In Re: Teresa A. Reynolds

CourtDistrict Court, S.D. Illinois
DecidedApril 16, 2021
Docket3:20-cv-01097
StatusUnknown

This text of In Re: Teresa A. Reynolds (In Re: Teresa A. Reynolds) is published on Counsel Stack Legal Research, covering District Court, S.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re: Teresa A. Reynolds, (S.D. Ill. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS

DEIGHAN LAW LLC, d/b/a UPRIGHT LAW, et al.,

Movants,

v. No. 20-CV-01176-SPM (lead case)

NANCY J. GARGULA, UNITED STATES TRUSTEE,

Respondent.

MEMORANDUM AND ORDER

McGLYNN, District Judge: Pending before the Court are Motions to Withdraw Reference from the United States Bankruptcy Court for the Southern District of Illinois filed by Movants Deighan Law LLC (“Deighan”) et al. pursuant to 28 U.S.C. § 157(d). Defendant United States Trustee Nancy J. Gargula filed responses in opposition to the requests to withdraw reference, and Deighan filed replies. The lead case is consolidated with thirty-five other cases presenting identical Motions and issues. BACKGROUND The origins of this current dispute begin with a dispute that arose out of potential misconduct and overcharging that allegedly occurred in a petition for relief under Chapter 7 of Title 11 of the Bankruptcy Code. See In re Chelsea Lynne Potter, Bankr. SDIL Case No. 19-60216-LKG. In the course of that proceeding, Chief United States Bankruptcy Judge Laura K. Grandy held a hearing to consider and act upon the disclosure of compensation. At the hearing, Judge Grandy issued a fee review order to Gargula relating to the fees Deighan charged Debtor Chelsea Lynne Potter. The issue then came before Chief United States District Judge Nancy J. Rosenstengel on Debtor Potter’s first motion to withdraw reference filed by Attorney

Eric James Homa from Deighan. See Homa v. US Trustee, SDIL Case No. 19-CV- 01139-NJR. In that motion, Debtor Potter requested the Court to establish an updated presumptively reasonable attorney fee for Chapter 7 cases and give guidance relating to the propriety of Gargula’s use of a Rule 2004 Examination as a tool to evaluate the reasonableness of a Chapter 7 attorney fee. Judge Rosenstengel denied Debtor Potter’s motion to withdraw the reference and ordered

the case to proceed in the bankruptcy court because she did not find cause to withdraw. One would think Judge Rosenstengel’s order spelled the end of Deighan challenging the bankruptcy court’s ability to review fee arrangements and fees paid to attorneys. But Deighan and its attorneys are nothing if not persistent. In thirty-six of its petitions for relief under Chapter 7 pending in this district’s bankruptcy court, including Debtor Potter’s petition, Deighan objected to

FED. R. BANK. P. 2004(a) examination motions filed by the Gargula and filed motions to close the cases, stating that the estates were fully administered, closure was mandatory, and Judge Grandy’s fee-related investigations violated the debtors’ due process and equal protection rights. Judge Grandy granted Gargula’s Rule 2004 motions permitting her to obtain documents and examine the debtors and Deighan Attorneys. Judge Grandy also denied the motions to close the cases. Shortly thereafter, in late September 2020 and early October 2020, Deighan filed Motions to Withdraw Reference in this Court on those petitions.1 LEGAL STANDARD

District courts have original jurisdiction over all bankruptcy proceedings arising out of Title 11 of the United States Code, see 28 U.S.C. § 1334, but a district court may “provide that any or all cases under title 11 [of the United States Code] and any or all proceeding arising under title 11 or arising in or related to a case under title 11 shall be referred to the bankruptcy judges for the district.” 28 U.S.C. § 157(a). This district’s Local Bankruptcy Rule 1001.1 automatically refers all cases

under Title 11 to the bankruptcy judge in this district. A district judge “may withdraw, in whole or in part, any case or proceeding referred under this section, on its own motion or on timely motion of any party, for cause shown” for the removal and “shall, on timely motion of a party, so withdraw a proceeding if the court determines that resolution of the proceeding requires consideration of both title 11 and other laws of the United States regulating organizations or activities affecting interstate commerce.” 28 U.S.C. § 157(d).

Section 157(d) does not define “cause,” but courts generally consider the following factors in determining whether cause exists: whether withdrawal would promote judicial economy or uniformity and efficiency in bankruptcy

1 Deighan also recently filed other Motions to Withdraw the Reference in companion cases involving adversarial complaints filed by Gargula, US Trustee v. Homa, SDIL Case No. 21-CV-00183-SPM (related to In re Potter); US Trustee v. Buch et al, SDIL Case No. 21-CV-00276-SPM (related to In re Brucker); and US Trustee v. Buch et al, SDIL Case No. 21-CV-00316-SPM (related to In re McClatchery). administration; whether it would reduce forum shopping; whether it would cause delay and costs to the parties; whether a particular court has familiarity with the case; whether the parties have demanded a jury trial; and whether a core or non-

core proceeding is involved. See Adelsperger as Tr. For Consol. Bankr. Estate of 5 Star Commercial, LLC v. 3d Holographics Med. Imaging Inc., No. 3:16-CV-759- HAB, 2019 WL 2206091, at *2 (N.D. Ind. May 21, 2019). As another district court put it, district courts have “broad discretion to determine whether to withdraw a reference based on cause, but at the same time, permissive withdrawal is the exception, rather than the rule, as bankruptcy

jurisdiction is ‘designed to provide a single forum for dealing with all claims to the bankrupt’s assets.’” In re K & R Express Sys., Inc., 382 B.R. 443, 446 (N.D. Ill. 2007) (citing In re Sevko, Inc., 143 B.R. 114, 115 (N.D. Ill. 1992), and quoting Xonics v. First Wis. Fin. Corp., 813 F.2d 127, 131 (7th Cir. 1987)). ANALYSIS Deighan asks the Court to withdraw the reference in order to close this case and vacate any order inconsistent with case closure. Under 28 U.S.C. § 157(d), a

district court may withdraw reference in two ways: permissive withdrawal or mandatory withdrawal. First, a district court “may withdraw, in whole or in part, any case or proceeding referred under this section . . . for cause shown.” Id. Likewise, the district court “shall, on timely motion of a party, so withdraw a proceeding if the court determines that resolution of the proceeding requires consideration of both [the Bankruptcy Code] and other laws of the United States regulating organizations or activities affecting interstate commerce.” Id. The moving party, in this case Deighan, bears the burden of showing that a withdrawal of reference is justified. In re Vicars Ins. Agency, Inc., 96 F.3d 949, 955 (7th Cir.

1996). Deighan argues that “withdrawal of the reference is mandatory under § 157(d) because resolution of the proceeding to be withdrawn requires substantial and material consideration of non-Bankruptcy Code federal law—namely, the Case or Controversy, Due Process, and Equal Protection Clauses of the U.S. Constitution.” In the alternative, Deighan argues that this Court should withdraw

the reference in these cases in its discretion. Gargula responds that the Motions were not timely filed.

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Related

In Re Sevko, Inc.
143 B.R. 114 (N.D. Illinois, 1992)
Holland v. LTV Steel Company, Inc.
288 B.R. 770 (N.D. Ohio, 2002)
Barnett v. Stern
909 F.2d 973 (Seventh Circuit, 1990)
Elscint, Inc. v. First Wisconsin Financial Corp.
813 F.2d 127 (Seventh Circuit, 1987)

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In Re: Teresa A. Reynolds, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-teresa-a-reynolds-ilsd-2021.