D. Ark. - Arkansas - Western N.D. Cal. - California - Northern E.D. Cal. - California - Eastern C.D. Cal. - California - Central S.D. Cal. - California - Southern D. Colo. - Colorado D. Conn. - Connecticut D. Del. - Delaware D.D.C. - District of Columbia N.D. Fla. - Florida - Northern M.D. Fla. - Florida - Middle S.D. Fla. - Florida - Southern N.D. Ga. - Georgia - Northern M.D. Ga. - Georgia - Middle S.D. Ga. - Georgia - Southern D. Haw. - Hawaii D. Idaho - Idaho N.D. Ill. - Illinois - Northern C.D. Ill. - Illinois - Central S.D. Ill. - Illinois - Southern N.D. Ind. - Indiana - Northern S.D. Ind. - Indiana - Southern N.D. Iowa - Iowa - Northern S.D. Iowa - Iowa - Southern D. Kan. - Kansas E.D. Ky. - Kentucky - Eastern W.D. Ky. - Kentucky - Western E.D. La. - Louisiana - Eastern M.D. La. - Louisiana - Middle W.D. La. - Louisiana - Western D. Me. - Maine D. Md. - Maryland D. Mass. - Massachusetts E.D. Mich. - Michigan - Eastern W.D. Mich. - Michigan - Western D. Minn. - Minnesota N.D. Miss. - Mississippi - Northern S.D. Miss. - Mississippi - Southern E.D. Mo. - Missouri - Eastern W.D. Mo. - Missouri - Western D. Mont. - Montana D. Neb. - Nebraska D. Nev. - Nevada D.N.H. - New Hampshire D.N.J. - New Jersey D.N.M. - New Mexico N.D.N.Y. - New York - Northern E.D.N.Y. - New York - Eastern S.D.N.Y. - New York - Southern W.D.N.Y. - New York - Western E.D.N.C. - North Carolina - Eastern M.D.N.C. - North Carolina - Middle W.D.N.C. - North Carolina - Western D.N.D. - North Dakota N.D. Ohio - Ohio - Northern S.D. Ohio - Ohio - Southern N.D. Okla. - Oklahoma - Northern E.D. Okla. - Oklahoma - Eastern W.D. Okla. - Oklahoma - Western D. Or. - Oregon E.D. Pa. - Pennsylvania - Eastern M.D. Pa. - Pennsylvania - Middle W.D. Pa. - Pennsylvania - Western D.R.I. - Rhode Island D.S.C. - South Carolina D.S.D. - South Dakota E.D. Tenn. - Tennessee - Eastern M.D. Tenn. - Tennessee - Middle W.D. Tenn. - Tennessee - Western N.D. Tex. - Texas - Northern E.D. Tex. - Texas - Eastern S.D. Tex. - Texas - Southern W.D. Tex. - Texas - Western D. Utah - Utah D. Vt. - Vermont E.D. Va. - Virginia - Eastern W.D. Va. - Virginia - Western E.D. Wash. - Washington - Eastern W.D. Wash. - Washington - Western N.D. W. Va. - West Virginia - Northern S.D. W. Va. - West Virginia - Southern E.D. Wis. - Wisconsin - Eastern W.D. Wis. - Wisconsin - Western D. Wyo. - Wyoming Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 Most-read OBP guides Brunner Test (§523(a)(8)) 3-prong analysis for discharging student loans Car Loan After Bankruptcy Buy a car and get financing post-discharge Student Loans in Bankruptcy Can you discharge them? 2026 guide Federal Exemptions §522(d) Complete list of federal exemptions Nondischargeable Debts List Debts that survive bankruptcy discharge --- ## Attorney Fee Review in Indiana - Northern (N.D. Ind.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/indiana-northern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - N.D. Ind. Section 329(b) fee review framework for cases filed in the Indiana - Northern (N.D. Ind.) bankruptcy court. 7th Circuit authority and local practice context. Jurisdiction and Authority The N.D. Ind. bankruptcy court operates within the 7th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 7th Circuit Authority The 7th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for N.D. Ind. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Indiana - Southern (S.D. Ind.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/indiana-southern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - S.D. Ind. Section 329(b) fee review framework for cases filed in the Indiana - Southern (S.D. Ind.) bankruptcy court. 7th Circuit authority and local practice context. Jurisdiction and Authority The S.D. Ind. bankruptcy court operates within the 7th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 7th Circuit Authority The 7th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for S.D. Ind. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Iowa - Northern (N.D. Iowa) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/iowa-northern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - N.D. Iowa Section 329(b) fee review framework for cases filed in the Iowa - Northern (N.D. Iowa) bankruptcy court. 8th Circuit authority and local practice context. Jurisdiction and Authority The N.D. Iowa bankruptcy court operates within the 8th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 8th Circuit Authority The 8th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for N.D. Iowa are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Iowa - Southern (S.D. Iowa) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/iowa-southern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - S.D. Iowa Section 329(b) fee review framework for cases filed in the Iowa - Southern (S.D. Iowa) bankruptcy court. 8th Circuit authority and local practice context. Jurisdiction and Authority The S.D. Iowa bankruptcy court operates within the 8th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 8th Circuit Authority The 8th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for S.D. Iowa are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Kansas (D. Kan.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/kansas.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - D. Kan. Section 329(b) fee review framework for cases filed in the Kansas (D. Kan.) bankruptcy court. 10th Circuit authority and local practice context. Jurisdiction and Authority The D. Kan. bankruptcy court operates within the 10th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 10th Circuit Authority The 10th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for D. Kan. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Kentucky - Eastern (E.D. Ky.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/kentucky-eastern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - E.D. Ky. Section 329(b) fee review framework for cases filed in the Kentucky - Eastern (E.D. Ky.) bankruptcy court. 6th Circuit authority and local practice context. Jurisdiction and Authority The E.D. Ky. bankruptcy court operates within the 6th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 6th Circuit Authority The 6th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for E.D. Ky. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Kentucky - Western (W.D. Ky.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/kentucky-western.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - W.D. Ky. Section 329(b) fee review framework for cases filed in the Kentucky - Western (W.D. Ky.) bankruptcy court. 6th Circuit authority and local practice context. Jurisdiction and Authority The W.D. Ky. bankruptcy court operates within the 6th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 6th Circuit Authority The 6th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for W.D. Ky. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Louisiana - Eastern (E.D. La.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/louisiana-eastern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - E.D. La. Section 329(b) fee review framework for cases filed in the Louisiana - Eastern (E.D. La.) bankruptcy court. 5th Circuit authority and local practice context. Jurisdiction and Authority The E.D. La. bankruptcy court operates within the 5th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 5th Circuit Authority The 5th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for E.D. La. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Louisiana - Middle (M.D. La.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/louisiana-middle.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - M.D. La. Section 329(b) fee review framework for cases filed in the Louisiana - Middle (M.D. La.) bankruptcy court. 5th Circuit authority and local practice context. Jurisdiction and Authority The M.D. La. bankruptcy court operates within the 5th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 5th Circuit Authority The 5th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for M.D. La. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Louisiana - Western (W.D. La.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/louisiana-western.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - W.D. La. Section 329(b) fee review framework for cases filed in the Louisiana - Western (W.D. La.) bankruptcy court. 5th Circuit authority and local practice context. Jurisdiction and Authority The W.D. La. bankruptcy court operates within the 5th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 5th Circuit Authority The 5th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for W.D. La. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Maine (D. Me.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/maine.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - D. Me. Section 329(b) fee review framework for cases filed in the Maine (D. Me.) bankruptcy court. 1st Circuit authority and local practice context. Jurisdiction and Authority The D. Me. bankruptcy court operates within the 1st Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 1st Circuit Authority The 1st Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for D. Me. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Maryland (D. Md.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/maryland.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - D. Md. Section 329(b) fee review framework for cases filed in the Maryland (D. Md.) bankruptcy court. 4th Circuit authority and local practice context. Jurisdiction and Authority The D. Md. bankruptcy court operates within the 4th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 4th Circuit Authority The 4th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for D. Md. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Massachusetts (D. Mass.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/massachusetts.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - D. Mass. Section 329(b) fee review framework for cases filed in the Massachusetts (D. Mass.) bankruptcy court. 1st Circuit authority and local practice context. Jurisdiction and Authority The D. Mass. bankruptcy court operates within the 1st Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 1st Circuit Authority The 1st Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for D. Mass. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Michigan - Eastern (E.D. Mich.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/michigan-eastern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - E.D. Mich. Section 329(b) fee review framework for cases filed in the Michigan - Eastern (E.D. Mich.) bankruptcy court. 6th Circuit authority and local practice context. Jurisdiction and Authority The E.D. Mich. bankruptcy court operates within the 6th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 6th Circuit Authority The 6th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for E.D. Mich. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Michigan - Western (W.D. Mich.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/michigan-western.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - W.D. Mich. Section 329(b) fee review framework for cases filed in the Michigan - Western (W.D. Mich.) bankruptcy court. 6th Circuit authority and local practice context. Jurisdiction and Authority The W.D. Mich. bankruptcy court operates within the 6th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 6th Circuit Authority The 6th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for W.D. Mich. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Minnesota (D. Minn.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/minnesota.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - D. Minn. Section 329(b) fee review framework for cases filed in the Minnesota (D. Minn.) bankruptcy court. 8th Circuit authority and local practice context. Jurisdiction and Authority The D. Minn. bankruptcy court operates within the 8th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 8th Circuit Authority The 8th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for D. Minn. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Mississippi - Northern (N.D. Miss.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/mississippi-northern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - N.D. Miss. Section 329(b) fee review framework for cases filed in the Mississippi - Northern (N.D. Miss.) bankruptcy court. 5th Circuit authority and local practice context. Jurisdiction and Authority The N.D. Miss. bankruptcy court operates within the 5th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 5th Circuit Authority The 5th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for N.D. Miss. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Mississippi - Southern (S.D. Miss.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/mississippi-southern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - S.D. Miss. Section 329(b) fee review framework for cases filed in the Mississippi - Southern (S.D. Miss.) bankruptcy court. 5th Circuit authority and local practice context. Jurisdiction and Authority The S.D. Miss. bankruptcy court operates within the 5th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 5th Circuit Authority The 5th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for S.D. Miss. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Missouri - Eastern (E.D. Mo.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/missouri-eastern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - E.D. Mo. Section 329(b) fee review framework for cases filed in the Missouri - Eastern (E.D. Mo.) bankruptcy court. 8th Circuit authority and local practice context. Jurisdiction and Authority The E.D. Mo. bankruptcy court operates within the 8th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 8th Circuit Authority The 8th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for E.D. Mo. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Missouri - Western (W.D. Mo.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/missouri-western.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - W.D. Mo. Section 329(b) fee review framework for cases filed in the Missouri - Western (W.D. Mo.) bankruptcy court. 8th Circuit authority and local practice context. Jurisdiction and Authority The W.D. Mo. bankruptcy court operates within the 8th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 8th Circuit Authority The 8th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for W.D. Mo. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Montana (D. Mont.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/montana.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - D. Mont. Section 329(b) fee review framework for cases filed in the Montana (D. Mont.) bankruptcy court. 9th Circuit authority and local practice context. Jurisdiction and Authority The D. Mont. bankruptcy court operates within the 9th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 9th Circuit Authority The 9th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for D. Mont. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Nebraska (D. Neb.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/nebraska.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - D. Neb. Section 329(b) fee review framework for cases filed in the Nebraska (D. Neb.) bankruptcy court. 8th Circuit authority and local practice context. Jurisdiction and Authority The D. Neb. bankruptcy court operates within the 8th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 8th Circuit Authority The 8th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for D. Neb. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Nevada (D. Nev.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/nevada.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - D. Nev. Section 329(b) fee review framework for cases filed in the Nevada (D. Nev.) bankruptcy court. 9th Circuit authority and local practice context. Jurisdiction and Authority The D. Nev. bankruptcy court operates within the 9th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 9th Circuit Authority The 9th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for D. Nev. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in New Hampshire (D.N.H.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/new-hampshire.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - D.N.H. Section 329(b) fee review framework for cases filed in the New Hampshire (D.N.H.) bankruptcy court. 1st Circuit authority and local practice context. Jurisdiction and Authority The D.N.H. bankruptcy court operates within the 1st Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 1st Circuit Authority The 1st Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for D.N.H. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in New Jersey (D.N.J.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/new-jersey.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - D.N.J. Section 329(b) fee review framework for cases filed in the New Jersey (D.N.J.) bankruptcy court. 3d Circuit authority and local practice context. Jurisdiction and Authority The D.N.J. bankruptcy court operates within the 3d Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 3d Circuit Authority The 3d Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for D.N.J. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in New Mexico (D.N.M.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/new-mexico.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - D.N.M. Section 329(b) fee review framework for cases filed in the New Mexico (D.N.M.) bankruptcy court. 10th Circuit authority and local practice context. Jurisdiction and Authority The D.N.M. bankruptcy court operates within the 10th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 10th Circuit Authority The 10th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for D.N.M. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in New York - Eastern (E.D.N.Y.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/new-york-eastern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - E.D.N.Y. Section 329(b) fee review framework for cases filed in the New York - Eastern (E.D.N.Y.) bankruptcy court. 2d Circuit authority and local practice context. Jurisdiction and Authority The E.D.N.Y. bankruptcy court operates within the 2d Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 2d Circuit Authority The 2d Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for E.D.N.Y. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in New York - Northern (N.D.N.Y.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/new-york-northern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - N.D.N.Y. Section 329(b) fee review framework for cases filed in the New York - Northern (N.D.N.Y.) bankruptcy court. 2d Circuit authority and local practice context. Jurisdiction and Authority The N.D.N.Y. bankruptcy court operates within the 2d Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 2d Circuit Authority The 2d Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for N.D.N.Y. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in New York - Southern (S.D.N.Y.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/new-york-southern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - S.D.N.Y. Section 329(b) fee review framework for cases filed in the New York - Southern (S.D.N.Y.) bankruptcy court. 2d Circuit authority and local practice context. Jurisdiction and Authority The S.D.N.Y. bankruptcy court operates within the 2d Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 2d Circuit Authority The 2d Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for S.D.N.Y. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in New York - Western (W.D.N.Y.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/new-york-western.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - W.D.N.Y. Section 329(b) fee review framework for cases filed in the New York - Western (W.D.N.Y.) bankruptcy court. 2d Circuit authority and local practice context. Jurisdiction and Authority The W.D.N.Y. bankruptcy court operates within the 2d Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 2d Circuit Authority The 2d Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for W.D.N.Y. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in North Carolina - Eastern (E.D.N.C.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/north-carolina-eastern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - E.D.N.C. Section 329(b) fee review framework for cases filed in the North Carolina - Eastern (E.D.N.C.) bankruptcy court. 4th Circuit authority and local practice context. Jurisdiction and Authority The E.D.N.C. bankruptcy court operates within the 4th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 4th Circuit Authority The 4th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for E.D.N.C. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in North Carolina - Middle (M.D.N.C.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/north-carolina-middle.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - M.D.N.C. Section 329(b) fee review framework for cases filed in the North Carolina - Middle (M.D.N.C.) bankruptcy court. 4th Circuit authority and local practice context. Jurisdiction and Authority The M.D.N.C. bankruptcy court operates within the 4th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 4th Circuit Authority The 4th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for M.D.N.C. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in North Carolina - Western (W.D.N.C.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/north-carolina-western.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - W.D.N.C. Section 329(b) fee review framework for cases filed in the North Carolina - Western (W.D.N.C.) bankruptcy court. 4th Circuit authority and local practice context. Jurisdiction and Authority The W.D.N.C. bankruptcy court operates within the 4th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 4th Circuit Authority The 4th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for W.D.N.C. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in North Dakota (D.N.D.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/north-dakota.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - D.N.D. Section 329(b) fee review framework for cases filed in the North Dakota (D.N.D.) bankruptcy court. 8th Circuit authority and local practice context. Jurisdiction and Authority The D.N.D. bankruptcy court operates within the 8th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 8th Circuit Authority The 8th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for D.N.D. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Ohio - Northern (N.D. Ohio) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/ohio-northern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - N.D. Ohio Section 329(b) fee review framework for cases filed in the Ohio - Northern (N.D. Ohio) bankruptcy court. 6th Circuit authority and local practice context. Jurisdiction and Authority The N.D. Ohio bankruptcy court operates within the 6th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 6th Circuit Authority The 6th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for N.D. Ohio are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Ohio - Southern (S.D. Ohio) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/ohio-southern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - S.D. Ohio Section 329(b) fee review framework for cases filed in the Ohio - Southern (S.D. Ohio) bankruptcy court. 6th Circuit authority and local practice context. Jurisdiction and Authority The S.D. Ohio bankruptcy court operates within the 6th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 6th Circuit Authority The 6th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for S.D. Ohio are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Oklahoma - Eastern (E.D. Okla.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/oklahoma-eastern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - E.D. Okla. Section 329(b) fee review framework for cases filed in the Oklahoma - Eastern (E.D. Okla.) bankruptcy court. 10th Circuit authority and local practice context. Jurisdiction and Authority The E.D. Okla. bankruptcy court operates within the 10th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 10th Circuit Authority The 10th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for E.D. Okla. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Oklahoma - Northern (N.D. Okla.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/oklahoma-northern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - N.D. Okla. Section 329(b) fee review framework for cases filed in the Oklahoma - Northern (N.D. Okla.) bankruptcy court. 10th Circuit authority and local practice context. Jurisdiction and Authority The N.D. Okla. bankruptcy court operates within the 10th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 10th Circuit Authority The 10th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for N.D. Okla. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Oklahoma - Western (W.D. Okla.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/oklahoma-western.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - W.D. Okla. Section 329(b) fee review framework for cases filed in the Oklahoma - Western (W.D. Okla.) bankruptcy court. 10th Circuit authority and local practice context. Jurisdiction and Authority The W.D. Okla. bankruptcy court operates within the 10th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 10th Circuit Authority The 10th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for W.D. Okla. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Oregon (D. Or.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/oregon.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - D. Or. Section 329(b) fee review framework for cases filed in the Oregon (D. Or.) bankruptcy court. 9th Circuit authority and local practice context. Jurisdiction and Authority The D. Or. bankruptcy court operates within the 9th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 9th Circuit Authority The 9th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for D. Or. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Pennsylvania - Eastern (E.D. Pa.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/pennsylvania-eastern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - E.D. Pa. Section 329(b) fee review framework for cases filed in the Pennsylvania - Eastern (E.D. Pa.) bankruptcy court. 3d Circuit authority and local practice context. Jurisdiction and Authority The E.D. Pa. bankruptcy court operates within the 3d Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 3d Circuit Authority The 3d Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for E.D. Pa. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Pennsylvania - Middle (M.D. Pa.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/pennsylvania-middle.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - M.D. Pa. Section 329(b) fee review framework for cases filed in the Pennsylvania - Middle (M.D. Pa.) bankruptcy court. 3d Circuit authority and local practice context. Jurisdiction and Authority The M.D. Pa. bankruptcy court operates within the 3d Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 3d Circuit Authority The 3d Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for M.D. Pa. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Pennsylvania - Western (W.D. Pa.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/pennsylvania-western.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - W.D. Pa. Section 329(b) fee review framework for cases filed in the Pennsylvania - Western (W.D. Pa.) bankruptcy court. 3d Circuit authority and local practice context. Jurisdiction and Authority The W.D. Pa. bankruptcy court operates within the 3d Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 3d Circuit Authority The 3d Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for W.D. Pa. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Rhode Island (D.R.I.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/rhode-island.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - D.R.I. Section 329(b) fee review framework for cases filed in the Rhode Island (D.R.I.) bankruptcy court. 1st Circuit authority and local practice context. Jurisdiction and Authority The D.R.I. bankruptcy court operates within the 1st Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 1st Circuit Authority The 1st Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for D.R.I. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in South Carolina (D.S.C.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/south-carolina.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - D.S.C. Section 329(b) fee review framework for cases filed in the South Carolina (D.S.C.) bankruptcy court. 4th Circuit authority and local practice context. Jurisdiction and Authority The D.S.C. bankruptcy court operates within the 4th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 4th Circuit Authority The 4th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for D.S.C. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in South Dakota (D.S.D.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/south-dakota.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - D.S.D. Section 329(b) fee review framework for cases filed in the South Dakota (D.S.D.) bankruptcy court. 8th Circuit authority and local practice context. Jurisdiction and Authority The D.S.D. bankruptcy court operates within the 8th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 8th Circuit Authority The 8th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for D.S.D. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Tennessee - Eastern (E.D. Tenn.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/tennessee-eastern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - E.D. Tenn. Section 329(b) fee review framework for cases filed in the Tennessee - Eastern (E.D. Tenn.) bankruptcy court. 6th Circuit authority and local practice context. Jurisdiction and Authority The E.D. Tenn. bankruptcy court operates within the 6th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 6th Circuit Authority The 6th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for E.D. Tenn. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Tennessee - Middle (M.D. Tenn.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/tennessee-middle.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - M.D. Tenn. Section 329(b) fee review framework for cases filed in the Tennessee - Middle (M.D. Tenn.) bankruptcy court. 6th Circuit authority and local practice context. Jurisdiction and Authority The M.D. Tenn. bankruptcy court operates within the 6th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 6th Circuit Authority The 6th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for M.D. Tenn. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Tennessee - Western (W.D. Tenn.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/tennessee-western.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - W.D. Tenn. Section 329(b) fee review framework for cases filed in the Tennessee - Western (W.D. Tenn.) bankruptcy court. 6th Circuit authority and local practice context. Jurisdiction and Authority The W.D. Tenn. bankruptcy court operates within the 6th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 6th Circuit Authority The 6th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for W.D. Tenn. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Texas - Eastern (E.D. Tex.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/texas-eastern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - E.D. Tex. Section 329(b) fee review framework for cases filed in the Texas - Eastern (E.D. Tex.) bankruptcy court. 5th Circuit authority and local practice context. Jurisdiction and Authority The E.D. Tex. bankruptcy court operates within the 5th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 5th Circuit Authority The 5th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for E.D. Tex. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Texas - Northern (N.D. Tex.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/texas-northern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - N.D. Tex. Section 329(b) fee review framework for cases filed in the Texas - Northern (N.D. Tex.) bankruptcy court. 5th Circuit authority and local practice context. Jurisdiction and Authority The N.D. Tex. bankruptcy court operates within the 5th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 5th Circuit Authority The 5th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for N.D. Tex. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Texas - Southern (S.D. Tex.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/texas-southern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - S.D. Tex. Section 329(b) fee review framework for cases filed in the Texas - Southern (S.D. Tex.) bankruptcy court. 5th Circuit authority and local practice context. Jurisdiction and Authority The S.D. Tex. bankruptcy court operates within the 5th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 5th Circuit Authority The 5th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for S.D. Tex. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Texas - Western (W.D. Tex.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/texas-western.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - W.D. Tex. Section 329(b) fee review framework for cases filed in the Texas - Western (W.D. Tex.) bankruptcy court. 5th Circuit authority and local practice context. Jurisdiction and Authority The W.D. Tex. bankruptcy court operates within the 5th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 5th Circuit Authority The 5th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for W.D. Tex. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Utah (D. Utah) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/utah.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - D. Utah Section 329(b) fee review framework for cases filed in the Utah (D. Utah) bankruptcy court. 10th Circuit authority and local practice context. Jurisdiction and Authority The D. Utah bankruptcy court operates within the 10th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 10th Circuit Authority The 10th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for D. Utah are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Vermont (D. Vt.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/vermont.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - D. Vt. Section 329(b) fee review framework for cases filed in the Vermont (D. Vt.) bankruptcy court. 2d Circuit authority and local practice context. Jurisdiction and Authority The D. Vt. bankruptcy court operates within the 2d Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 2d Circuit Authority The 2d Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for D. Vt. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Virginia - Eastern (E.D. Va.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/virginia-eastern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - E.D. Va. Section 329(b) fee review framework for cases filed in the Virginia - Eastern (E.D. Va.) bankruptcy court. 4th Circuit authority and local practice context. Jurisdiction and Authority The E.D. Va. bankruptcy court operates within the 4th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 4th Circuit Authority The 4th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for E.D. Va. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Virginia - Western (W.D. Va.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/virginia-western.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - W.D. Va. Section 329(b) fee review framework for cases filed in the Virginia - Western (W.D. Va.) bankruptcy court. 4th Circuit authority and local practice context. Jurisdiction and Authority The W.D. Va. bankruptcy court operates within the 4th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 4th Circuit Authority The 4th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for W.D. Va. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Washington - Eastern (E.D. Wash.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/washington-eastern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - E.D. Wash. Section 329(b) fee review framework for cases filed in the Washington - Eastern (E.D. Wash.) bankruptcy court. 9th Circuit authority and local practice context. Jurisdiction and Authority The E.D. Wash. bankruptcy court operates within the 9th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 9th Circuit Authority The 9th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for E.D. Wash. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Washington - Western (W.D. Wash.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/washington-western.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - W.D. Wash. Section 329(b) fee review framework for cases filed in the Washington - Western (W.D. Wash.) bankruptcy court. 9th Circuit authority and local practice context. Jurisdiction and Authority The W.D. Wash. bankruptcy court operates within the 9th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 9th Circuit Authority The 9th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for W.D. Wash. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in West Virginia - Northern (N.D. W. Va.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/west-virginia-northern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - N.D. W. Va. Section 329(b) fee review framework for cases filed in the West Virginia - Northern (N.D. W. Va.) bankruptcy court. 4th Circuit authority and local practice context. Jurisdiction and Authority The N.D. W. Va. bankruptcy court operates within the 4th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 4th Circuit Authority The 4th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for N.D. W. Va. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in West Virginia - Southern (S.D. W. Va.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/west-virginia-southern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - S.D. W. Va. Section 329(b) fee review framework for cases filed in the West Virginia - Southern (S.D. W. Va.) bankruptcy court. 4th Circuit authority and local practice context. Jurisdiction and Authority The S.D. W. Va. bankruptcy court operates within the 4th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 4th Circuit Authority The 4th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for S.D. W. Va. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Wisconsin - Eastern (E.D. Wis.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/wisconsin-eastern.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - E.D. Wis. Section 329(b) fee review framework for cases filed in the Wisconsin - Eastern (E.D. Wis.) bankruptcy court. 7th Circuit authority and local practice context. Jurisdiction and Authority The E.D. Wis. bankruptcy court operates within the 7th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 7th Circuit Authority The 7th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for E.D. Wis. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Wisconsin - Western (W.D. Wis.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/wisconsin-western.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - W.D. Wis. Section 329(b) fee review framework for cases filed in the Wisconsin - Western (W.D. Wis.) bankruptcy court. 7th Circuit authority and local practice context. Jurisdiction and Authority The W.D. Wis. bankruptcy court operates within the 7th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 7th Circuit Authority The 7th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for W.D. Wis. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Wyoming (D. Wyo.) | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/districts/wyoming.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review - D. Wyo. Section 329(b) fee review framework for cases filed in the Wyoming (D. Wyo.) bankruptcy court. 10th Circuit authority and local practice context. Jurisdiction and Authority The D. Wyo. bankruptcy court operates within the 10th Circuit. Attorney fee review in this district proceeds under 11 U.S.C. Sections 329 and 330, Federal Rule of Bankruptcy Procedure 2016(b) (disclosure), and Rule 2017 (procedural vehicle for fee review). 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." Any party in interest, including the debtor, trustee, U.S. Trustee, or any creditor, may move for fee review. The bankruptcy court may also raise the issue on its own motion under Rule 2017. 10th Circuit Authority The 10th Circuit's fee-review framework combines the lodestar methodology with the Section 330(a)(3) factors. The leading cases applying this framework are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). Key concepts applied in every circuit: Disclosure prong: Section 329(a) and Rule 2016(b) require complete and timely disclosure of all compensation. Failure is independently sanctionable. Reasonableness prong: The Section 330(a)(3) factors - time spent, rates charged, necessity and benefit, timeliness, skill, and comparable non-bankruptcy compensation. Remedy prong: Full disgorgement is the presumptive remedy for disclosure failures; partial reduction is available for reasonableness-only challenges. Procedural authority: Rule 2017 motion, U.S. Trustee Section 307 standing, and Court sua sponte review. The Three Documents Every fee review analysis begins with three documents: The Rule 2016(b) disclosure statement - filed at the opening of the case and supplemented when the fee arrangement changes The fee application (if filed) - typically required in Chapter 11 and Subchapter V; may be optional in consumer Chapter 7/13 The complete billing record - time entries, task descriptions, rates, and amounts charged Discrepancies among the three documents are the strongest evidence of a Section 329 violation. See billing review methodology for line-by-line analysis. Local Practice Considerations Each bankruptcy court maintains local rules and presumptive fee ("no-look") guidelines. Common variations: Consumer Chapter 13 no-look fees (typical range $3,000 - $5,500, varies by district) Fee application timing and form requirements Interim compensation procedures in Chapter 11 and Subchapter V Trustee compensation separate from debtor's counsel fees Local rules for D. Wyo. are available on the court's website. Section 329(b) applies in every district regardless of local no-look fees - a presumptive fee is not a safe harbor against a reasonableness challenge. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map How to structure a Section 329(b) motion U.S. Trustee fee review process Line-by-line billing audit methodology Common fee issues Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Engagement Letter Review Checklist - Bankruptcy Attorney Retainer Agreements Source: https://bankruptcylawyerreview.org/engagement-letter-review.html bankruptcylawyerreview.org HomeBilling ReviewLodestarWorked ExamplesServices AuditNo-Look FeesEngagement LetterState Guides Engagement Letter Review Checklist Before you sign a retainer agreement with a bankruptcy attorney, read through this checklist. Each item is something that should be clear in writing. If it is not clear, ask. If the attorney will not clarify in writing, that is itself an answer. Why the Engagement Letter Matters The engagement letter (also called "retainer agreement" or "fee agreement") is the contract between you and your bankruptcy attorney. It is the document that defines: Exactly what work the attorney will do for you How much you pay, when, and to whom What happens if something changes (conversion, dismissal, adversary, contested matter) What services are excluded and require an additional fee Key principle: The engagement letter is the best evidence of what you actually agreed to. If a dispute arises later about scope, fees, or duty, the written document controls - not verbal assurances. The same letter is also the evidence used by the court and the U.S. Trustee under Rule 2016(b) to evaluate whether the attorney's Section 329(a) disclosure matches reality. Section 1 - Basic Terms (Must Be in Writing) ✓Attorney's legal name and bar number. Not just the firm name - the specific attorney responsible for your case. ✓Bar admission information. Which state bars the attorney is admitted in. Critical if your case is in a state where the attorney is not primarily admitted. ✓Date of the engagement letter. With space for your signature date. ✓Client identity. Are you signing personally, on behalf of a business, or both? This determines who the attorney represents. ✓Chapter of bankruptcy covered. Chapter 7? Chapter 13? Chapter 11 (Subchapter V or standard)? The scope is chapter-specific. Section 2 - Scope of Services This is the most important section to read carefully. An ambiguous scope is how attorneys later justify charging extra fees. ✓What services are included? Petition preparation, schedules, SOFA, Section 341 meeting, plan confirmation, and any chapter-specific routine work should be listed explicitly. ✓What services are excluded? Common exclusions: adversary proceedings, contested confirmation, stay relief litigation, objections to claims, plan modifications, dischargeability disputes, tax litigation. ✓How are excluded services handled? Separate hourly rate? Separate retainer? Written amendment to engagement? Get the process in writing. ✓Conversion between chapters. What happens to the fee arrangement if Chapter 7 converts to 13, or 13 converts to 7, or 11 converts to 7? ✓Dismissal. What happens if the case is dismissed before discharge or confirmation? Is any portion of the fee refundable? Under what circumstances? Common trap: "Scope of representation includes all matters necessary to conclude the bankruptcy case." This phrasing is so broad it means nothing - and it lets the attorney later define "necessary" however they want. Ask for specific scope. Section 3 - Fees and Payment ✓Total fee amount (if flat fee). The single dollar figure, stated plainly. ✓Hourly rates (if hourly). Rate for each person who may bill - lead attorney, associate, paralegal, staff. If multiple rates, list each. ✓Minimum retainer required. Up-front payment before work begins. Where is it held? In a trust account? ✓Draw-down mechanism. If a retainer is held in trust, when and how does the attorney draw against it? ✓Filing fees and costs. Are court filing fees, credit counseling fees, and copy charges included in the fee or billed separately? ✓Payment schedule. Pre-petition installments? Through-the-plan payments? Post-petition deferred arrangements? ✓Billing frequency. How often will you receive an itemized invoice? What information will each invoice include? Under Rule 2016(b), your attorney must file a statement of compensation with the court disclosing the fee arrangement. Ask for a copy of what they intend to file. Section 4 - Source of Payment ✓Who is paying? Debtor personally, spouse, family member, business, third party? ✓If a third party is paying, who do they represent? This matters for conflict-of-interest analysis. ✓If a business is paying for an individual case (or vice versa), is that disclosed in the engagement letter and in Rule 2016(b)? ✓Any guarantors - i.e., someone other than the client who has agreed to pay if the client does not? All of these must be disclosed to the court. See the Rule 2016(b) red flags checklist for how these issues play out downstream. Section 5 - Conflicts of Interest ✓Does the attorney represent any creditor that has a claim in your case? ✓Does the attorney represent your spouse if your spouse is not jointly filing? ✓Does the attorney represent a business you own? Or a business partner, co-owner, or co-signer? ✓In Subchapter V: the attorney representing the debtor must meet the disinterestedness requirement of Section 1195/327. The engagement should reference this. ✓Fee-sharing arrangements with non-attorneys (petition preparers, lead-generation services, referral platforms) must be disclosed. Section 6 - Communication and Staffing ✓Who is the primary attorney you will communicate with? ✓Will other attorneys or staff work on your case? At what rates? ✓Who will appear at the Section 341 meeting - the attorney personally, or a substitute? ✓How quickly will the attorney respond to your emails or calls? What is the expected turnaround? ✓Will you receive copies of filings, court orders, trustee correspondence, and creditor claims? Section 7 - Termination and Withdrawal ✓How can you terminate the engagement? What notice is required? ✓How can the attorney withdraw? In a filed case, withdrawal requires court approval; the engagement should acknowledge this. ✓If the attorney withdraws, what portion of the fee is refundable? And when? ✓Does the attorney have a retaining lien on your file? What conditions apply? ✓What happens to your client file after representation ends? Electronic copy? Paper copy? Who pays for retrieval? Section 8 - Dispute Resolution and Fee Review ✓Does the engagement require arbitration of fee disputes? Binding arbitration waives your right to go to court. ✓Does the engagement waive your right to challenge fees under Section 329(b)? It cannot. Any such waiver is void as against the statutory supervisory authority of the bankruptcy court. But some engagements try. ✓Does the engagement require that you first pay disputed amounts before challenging them? This is separate from waiver and can be negotiated. ✓Does the engagement require any confidentiality provisions that would prevent you from disclosing fee arrangements to the court or UST? It cannot. Bankruptcy disclosure obligations override any private confidentiality agreement. Red flag: If an engagement letter contains a clause preventing you from challenging fees in the bankruptcy court or disclosing them to the UST, that clause is not enforceable. But the presence of such a clause tells you something about the attorney's posture. Section 9 - Specific Subchapter V Considerations If the case is a Subchapter V small-business reorganization, additional items should appear: ✓Employment application acknowledgment. The attorney will file an application to be employed under Section 1195/327. Is this covered in the engagement? ✓Court approval of post-petition fees. Post-petition fees are paid from the estate only after court approval of a fee application under Rule 2016(a). The engagement should explain this mechanism. ✓Interaction with the Subchapter V trustee. The Subchapter V trustee has an independent role under Section 1183. The engagement should acknowledge the trustee's involvement and how your attorney will coordinate. ✓Plan filing timeline. Plans must be filed within 90 days of the order for relief (Section 1189(b)). Who is responsible for meeting this deadline, and what happens if missed? Red Flags Summary Walk away (or ask serious questions) if any of these appear: Scope described only in general terms, no specific services listed Attorney refuses to put additional assurances in writing Fee quoted verbally as "around" or "approximately" a number, not in writing No clear explanation of what happens on dismissal or conversion Arbitration clause that waives court oversight Clause prohibiting disclosure of fees to the UST or court Payment required to a non-attorney entity or third party No mention of Rule 2016(b) disclosure "Fee is non-refundable regardless of outcome" language without exception Engagement letter not signed by the specific attorney who will represent you If You Already Signed an Engagement Letter If you are already in a case and have concerns about the engagement letter, you still have options: Request a copy if you do not have one. Attorneys must provide clients with copies of engagement agreements on request. Review against what was disclosed to the court under Rule 2016(b). Discrepancies may be actionable. Request itemized billing for all work performed. You are entitled to a detailed accounting. Consult an independent attorney about fee reasonableness. A second opinion is often available for a fixed consultation fee. Contact the U.S. Trustee if the arrangement involves undisclosed terms, excessive fees, or conflicts of interest. File a Section 329(b) motion through independent counsel, or request Rule 2017 sua sponte review by the court. Related Resources Line-by-line billing audit methodology Lodestar methodology Lodestar worked examples Services-rendered vs services-charged audit Chapter 13 no-look fees Rule 2016(b) disclosure requirements Rule 2016(b) red flags checklist Section 329(b) motion structure Section 329 vs Section 330 Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. OBPsection329.org1328f.com Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Lodestar Worked Examples - Concrete Dollar Calculations for Section 329(b) Fee Review Source: https://bankruptcylawyerreview.org/lodestar-worked-examples.html bankruptcylawyerreview.org HomeBilling ReviewLodestarWorked ExamplesServices AuditNo-Look FeesStatesDistricts Lodestar Worked Examples Six illustrative fee-reduction calculations showing how deficiency categories translate into specific dollar amounts. Numbers are illustrative, not tied to any real case. Use as a template for quantifying fee-review findings in your own records. Why Worked Examples Matter A Section 329(b) motion that asks for "disgorgement of excessive fees" without specific dollar amounts is weaker than a motion that quantifies the disparity. The court evaluates requested remedy against a specific number; vague requests get vague rulings. These worked examples show the arithmetic of converting deficiency findings into dollar-denominated relief requests. Each example uses illustrative numbers; substitute the actual record figures when applying to a real case. All names, rates, and hours below are illustrative only. The methodology applies to any case. The numbers do not reflect any specific attorney, firm, or debtor. Example 1: Excess Rate Over Firm's Standard Scenario: The attorney's Rule 2016(b) statement discloses a $350/hour rate. PACER cross-referencing the attorney's fee applications in other contemporaneous cases shows a standard rate of $300/hour charged to similar clients in the same period. The debtor in this case was charged the $350 premium without documented justification for the premium. # Hours billed at $350/hour: 100.0 hrs # Firm standard rate (other cases): $300.00/hr # Rate charged this debtor: $350.00/hr # Per-hour premium: $50.00/hr # Total premium exposure: 100.0 × $50.00 Reducible amount: $5,000.00 Legal basis: Where the attorney charges one client at a rate higher than the firm's standard rate without case-specific justification (complexity, urgency, specialization), the premium exceeds reasonable value under Section 329(b). If the rate premium was also not disclosed in a supplemental Rule 2016(b) statement, the violation is also a disclosure violation under In re Kisseberth, 273 F.3d 714 (CourtListener). Methodology note: The firm's standard rate is evidenced by the attorney's fee applications in OTHER contemporaneous cases. PACER cross-reference is the standard research approach. A consistent $300 rate across 5-10 other contemporaneous cases establishes the firm-standard benchmark. Example 2: Block Billing Discount Scenario: Of the total 100 hours billed at $350/hour ($35,000 gross), 40 hours are in block-billed entries combining multiple tasks under single time totals. The court cannot evaluate per-task reasonableness. Apply a 30% discount (midpoint of the typical 20-50% block-billing reduction range). CategoryHoursRateGrossDiscountNet Reducible Block-billed40.0$350$14,00030%$4,200 Non-block60.0$350$21,0000%$0 Total100.0$35,000$4,200 Legal basis: Block-billed entries obscure reasonableness. Courts routinely discount block-billed time by 20-50% per In re Busy Beaver Bldg. Centers, Inc., 19 F.3d 833 (CourtListener) framework of independent judicial review. Example 3: Administrative Work at Attorney Rates Scenario: Review of billing records identifies 12 hours of clerical/administrative work (document filing, serving papers, mailing items, scheduling hearings, formatting motions) billed at the attorney rate of $350/hour. Reclassify to paralegal rate ($125/hour) or disallow entirely if the retainer agreement specifies "no charge" for routine secretarial work. Option A: Reclassify to paralegal rate # Hours: 12.0 # Billed at attorney rate: $350/hr × 12.0 = $4,200.00 # Reasonable paralegal: $125/hr × 12.0 = $1,500.00 Reducible amount: $2,700.00 Option B: Disallow entirely (retainer specifies "no charge" for secretarial work) # Hours: 12.0 # Billed: $4,200.00 # Reasonable per retainer: $0.00 Reducible amount: $4,200.00 Legal basis: Administrative work billed at attorney rates exceeds reasonable value under Section 330(a)(3)(F) ("whether the compensation is reasonable based on the customary compensation charged by comparably skilled practitioners"). Clerical work is not compensable at attorney rates. Example 4: Duplicative Billing Across Timekeepers Scenario: Two attorneys (Senior Partner at $500/hour, Associate at $275/hour) both billed for attending a 2-hour routine status hearing. No case-specific justification appears in the application. Reduce one of the two bills (typically the more junior, who was unnecessary for a routine hearing). # Senior Partner: 2.0 × $500 = $1,000.00 # Associate: 2.0 × $275 = $550.00 ← duplicate # Gross charged: $1,550.00 # Reasonable: $1,000.00 (senior only, or associate only) Reducible amount: $550.00 Legal basis: Duplication of effort without justification exceeds reasonable value. Section 330(a)(3)(C) asks "whether the services were necessary to the administration of, or beneficial at the time at which the service was rendered toward the completion of, a case." Duplicative attendance at routine hearings fails this test. Scale this analysis: if duplicative billing appears on 10 hearings across the case, the reducible amount multiplies to $5,500. Example 5: Services Not Delivered (Docket Cross-Reference) Scenario: Billing entries include 8 hours for "draft motion to compel" on various dates. Cross-reference to the docket shows no motion to compel was ever filed. The billing claim does not match deliverable work product. # Hours billed: 8.0 # Rate: $350/hr # Gross charged: $2,800.00 # Work product delivered: None (no filing) # Reasonable amount: $0.00 Reducible amount: $2,800.00 Legal basis: Billing for work not performed is the strongest factual ground for Section 329(b) relief. Docket cross-reference demonstrates the work was not delivered. This category of deficiency often warrants full disallowance rather than partial reduction, and may support additional sanctions for willful or bad-faith conduct. Note: A single unfiled motion where the attorney can credibly claim "drafted but abandoned on strategic reassessment" may be excusable. A pattern of multiple entries with no corresponding deliverables suggests systematic billing irregularity. Example 6: Compounding Effect - Multi-Layer Deficiency Total Scenario: Apply all five prior examples to the same illustrative case. Compute the compounded reducible amount. Deficiency CategoryExampleReducible Excess rate premiumExample 1$5,000.00 Block-billing discountExample 2$4,200.00 Administrative at attorney rates (Option A)Example 3A$2,700.00 Duplicative billing (single hearing)Example 4$550.00 Services not deliveredExample 5$2,800.00 Total reducible (partial disgorgement)$15,250.00 If the gross amount billed across the case was $35,000, the illustrative partial-disgorgement total of $15,250 represents 43.6% of gross fees - reducible through quantified category-by-category analysis. Disclosure-violation escalation: If any of the above deficiencies coincide with a Rule 2016(b) disclosure violation (e.g., the rate premium in Example 1 was not supplementally disclosed), the In re Stewart, 970 F.3d 1255 (CourtListener) presumption applies: full disgorgement of all fees, with the attorney bearing the burden to show compelling mitigation. # Gross fees paid: $35,000.00 # Partial disgorgement (category): $15,250.00 (43.6%) # Full disgorgement (Stewart): $35,000.00 (100%) Methodology Notes Evidence first, arithmetic second. Every calculation should be supported by specific record citations: docket entries, billing invoices, fee application exhibits, Rule 2016(b) statements. Quantification without evidence is advocacy; quantification with evidence is a motion. Round conservatively. If block-billing discount range is 20-50%, choose 30% as the midpoint absent exceptional facts. Courts are more receptive to moderate reductions that survive scrutiny than aggressive ones that invite pushback. Present as alternatives. Give the court two paths: "reducible amount is $X under partial disgorgement, or $Y under full disgorgement per Stewart." The court chooses; the motion preserves both options. Cross-reference to the caselaw. Each category links to the case authority supporting it. See the Section 329(b) caselaw map for full holdings. Use the motion template. The Section 329(b) motion template has seven parts; quantification sits in Parts 3 (factual recitation) and 5 (reasonableness prong). Related Resources Lodestar methodology overview Services-rendered vs services-charged audit framework Line-by-line billing audit Fee application deficiencies checklist Section 329(b) motion template Section 329(b) caselaw map Disgorgement remedy mechanics UST authority in fee review Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Illustrative calculations; substitute actual record figures. OBPsection329.org1328f.com Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Lodestar Methodology in Bankruptcy Fee Review Source: https://bankruptcylawyerreview.org/lodestar.html bankruptcylawyerreview.org HomeBilling ReviewLodestarWorked ExamplesServices AuditNo-Look FeesEngagement LetterStates Lodestar Methodology in Bankruptcy Fee Review Hours reasonably expended multiplied by a reasonable hourly rate. The primary analytical framework for Section 329(b) reasonableness review, combined with the Johnson 12-factor test and Section 330(a)(3) factors. What the Lodestar Is The lodestar method calculates attorney fees as: Lodestar = Hours reasonably expended x Reasonable hourly rate The lodestar was adopted by the Supreme Court in Hensley v. Eckerhart, 461 U.S. 424 (1983), as the starting point for attorney fee analysis. Every federal circuit applies it in bankruptcy fee review, generally paired with a check against additional factors (Johnson 12-factor test, Section 330(a)(3)). The Two Components Hours Reasonably Expended Not all hours billed are "reasonably expended." Hours that should be excluded: Excessive or duplicative work (multiple attorneys billing for the same task) Block-billed entries where reasonableness cannot be evaluated Administrative or clerical work billed at attorney rates Work on unsuccessful claims that lacked reasonable basis Time not documented contemporaneously Entries with vague descriptions preventing reasonableness review Reasonable Hourly Rate The rate is determined by reference to prevailing market rates for attorneys of comparable skill, experience, and reputation in the relevant legal community. For bankruptcy cases, the relevant community is typically the bankruptcy bar in the judicial district. 8th Circuit Authority In re Apex Oil Co., 960 F.2d 728 (8th Cir. 1992), adopted the lodestar methodology for bankruptcy fee review in the Eighth Circuit. In re Larsen, 59 F.3d 783 (8th Cir. 1995), clarified that Section 330(a) authorizes compensation for "reasonable compensation for actual, necessary services rendered" evaluated on "the nature, extent, value, time spent, and cost of comparable services other than in bankruptcy cases" - imposing a multi-factor analysis rather than pure lodestar. The Eighth Circuit's approach: start with the lodestar, then cross-check against the Section 330(a)(3) factors, then cross-check again against the Johnson 12-factor test where appropriate. See our Section 329(b) caselaw map. 10th Circuit Authority In re Market Center East Retail Property, Inc., 730 F.3d 1239 (10th Cir. 2013), confirmed that the bankruptcy court has an independent duty to review professional fees for reasonableness applying the lodestar and the Section 330(a)(3) factors. Busy Beaver Bldg. Centers, Inc., 19 F.3d 833 (3d Cir. 1994), widely cited in the 10th Circuit, holds that the court cannot rubber-stamp an unopposed fee request. The Section 330(a)(3) Factors Section 330(a)(3) requires courts to consider: The time spent on the services The rates charged for the services Whether the services were necessary to administration or beneficial at the time rendered toward completion of the case Whether the services were performed within a reasonable amount of time commensurate with the complexity, importance, and nature of the problem, issue, or task addressed Whether the person is board certified or has demonstrated skill and experience in bankruptcy Whether the compensation is reasonable based on customary compensation charged by comparably skilled practitioners in non-bankruptcy cases These factors are imported into the Section 329(b) analysis as the measure of "reasonable value." The Johnson 12-Factor Test Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974), established twelve factors for attorney fee reasonableness: Time and labor required Novelty and difficulty of the legal questions Skill required to perform the services properly Preclusion of other employment by the attorney due to acceptance of the case Customary fee in the community Whether the fee is fixed or contingent Time limitations imposed by the client or circumstances Amount involved and results obtained Experience, reputation, and ability of the attorney "Undesirability" of the case Nature and length of the professional relationship Awards in similar cases Typical District Rate Ranges Bankruptcy attorney hourly rates vary widely by district, chapter, and attorney experience. Typical ranges: ExperienceConsumer DistrictsUrban MarketsMajor Metros Partner (10+ years)$300-$450$400-$600$600-$1,200+ Associate (3-10 years)$200-$350$275-$450$400-$750 Junior associate (<3 years)$150-$250$200-$325$275-$500 Paralegal$75-$150$100-$175$150-$250 Ranges reflect broad market practice; specific district guidelines or presumptive rates may apply. Check local bankruptcy court rules and recent fee orders for the relevant district. Selective Pricing - Above-Standard Rates A rate disclosure that differs from what the attorney actually bills is an independent Section 329 violation. Closely related but distinct: selective pricing, where the attorney bills the same client at a higher rate than other similarly-situated clients in the same firm, same year, same practice area. Some circuits treat an unexplained premium above the firm's standard rate as per se unreasonable under Section 329(b). The analysis: Identify the firm's standard rate for the attorney in the relevant time period (from other filings, fee applications in other cases, or PACER cross-reference) Compare to the rate charged to the debtor If the debtor was charged at a premium, the attorney must justify the premium with case-specific factors (complexity, urgency, specialization) Absent justification, the excess is recoverable under Section 329(b) Related Resources Lodestar worked examples - six illustrative fee-reduction calculations Line-by-line billing audit methodology Services-rendered vs services-charged framework Section 329 fee disgorgement Section 329(b) caselaw map How to structure a Section 329(b) motion Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. OBPsection329.org1328f.com Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Chapter 13 No-Look Fees - Presumptive Flat Fees and When They Can Be Challenged Source: https://bankruptcylawyerreview.org/no-look-fees.html bankruptcylawyerreview.org HomeBilling ReviewLodestarWorked ExamplesServices AuditNo-Look FeesState GuidesDistrict Guides Chapter 13 No-Look Fees Explained Most Chapter 13 bankruptcy courts use a "no-look" or "presumptively reasonable" flat fee for debtor's counsel. This page explains how the presumption works, what services it covers, what it does not cover, and when a no-look fee can still be challenged. What a No-Look Fee Is A no-look fee is a flat dollar amount that a local bankruptcy court treats as presumptively reasonable for routine Chapter 13 debtor-representation work. If the fee matches the local presumptive amount and the work is limited to the scope covered by the presumption, the court approves it without line-by-line review. Common labels: "presumptive fee," "no-look fee," "flat fee," "simplified fee arrangement," "standard Chapter 13 fee." All refer to the same mechanism. The authority for presumptive fees derives from Section 330(a) (reasonable compensation) and local bankruptcy court rules or standing orders. The presumption is designed to reduce administrative burden on routine cases; it is not a statutory requirement. Typical No-Look Fee Ranges (General Benchmarks) Amounts vary significantly by district. The ranges below reflect broad market practice; always check the specific district's local rules, fee guidelines, or standing order. Market TypeTypical Presumptive FeeNotes Rural/consumer districts$3,500 - $4,500Often includes filing fee reimbursement separately Mid-size urban markets$4,000 - $5,500May include post-confirmation modifications up to a cap Major metropolitan areas$5,000 - $7,500+Some districts have tiered structures based on plan complexity Business or complex consumer casesExceeds no-look, requires applicationCourts typically require fee application under Rule 2016(a) when fees exceed the cap Check the current local rule or standing order for the specific district. Amounts change periodically. What the No-Look Fee Typically Covers The scope of work included in a presumptive fee usually extends from pre-filing counseling through confirmation, plus a defined set of routine post-confirmation services. A typical scope of "basic" Chapter 13 services: Pre-filing consultation and case evaluation Preparation of the petition, schedules, Statement of Financial Affairs, and means test Preparation of the Chapter 13 plan Representation at the Section 341 meeting of creditors Routine confirmation-hearing preparation and appearance Responding to standard trustee requests for documents Handling routine motion practice (e.g., standard motions to value collateral, routine claim objections) Some portion of post-confirmation plan monitoring What the No-Look Fee Typically Does Not Cover Most local rules expressly carve out non-routine work from the presumptive fee. Extra work requires a separate fee application under Rule 2016(a): Contested confirmation (objections requiring evidentiary hearing) Adversary proceedings under Rule 7001 (dischargeability, lien stripping outside routine, nondischargeability defense) Motions for relief from the automatic stay requiring evidentiary response Contested claim objections beyond routine Plan modifications requiring re-notice and hearing Motions to redeem, reaffirm, or lien-strip requiring valuation hearings Tax-related litigation Discharge-related disputes Red flag: An attorney who takes the full no-look fee and then bills separately for work that was supposed to be included (e.g., routine 341 meeting appearances or standard confirmation) is double-billing. How Disclosure Works for No-Look Fees The no-look presumption does not eliminate the Rule 2016(b) disclosure requirement. Debtor's counsel must still file the statement of compensation disclosing the fee arrangement, source of payment, and any sharing arrangement. If the attorney is charging at the no-look amount, the Rule 2016(b) disclosure should: State the amount of the flat fee State that the fee is being charged pursuant to the local presumptive fee structure Identify the portion paid pre-petition vs. through the plan Identify any supplemental fee arrangements (e.g., payment for excluded services if they arise) Be supplemented if the arrangement changes When No-Look Fees Can Still Be Challenged The "no-look" presumption is a procedural shortcut, not a statutory shield. A flat fee can still be reviewed under Section 329(b) if the fee exceeds the reasonable value of services rendered. Common challenge scenarios: Scenario 1 - Case dismissed before confirmation Attorney charged full no-look fee; case was dismissed at the 341 meeting or on an early trustee motion to dismiss. Services actually rendered (consultation, petition filing) are a fraction of what the presumption assumes. Courts have reduced no-look fees where the case never progressed to confirmation. See services-rendered vs services-charged audit. Scenario 2 - Attorney collected no-look fee plus additional undisclosed retainer Attorney files a 2016(b) disclosure reporting the no-look fee, but also collected a separate cash retainer outside the docket. This is a disclosure violation - the remedy is disgorgement of the undisclosed amount under Section 329(b) regardless of whether the no-look fee itself was reasonable. Scenario 3 - No-look fee is taken, but work is minimal Debtor files pro-se-style boilerplate schedules; attorney performs no meaningful case analysis, no plan drafting, no 341 appearance preparation; but bills the full presumptive fee. This is challengeable under Section 329(b) as compensation exceeding reasonable value. Scenario 4 - Conversion to Chapter 7 after collecting full Chapter 13 fee Attorney collects the no-look Chapter 13 fee, case converts to Chapter 7 before confirmation, and attorney continues in Chapter 7 representation. The portion of the fee allocable to work that was never performed (confirmation, plan monitoring, discharge, post-confirmation services) is recoverable. How to Challenge a No-Look Fee The mechanics of a no-look fee challenge mirror the general Section 329(b) motion structure: Pull the 2016(b) disclosure. Confirm what was disclosed and what fee arrangement was represented. Reconstruct services rendered. Review the docket for appearances, filings, responses. Compare to what the presumption is supposed to cover. Identify the delta. Where services are materially less than the presumption contemplates, the excess is recoverable under 329(b). Motion under Section 329(b) (or Rule 2017 sua sponte request). The motion asks the court to review whether the presumptive fee continues to represent reasonable value in this case. Remedy: reduction to amount reasonably commensurate with actual services; return of excess to debtor or estate. See motion template for structural guidance. The worked examples page illustrates how to compute specific reductions. Special Considerations "Pot" Plans Some Chapter 13 plans pay attorney fees "through the plan" over the life of the plan (often 36-60 months). Debtors who ultimately cannot complete the plan may be paying on an attorney fee for services that were not reasonably rendered. The presumption is reviewable at any time under Section 329(b). Pre-Petition Retainer Plus Plan Payments Some arrangements combine an up-front pre-petition retainer with plan payments totaling the full presumptive amount. Both tranches are compensation and must be disclosed under Rule 2016(b). Undisclosed pre-petition retainer is an independent violation. Multi-Case Referral Arrangements Some high-volume Chapter 13 practices operate on a referral/volume model that aggregates cases. The presumption does not excuse the attorney from individualized review in each case. Where a mill-style practice is collecting presumptive fees without individualized service, the UST and trustees have authority to examine aggregate patterns. Questions to Ask Your Chapter 13 Attorney What is the presumptive/no-look fee in this district, and how much are you charging? What services are included in the flat fee? What is excluded? How much do I pay up-front, and how much is paid through the plan? Will you file a Rule 2016(b) disclosure, and can I see a copy? What happens to the fee if my case is dismissed before confirmation? What happens to the fee if we need to convert to Chapter 7? Are there any additional charges I should expect (e.g., for motions, adversary actions, plan modifications)? Related Resources Lodestar methodology Lodestar worked examples Line-by-line billing audit Services-rendered vs services-charged audit Section 329(b) motion structure Rule 2016(b) disclosure requirements Section 329 vs Section 330 distinction Section 329(b) caselaw map Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. OBPsection329.org1328f.com Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Services-Rendered vs Services-Charged Audit Framework Source: https://bankruptcylawyerreview.org/services-audit.html bankruptcylawyerreview.org HomeBilling ReviewLodestarWorked ExamplesServices AuditNo-Look FeesState GuidesDistrict Guides Services-Rendered vs Services-Charged Audit A structured framework for comparing billed work to actual case record. Use this methodology to quantify the gap between what the attorney charged and what was delivered. The Premise A Section 329(b) reasonableness challenge succeeds or fails on the evidentiary record of what was charged versus what was delivered. The billing statement shows hours and tasks; the docket shows work product. When these diverge materially, Section 329(b) relief is available. This audit framework is the methodology for conducting that comparison on a line-by-line basis. Step 1: Assemble the Record Three documents are required: Complete billing statement - all time entries with date, attorney, task description, hours, rate, and amount Case docket - every filing, order, hearing, and communication in the case record Any fee applications - both interim and final, with supporting declarations Supplement with: retainer agreement, Rule 2016(b) statement, correspondence between attorney and client, written work product. Step 2: Red Flag Categories Block Billing Entries combining multiple tasks without per-task time: "Review case file, draft response, confer with client - 4.0 hours" Block billing obscures reasonableness analysis. Courts routinely discount block-billed time by 20-50%. Vague Entries "Attention to file" / "Review matter" / "Work on case" Without specific task identification, reasonableness cannot be evaluated. Courts typically disallow. Administrative Work at Attorney Rates Filing documents (clerical) Serving papers (clerical) Scheduling hearings (clerical) Mailing items (clerical) Formatting or proofreading (clerical unless complex drafting) Most fee agreements specify no charge for routine secretarial work. Such work billed at paralegal or attorney rates is independently challengeable. Duplicative Entries Multiple attorneys billing for the same task (e.g., two attorneys attending the same routine hearing) without clear justification. Entries Without Work Product Time billed for work where no corresponding work product appears in the case record: "Draft motion" entries with no motion filed "Prepare for hearing" where no hearing was held "Review documents" where no documents exist in the matter Undisclosed Rate Increases Billing at rates higher than disclosed in Rule 2016(b). Each hour at the increased rate reflects an independent disclosure violation. Step 3: Quantification For each red flag category, quantify the disparity: Identify affected entries. List every billing entry fitting the category. Calculate dollar exposure. Sum the amounts charged in those entries. Apply reasonable discount. Courts typically apply 20-100% reductions depending on severity. Compile totals. Sum disparities across all categories for the motion's quantification. Step 4: Docket Cross-Reference For every significant billing entry, locate the corresponding docket filing or court record entry: Motion drafted - find the motion in the docket Hearing attended - find the hearing minutes Brief filed - find the brief in the docket Settlement negotiated - find the settlement agreement or order Meeting held - identify any resulting work product Gaps between billing entries and docket records are red flags. Billing for undone work is the strongest evidence of Section 329(b) violation. Step 5: Time Distribution Analysis Chart total hours by task category. Common patterns that indicate mischarging: Administrative tasks exceeding 15-20% of total time (should be negligible at attorney rates) Research hours disproportionate to complexity (large research blocks on routine issues) Conference/call hours where no written record of the conference exists Drafting hours for short or form-based filings Review hours for documents that are short or routine Step 6: Identify Services Promised but Not Delivered Review the retainer agreement or engagement letter for scope of representation. Match promised services to delivered services: Did the attorney complete all deliverables in the engagement letter? Were any required court filings missed? Were deadlines met? Did the attorney perform ancillary work described in the retainer (e.g., negotiate with specific creditors)? Services promised but not delivered support reasonableness-prong arguments and may rise to the level of malpractice. Step 7: Document Gap Compile findings into a structured disparity report: Total amount billed Total amount reasonable (after red-flag discounts) Per-category breakdown of disparities Docket cross-reference showing services not delivered Services outside the Rule 2016(b) scope Selective pricing premiums above standard rate The disparity report becomes the factual exhibit for a Section 329(b) motion. A clean report showing a specific dollar disparity between billed and delivered makes the motion significantly easier to draft and defend. Related Resources Step-by-step billing audit Lodestar methodology Common fee issues Section 329 fee disgorgement Section 329(b) caselaw map How to structure a Section 329(b) motion Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. OBPsection329.org1328f.com Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Alabama Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/alabama.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Alabama How attorney fees are set and reviewed in Alabama bankruptcy cases. Market ranges, Region 21 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Alabama Bankruptcy attorney fees in Alabama generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,000-$2,000Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,000-$4,500Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 21 The Office of the United States Trustee (Region 21) supervises bankruptcy cases filed in Alabama. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Alabama Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 11th Circuit Alabama bankruptcy cases are governed by 11th Circuit precedent. The leading 11th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. N.D./M.D./S.D. Ala. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. N.D./M.D./S.D. Ala.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 21) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Alaska Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/alaska.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Alaska How attorney fees are set and reviewed in Alaska bankruptcy cases. Market ranges, Region 18 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Alaska Bankruptcy attorney fees in Alaska generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,200-$2,500Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,000-$5,000Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 18 The Office of the United States Trustee (Region 18) supervises bankruptcy cases filed in Alaska. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Alaska Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 9th Circuit Alaska bankruptcy cases are governed by 9th Circuit precedent. The leading 9th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. D. Alaska Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. D. Alaska. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 18) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Arizona Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/arizona.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Arizona How attorney fees are set and reviewed in Arizona bankruptcy cases. Market ranges, Region 14 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Arizona Bankruptcy attorney fees in Arizona generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,500-$2,800Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,500-$5,500Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 14 The Office of the United States Trustee (Region 14) supervises bankruptcy cases filed in Arizona. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Arizona Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 9th Circuit Arizona bankruptcy cases are governed by 9th Circuit precedent. The leading 9th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. D. Ariz. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. D. Ariz.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 14) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Arkansas Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/arkansas.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Arkansas How attorney fees are set and reviewed in Arkansas bankruptcy cases. Market ranges, Region 13 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Arkansas Bankruptcy attorney fees in Arkansas generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$800-$1,800Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$2,500-$4,000Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 13 The Office of the United States Trustee (Region 13) supervises bankruptcy cases filed in Arkansas. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Arkansas Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 8th Circuit Arkansas bankruptcy cases are governed by 8th Circuit precedent. The leading 8th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. E.D./W.D. Ark. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. E.D./W.D. Ark.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 13) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in California Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/california.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in California How attorney fees are set and reviewed in California bankruptcy cases. Market ranges, Region 15/16/17 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in California Bankruptcy attorney fees in California generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,800-$3,500Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$4,000-$6,500Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 15/16/17 The Office of the United States Trustee (Region 15/16/17) supervises bankruptcy cases filed in California. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in California Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 9th Circuit California bankruptcy cases are governed by 9th Circuit precedent. The leading 9th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. N.D./E.D./C.D./S.D. Cal. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. N.D./E.D./C.D./S.D. Cal.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 15/16/17) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Colorado Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/colorado.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Colorado How attorney fees are set and reviewed in Colorado bankruptcy cases. Market ranges, Region 19 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Colorado Bankruptcy attorney fees in Colorado generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,500-$2,800Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,500-$5,500Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 19 The Office of the United States Trustee (Region 19) supervises bankruptcy cases filed in Colorado. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Colorado Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 10th Circuit Colorado bankruptcy cases are governed by 10th Circuit precedent. The leading 10th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. D. Colo. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. D. Colo.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 19) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Connecticut Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/connecticut.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Connecticut How attorney fees are set and reviewed in Connecticut bankruptcy cases. Market ranges, Region 2 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Connecticut Bankruptcy attorney fees in Connecticut generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,800-$3,200Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,800-$5,800Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 2 The Office of the United States Trustee (Region 2) supervises bankruptcy cases filed in Connecticut. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Connecticut Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 2d Circuit Connecticut bankruptcy cases are governed by 2d Circuit precedent. The leading 2d Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. D. Conn. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. D. Conn.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 2) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Delaware Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/delaware.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Delaware How attorney fees are set and reviewed in Delaware bankruptcy cases. Market ranges, Region 3 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Delaware Bankruptcy attorney fees in Delaware generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,500-$3,000Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,500-$5,500Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 3 The Office of the United States Trustee (Region 3) supervises bankruptcy cases filed in Delaware. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Delaware Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 3d Circuit Delaware bankruptcy cases are governed by 3d Circuit precedent. The leading 3d Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. D. Del. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. D. Del.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 3) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Florida Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/florida.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Florida How attorney fees are set and reviewed in Florida bankruptcy cases. Market ranges, Region 21 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Florida Bankruptcy attorney fees in Florida generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,200-$2,500Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,000-$5,000Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 21 The Office of the United States Trustee (Region 21) supervises bankruptcy cases filed in Florida. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Florida Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 11th Circuit Florida bankruptcy cases are governed by 11th Circuit precedent. The leading 11th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. N.D./M.D./S.D. Fla. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. N.D./M.D./S.D. Fla.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 21) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Georgia Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/georgia.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Georgia How attorney fees are set and reviewed in Georgia bankruptcy cases. Market ranges, Region 21 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Georgia Bankruptcy attorney fees in Georgia generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,000-$2,200Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$2,800-$4,500Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 21 The Office of the United States Trustee (Region 21) supervises bankruptcy cases filed in Georgia. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Georgia Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 11th Circuit Georgia bankruptcy cases are governed by 11th Circuit precedent. The leading 11th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. N.D./M.D./S.D. Ga. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. N.D./M.D./S.D. Ga.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 21) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Hawaii Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/hawaii.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Hawaii How attorney fees are set and reviewed in Hawaii bankruptcy cases. Market ranges, Region 15 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Hawaii Bankruptcy attorney fees in Hawaii generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,800-$3,200Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$4,000-$6,000Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 15 The Office of the United States Trustee (Region 15) supervises bankruptcy cases filed in Hawaii. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Hawaii Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 9th Circuit Hawaii bankruptcy cases are governed by 9th Circuit precedent. The leading 9th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. D. Haw. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. D. Haw.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 15) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Idaho Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/idaho.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Idaho How attorney fees are set and reviewed in Idaho bankruptcy cases. Market ranges, Region 18 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Idaho Bankruptcy attorney fees in Idaho generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,200-$2,400Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,000-$5,000Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 18 The Office of the United States Trustee (Region 18) supervises bankruptcy cases filed in Idaho. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Idaho Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 9th Circuit Idaho bankruptcy cases are governed by 9th Circuit precedent. The leading 9th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. D. Idaho Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. D. Idaho. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 18) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Illinois Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/illinois.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Illinois How attorney fees are set and reviewed in Illinois bankruptcy cases. Market ranges, Region 10/11 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Illinois Bankruptcy attorney fees in Illinois generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,500-$2,800Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,500-$5,500Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 10/11 The Office of the United States Trustee (Region 10/11) supervises bankruptcy cases filed in Illinois. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Illinois Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 7th Circuit Illinois bankruptcy cases are governed by 7th Circuit precedent. The leading 7th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. N.D./C.D./S.D. Ill. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. N.D./C.D./S.D. Ill.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 10/11) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## State Attorney Fee Review Guides | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/ bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains State Fee Review Guides All 50 states - typical bankruptcy attorney fee ranges, U.S. Trustee oversight, and Section 329(b) framework. Browse by State Alabama Alaska Arizona Arkansas California Colorado Connecticut Delaware Florida Georgia Hawaii Idaho Illinois Indiana Iowa Kansas Kentucky Louisiana Maine Maryland Massachusetts Michigan Minnesota Mississippi Missouri Montana Nebraska Nevada New Hampshire New Jersey New Mexico New York North Carolina North Dakota Ohio Oklahoma Oregon Pennsylvania Rhode Island South Carolina South Dakota Tennessee Texas Utah Vermont Virginia Washington West Virginia Wisconsin Wyoming Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 Most-read OBP guides Brunner Test (§523(a)(8)) 3-prong analysis for discharging student loans Car Loan After Bankruptcy Buy a car and get financing post-discharge Student Loans in Bankruptcy Can you discharge them? 2026 guide Federal Exemptions §522(d) Complete list of federal exemptions Nondischargeable Debts List Debts that survive bankruptcy discharge --- ## Attorney Fee Review in Indiana Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/indiana.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Indiana How attorney fees are set and reviewed in Indiana bankruptcy cases. Market ranges, Region 10 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Indiana Bankruptcy attorney fees in Indiana generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,200-$2,400Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,000-$5,000Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 10 The Office of the United States Trustee (Region 10) supervises bankruptcy cases filed in Indiana. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Indiana Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 7th Circuit Indiana bankruptcy cases are governed by 7th Circuit precedent. The leading 7th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. N.D./S.D. Ind. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. N.D./S.D. Ind.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 10) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Iowa Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/iowa.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Iowa How attorney fees are set and reviewed in Iowa bankruptcy cases. Market ranges, Region 12 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Iowa Bankruptcy attorney fees in Iowa generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,200-$2,300Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,000-$5,000Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 12 The Office of the United States Trustee (Region 12) supervises bankruptcy cases filed in Iowa. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Iowa Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 8th Circuit Iowa bankruptcy cases are governed by 8th Circuit precedent. The leading 8th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. N.D./S.D. Iowa Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. N.D./S.D. Iowa. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 12) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Kansas Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/kansas.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Kansas How attorney fees are set and reviewed in Kansas bankruptcy cases. Market ranges, Region 20 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Kansas Bankruptcy attorney fees in Kansas generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,200-$2,500Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,000-$5,000Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 20 The Office of the United States Trustee (Region 20) supervises bankruptcy cases filed in Kansas. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Kansas Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 10th Circuit Kansas bankruptcy cases are governed by 10th Circuit precedent. The leading 10th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. D. Kan. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. D. Kan.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 20) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Kentucky Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/kentucky.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Kentucky How attorney fees are set and reviewed in Kentucky bankruptcy cases. Market ranges, Region 8 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Kentucky Bankruptcy attorney fees in Kentucky generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,000-$2,200Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$2,800-$4,500Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 8 The Office of the United States Trustee (Region 8) supervises bankruptcy cases filed in Kentucky. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Kentucky Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 6th Circuit Kentucky bankruptcy cases are governed by 6th Circuit precedent. The leading 6th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. E.D./W.D. Ky. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. E.D./W.D. Ky.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 8) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Louisiana Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/louisiana.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Louisiana How attorney fees are set and reviewed in Louisiana bankruptcy cases. Market ranges, Region 5 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Louisiana Bankruptcy attorney fees in Louisiana generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,200-$2,400Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,000-$5,000Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 5 The Office of the United States Trustee (Region 5) supervises bankruptcy cases filed in Louisiana. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Louisiana Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 5th Circuit Louisiana bankruptcy cases are governed by 5th Circuit precedent. The leading 5th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. E.D./M.D./W.D. La. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. E.D./M.D./W.D. La.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 5) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Maine Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/maine.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Maine How attorney fees are set and reviewed in Maine bankruptcy cases. Market ranges, Region 1 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Maine Bankruptcy attorney fees in Maine generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,500-$2,800Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,500-$5,500Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 1 The Office of the United States Trustee (Region 1) supervises bankruptcy cases filed in Maine. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Maine Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 1st Circuit Maine bankruptcy cases are governed by 1st Circuit precedent. The leading 1st Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. D. Me. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. D. Me.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 1) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Maryland Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/maryland.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Maryland How attorney fees are set and reviewed in Maryland bankruptcy cases. Market ranges, Region 4 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Maryland Bankruptcy attorney fees in Maryland generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,500-$2,800Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,500-$5,500Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 4 The Office of the United States Trustee (Region 4) supervises bankruptcy cases filed in Maryland. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Maryland Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 4th Circuit Maryland bankruptcy cases are governed by 4th Circuit precedent. The leading 4th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. D. Md. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. D. Md.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 4) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Massachusetts Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/massachusetts.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Massachusetts How attorney fees are set and reviewed in Massachusetts bankruptcy cases. Market ranges, Region 1 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Massachusetts Bankruptcy attorney fees in Massachusetts generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,800-$3,200Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$4,000-$6,000Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 1 The Office of the United States Trustee (Region 1) supervises bankruptcy cases filed in Massachusetts. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Massachusetts Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 1st Circuit Massachusetts bankruptcy cases are governed by 1st Circuit precedent. The leading 1st Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. D. Mass. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. D. Mass.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 1) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Michigan Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/michigan.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Michigan How attorney fees are set and reviewed in Michigan bankruptcy cases. Market ranges, Region 9 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Michigan Bankruptcy attorney fees in Michigan generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,300-$2,500Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,200-$5,200Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 9 The Office of the United States Trustee (Region 9) supervises bankruptcy cases filed in Michigan. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Michigan Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 6th Circuit Michigan bankruptcy cases are governed by 6th Circuit precedent. The leading 6th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. E.D./W.D. Mich. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. E.D./W.D. Mich.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 9) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Minnesota Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/minnesota.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Minnesota How attorney fees are set and reviewed in Minnesota bankruptcy cases. Market ranges, Region 12 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Minnesota Bankruptcy attorney fees in Minnesota generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,400-$2,600Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,200-$5,200Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 12 The Office of the United States Trustee (Region 12) supervises bankruptcy cases filed in Minnesota. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Minnesota Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 8th Circuit Minnesota bankruptcy cases are governed by 8th Circuit precedent. The leading 8th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. D. Minn. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. D. Minn.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 12) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Mississippi Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/mississippi.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Mississippi How attorney fees are set and reviewed in Mississippi bankruptcy cases. Market ranges, Region 5 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Mississippi Bankruptcy attorney fees in Mississippi generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$900-$2,000Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$2,500-$4,200Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 5 The Office of the United States Trustee (Region 5) supervises bankruptcy cases filed in Mississippi. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Mississippi Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 5th Circuit Mississippi bankruptcy cases are governed by 5th Circuit precedent. The leading 5th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. N.D./S.D. Miss. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. N.D./S.D. Miss.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 5) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Missouri Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/missouri.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Missouri How attorney fees are set and reviewed in Missouri bankruptcy cases. Market ranges, Region 13 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Missouri Bankruptcy attorney fees in Missouri generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,100-$2,300Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,000-$5,000Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 13 The Office of the United States Trustee (Region 13) supervises bankruptcy cases filed in Missouri. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Missouri Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 8th Circuit Missouri bankruptcy cases are governed by 8th Circuit precedent. The leading 8th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. E.D./W.D. Mo. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. E.D./W.D. Mo.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 13) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Montana Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/montana.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Montana How attorney fees are set and reviewed in Montana bankruptcy cases. Market ranges, Region 18 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Montana Bankruptcy attorney fees in Montana generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,200-$2,400Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,000-$5,000Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 18 The Office of the United States Trustee (Region 18) supervises bankruptcy cases filed in Montana. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Montana Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 9th Circuit Montana bankruptcy cases are governed by 9th Circuit precedent. The leading 9th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. D. Mont. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. D. Mont.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 18) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Nebraska Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/nebraska.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Nebraska How attorney fees are set and reviewed in Nebraska bankruptcy cases. Market ranges, Region 13 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Nebraska Bankruptcy attorney fees in Nebraska generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,100-$2,200Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$2,800-$4,800Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 13 The Office of the United States Trustee (Region 13) supervises bankruptcy cases filed in Nebraska. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Nebraska Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 8th Circuit Nebraska bankruptcy cases are governed by 8th Circuit precedent. The leading 8th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. D. Neb. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. D. Neb.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 13) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Nevada Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/nevada.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Nevada How attorney fees are set and reviewed in Nevada bankruptcy cases. Market ranges, Region 17 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Nevada Bankruptcy attorney fees in Nevada generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,500-$2,800Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,500-$5,500Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 17 The Office of the United States Trustee (Region 17) supervises bankruptcy cases filed in Nevada. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Nevada Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 9th Circuit Nevada bankruptcy cases are governed by 9th Circuit precedent. The leading 9th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. D. Nev. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. D. Nev.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 17) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in New Hampshire Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/new-hampshire.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in New Hampshire How attorney fees are set and reviewed in New Hampshire bankruptcy cases. Market ranges, Region 1 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in New Hampshire Bankruptcy attorney fees in New Hampshire generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,500-$2,800Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,500-$5,500Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 1 The Office of the United States Trustee (Region 1) supervises bankruptcy cases filed in New Hampshire. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in New Hampshire Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 1st Circuit New Hampshire bankruptcy cases are governed by 1st Circuit precedent. The leading 1st Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. D.N.H. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. D.N.H.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 1) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in New Jersey Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/new-jersey.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in New Jersey How attorney fees are set and reviewed in New Jersey bankruptcy cases. Market ranges, Region 3 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in New Jersey Bankruptcy attorney fees in New Jersey generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,800-$3,200Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$4,000-$6,000Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 3 The Office of the United States Trustee (Region 3) supervises bankruptcy cases filed in New Jersey. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in New Jersey Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 3d Circuit New Jersey bankruptcy cases are governed by 3d Circuit precedent. The leading 3d Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. D.N.J. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. D.N.J.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 3) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in New Mexico Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/new-mexico.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in New Mexico How attorney fees are set and reviewed in New Mexico bankruptcy cases. Market ranges, Region 20 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in New Mexico Bankruptcy attorney fees in New Mexico generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,300-$2,500Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,200-$5,200Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 20 The Office of the United States Trustee (Region 20) supervises bankruptcy cases filed in New Mexico. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in New Mexico Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 10th Circuit New Mexico bankruptcy cases are governed by 10th Circuit precedent. The leading 10th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. D.N.M. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. D.N.M.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 20) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in New York Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/new-york.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in New York How attorney fees are set and reviewed in New York bankruptcy cases. Market ranges, Region 2 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in New York Bankruptcy attorney fees in New York generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,800-$3,500Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$4,000-$6,500Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 2 The Office of the United States Trustee (Region 2) supervises bankruptcy cases filed in New York. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in New York Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 2d Circuit New York bankruptcy cases are governed by 2d Circuit precedent. The leading 2d Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. N.D./E.D./S.D./W.D.N.Y. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. N.D./E.D./S.D./W.D.N.Y.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 2) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in North Carolina Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/north-carolina.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in North Carolina How attorney fees are set and reviewed in North Carolina bankruptcy cases. Market ranges, Region 4 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in North Carolina Bankruptcy attorney fees in North Carolina generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,300-$2,500Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,200-$5,200Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 4 The Office of the United States Trustee (Region 4) supervises bankruptcy cases filed in North Carolina. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in North Carolina Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 4th Circuit North Carolina bankruptcy cases are governed by 4th Circuit precedent. The leading 4th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. E.D./M.D./W.D.N.C. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. E.D./M.D./W.D.N.C.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 4) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in North Dakota Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/north-dakota.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in North Dakota How attorney fees are set and reviewed in North Dakota bankruptcy cases. Market ranges, Region 12 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in North Dakota Bankruptcy attorney fees in North Dakota generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,200-$2,300Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,000-$5,000Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 12 The Office of the United States Trustee (Region 12) supervises bankruptcy cases filed in North Dakota. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in North Dakota Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 8th Circuit North Dakota bankruptcy cases are governed by 8th Circuit precedent. The leading 8th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. D.N.D. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. D.N.D.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 12) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Ohio Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/ohio.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Ohio How attorney fees are set and reviewed in Ohio bankruptcy cases. Market ranges, Region 9 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Ohio Bankruptcy attorney fees in Ohio generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,200-$2,400Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,000-$5,000Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 9 The Office of the United States Trustee (Region 9) supervises bankruptcy cases filed in Ohio. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Ohio Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 6th Circuit Ohio bankruptcy cases are governed by 6th Circuit precedent. The leading 6th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. N.D./S.D. Ohio Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. N.D./S.D. Ohio. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 9) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Oklahoma Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/oklahoma.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Oklahoma How attorney fees are set and reviewed in Oklahoma bankruptcy cases. Market ranges, Region 20 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Oklahoma Bankruptcy attorney fees in Oklahoma generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,100-$2,300Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$2,800-$4,800Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 20 The Office of the United States Trustee (Region 20) supervises bankruptcy cases filed in Oklahoma. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Oklahoma Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 10th Circuit Oklahoma bankruptcy cases are governed by 10th Circuit precedent. The leading 10th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. N.D./E.D./W.D. Okla. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. N.D./E.D./W.D. Okla.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 20) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Oregon Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/oregon.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Oregon How attorney fees are set and reviewed in Oregon bankruptcy cases. Market ranges, Region 18 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Oregon Bankruptcy attorney fees in Oregon generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,500-$2,800Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,500-$5,500Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 18 The Office of the United States Trustee (Region 18) supervises bankruptcy cases filed in Oregon. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Oregon Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 9th Circuit Oregon bankruptcy cases are governed by 9th Circuit precedent. The leading 9th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. D. Or. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. D. Or.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 18) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Pennsylvania Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/pennsylvania.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Pennsylvania How attorney fees are set and reviewed in Pennsylvania bankruptcy cases. Market ranges, Region 3 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Pennsylvania Bankruptcy attorney fees in Pennsylvania generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,400-$2,700Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,300-$5,300Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 3 The Office of the United States Trustee (Region 3) supervises bankruptcy cases filed in Pennsylvania. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Pennsylvania Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 3d Circuit Pennsylvania bankruptcy cases are governed by 3d Circuit precedent. The leading 3d Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. E.D./M.D./W.D. Pa. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. E.D./M.D./W.D. Pa.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 3) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Rhode Island Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/rhode-island.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Rhode Island How attorney fees are set and reviewed in Rhode Island bankruptcy cases. Market ranges, Region 1 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Rhode Island Bankruptcy attorney fees in Rhode Island generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,500-$2,800Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,500-$5,500Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 1 The Office of the United States Trustee (Region 1) supervises bankruptcy cases filed in Rhode Island. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Rhode Island Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 1st Circuit Rhode Island bankruptcy cases are governed by 1st Circuit precedent. The leading 1st Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. D.R.I. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. D.R.I.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 1) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in South Carolina Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/south-carolina.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in South Carolina How attorney fees are set and reviewed in South Carolina bankruptcy cases. Market ranges, Region 4 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in South Carolina Bankruptcy attorney fees in South Carolina generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,200-$2,400Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,000-$5,000Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 4 The Office of the United States Trustee (Region 4) supervises bankruptcy cases filed in South Carolina. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in South Carolina Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 4th Circuit South Carolina bankruptcy cases are governed by 4th Circuit precedent. The leading 4th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. D.S.C. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. D.S.C.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 4) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in South Dakota Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/south-dakota.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in South Dakota How attorney fees are set and reviewed in South Dakota bankruptcy cases. Market ranges, Region 12 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in South Dakota Bankruptcy attorney fees in South Dakota generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,100-$2,200Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$2,800-$4,800Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 12 The Office of the United States Trustee (Region 12) supervises bankruptcy cases filed in South Dakota. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in South Dakota Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 8th Circuit South Dakota bankruptcy cases are governed by 8th Circuit precedent. The leading 8th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. D.S.D. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. D.S.D.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 12) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Tennessee Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/tennessee.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Tennessee How attorney fees are set and reviewed in Tennessee bankruptcy cases. Market ranges, Region 8 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Tennessee Bankruptcy attorney fees in Tennessee generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,200-$2,400Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,000-$5,000Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 8 The Office of the United States Trustee (Region 8) supervises bankruptcy cases filed in Tennessee. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Tennessee Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 6th Circuit Tennessee bankruptcy cases are governed by 6th Circuit precedent. The leading 6th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. E.D./M.D./W.D. Tenn. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. E.D./M.D./W.D. Tenn.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 8) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Texas Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/texas.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Texas How attorney fees are set and reviewed in Texas bankruptcy cases. Market ranges, Region 6/7 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Texas Bankruptcy attorney fees in Texas generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,200-$2,500Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,000-$5,000Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 6/7 The Office of the United States Trustee (Region 6/7) supervises bankruptcy cases filed in Texas. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Texas Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 5th Circuit Texas bankruptcy cases are governed by 5th Circuit precedent. The leading 5th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. N.D./E.D./S.D./W.D. Tex. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. N.D./E.D./S.D./W.D. Tex.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 6/7) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Utah Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/utah.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Utah How attorney fees are set and reviewed in Utah bankruptcy cases. Market ranges, Region 19 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Utah Bankruptcy attorney fees in Utah generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,300-$2,500Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,200-$5,200Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 19 The Office of the United States Trustee (Region 19) supervises bankruptcy cases filed in Utah. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Utah Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 10th Circuit Utah bankruptcy cases are governed by 10th Circuit precedent. The leading 10th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. D. Utah Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. D. Utah. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 19) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Vermont Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/vermont.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Vermont How attorney fees are set and reviewed in Vermont bankruptcy cases. Market ranges, Region 2 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Vermont Bankruptcy attorney fees in Vermont generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,500-$2,800Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,500-$5,500Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 2 The Office of the United States Trustee (Region 2) supervises bankruptcy cases filed in Vermont. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Vermont Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 2d Circuit Vermont bankruptcy cases are governed by 2d Circuit precedent. The leading 2d Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. D. Vt. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. D. Vt.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 2) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Virginia Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/virginia.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Virginia How attorney fees are set and reviewed in Virginia bankruptcy cases. Market ranges, Region 4 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Virginia Bankruptcy attorney fees in Virginia generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,300-$2,500Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,200-$5,200Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 4 The Office of the United States Trustee (Region 4) supervises bankruptcy cases filed in Virginia. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Virginia Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 4th Circuit Virginia bankruptcy cases are governed by 4th Circuit precedent. The leading 4th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. E.D./W.D. Va. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. E.D./W.D. Va.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 4) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Washington Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/washington.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Washington How attorney fees are set and reviewed in Washington bankruptcy cases. Market ranges, Region 18 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Washington Bankruptcy attorney fees in Washington generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,500-$2,800Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,500-$5,500Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 18 The Office of the United States Trustee (Region 18) supervises bankruptcy cases filed in Washington. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Washington Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 9th Circuit Washington bankruptcy cases are governed by 9th Circuit precedent. The leading 9th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. E.D./W.D. Wash. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. E.D./W.D. Wash.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 18) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in West Virginia Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/west-virginia.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in West Virginia How attorney fees are set and reviewed in West Virginia bankruptcy cases. Market ranges, Region 4 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in West Virginia Bankruptcy attorney fees in West Virginia generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,100-$2,200Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$2,800-$4,800Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 4 The Office of the United States Trustee (Region 4) supervises bankruptcy cases filed in West Virginia. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in West Virginia Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 4th Circuit West Virginia bankruptcy cases are governed by 4th Circuit precedent. The leading 4th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. N.D./S.D. W. Va. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. N.D./S.D. W. Va.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 4) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Wisconsin Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/wisconsin.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Wisconsin How attorney fees are set and reviewed in Wisconsin bankruptcy cases. Market ranges, Region 11 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Wisconsin Bankruptcy attorney fees in Wisconsin generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,300-$2,500Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,200-$5,200Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 11 The Office of the United States Trustee (Region 11) supervises bankruptcy cases filed in Wisconsin. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Wisconsin Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 7th Circuit Wisconsin bankruptcy cases are governed by 7th Circuit precedent. The leading 7th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. E.D./W.D. Wis. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. E.D./W.D. Wis.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 11) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## Attorney Fee Review in Wyoming Bankruptcy Cases | bankruptcylawyerreview.org Source: https://bankruptcylawyerreview.org/states/wyoming.html bankruptcylawyerreview.org Home Billing Review Case File Docket Reading Common Issues State Guides District Guides Part of the Open Bankruptcy Project - 210+ free domains Attorney Fee Review in Wyoming How attorney fees are set and reviewed in Wyoming bankruptcy cases. Market ranges, Region 19 U.S. Trustee oversight, billing review basics, and pointers into Section 329(b) disgorgement authority. Typical Attorney Fee Ranges in Wyoming Bankruptcy attorney fees in Wyoming generally fall within the following market ranges. These reflect typical practice in no-asset and straightforward cases. Complex cases, litigation, or Chapter 11 matters routinely exceed these ranges. ChapterTypical RangeNotes Chapter 7 (consumer)$1,200-$2,400Usually flat fee; includes basic counseling and 341 meeting Chapter 13 (consumer)$3,000-$5,000Split flat / interim fee application; local "no-look" presumptive fee common Chapter 11 (business)hourly, $250-$600/hr typicalHourly billing, court-approved fee applications required Subchapter V (small business)hourly, $250-$550/hr typicalStreamlined Ch. 11; Sub V trustee paid separately under Section 1195 Ranges reflect typical market practice; specific district-level no-look fees or presumptive guidelines may apply. Always check local rules for the bankruptcy court serving your case. U.S. Trustee Oversight - Region 19 The Office of the United States Trustee (Region 19) supervises bankruptcy cases filed in Wyoming. The U.S. Trustee has authority under 11 U.S.C. Section 307 to raise any issue in any case, including the reasonableness of attorney compensation. Under Section 329(b), the court may review fees on the U.S. Trustee's motion or on its own initiative. 11 U.S.C. Section 329(b): "If such compensation exceeds the reasonable value of any such services, the court may cancel any such agreement, or order the return of any such payment, to the extent excessive..." When the U.S. Trustee identifies fees that appear disproportionate to services rendered, the office may file a motion under Section 329(b) and Rule 2017. The presumptive remedy for disclosure violations under Rule 2016(b) is full disgorgement. See our Section 329(b) caselaw map for the leading authorities. Billing Review in Wyoming Cases If your attorney has charged fees you believe are excessive, the first step is a line-by-line billing review. Look for: Block billing: entries that combine multiple tasks under one time entry (e.g., "review file, draft motion, confer with client - 3.5 hours"). Block billing obscures per-task reasonableness. Vague descriptions: entries like "review case" or "attention to file" without specifying the task. Administrative work billed at attorney rates: filing, serving, mailing, formatting, or scheduling at $250+/hour. Duplicative entries: multiple attorneys or paralegals billing for the same task. Rate increases without disclosure: billing above the rate stated in the Rule 2016(b) statement. Billing for undone work: entries for tasks where no work product appears in the case record. For a step-by-step methodology, see How to Review Your Bankruptcy Attorney's Billing. Circuit Authority: 10th Circuit Wyoming bankruptcy cases are governed by 10th Circuit precedent. The leading 10th Circuit cases on attorney fee review are catalogued in our Section 329(b) caselaw map, organized by doctrinal prong (disclosure, reasonableness, remedy, procedural authority). The universally-applied framework combines: The lodestar method - hours reasonably expended multiplied by a reasonable hourly rate (adopted from Hensley v. Eckerhart, 461 U.S. 424 (1983)) The Johnson 12-factor test - Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) The Section 330(a)(3) factors - imported into Section 329(b) analysis as the measure of "reasonable value" Filing a Section 329(b) Fee Review in Bankr. D. Wyo. Fee review motions are filed in the bankruptcy court where the case is pending: Bankr. D. Wyo.. Any party in interest has standing: The debtor The trustee (Chapter 7/13) or Sub V trustee (Subchapter V) The U.S. Trustee (Region 19) Any creditor The court on its own motion under Rule 2017 A motion typically addresses four elements: (1) the attorney's disclosures under Section 329(a) and Rule 2016(b); (2) services rendered versus services charged; (3) reasonableness measured against the lodestar and Section 330(a)(3) factors; (4) the appropriate remedy (full or partial disgorgement). If you are reviewing attorney fees in a pending case, begin with a complete billing statement, the fee application (if any), and the Rule 2016(b) disclosure statement. These are the three primary documents for any Section 329(b) analysis. Related Resources Section 329 fee disgorgement overview Section 329(b) caselaw map - 8th + 10th Circuit and foundational authority Rule 2016(b) disclosure requirements What courts consider excessive U.S. Trustee fee review process How to audit attorney billing line-by-line Common fee issues and what to watch for Open Bankruptcy Project - Free, open-source bankruptcy information Research index only - not legal advice. Independent verification required before use in any filing. OBP section329.org 1328f.com 1328f.org Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5 --- ## File Bankruptcy Without a Lawyer in District of Columbia [2026] Source: https://bankruptcylawyerreview.org/states/district-of-columbia.html Pro Se Guide | How to File | Screener Filing Bankruptcy Without a Lawyer in District of Columbia Guide to filing pro se bankruptcy in District of Columbia. Forms, procedures, costs, and free resources. Frequently Asked Questions Can I file bankruptcy without a lawyer in District of Columbia? Yes. You have a constitutional right to file pro se (without an attorney). The court filing fee is $338 for Chapter 7 or $313 for Chapter 13. However, bankruptcy forms are complex, and mistakes can have serious consequences. Where do I get bankruptcy forms for District of Columbia? Official bankruptcy forms are available free at uscourts.gov/forms/bankruptcy-forms. You need the voluntary petition, all applicable schedules (A/B through J), the Statement of Financial Affairs, and the means test form (122A for Ch. 7 or 122C for Ch. 13). Is there free legal help for bankruptcy in District of Columbia? Yes. Contact your local Legal Aid office, the District of Columbia bar association's lawyer referral service, or a law school clinic. Many bankruptcy courts also have a pro se clinic or self-help desk. Bankruptcy in Nearby States Maryland · Virginia Free Bankruptcy Tools From the Open Bankruptcy Project -- free information, no strings. Discharge Screener Means Test Calculator Free, open-source bankruptcy transparency. No ads. No affiliate links. Supported by donations. Part of the Open Bankruptcy Project | Free information, no strings. Automatic Stay · 341 Meeting · 523(a) Exceptions · 727(a)(8) · Ch 7 vs 13 · How to File · Cost Guide Our research was cited by the federal judiciary as Suggestions 26-BK-3 and 26-BK-5