RKF Global PLLC v. Nuti Hart LLP

CourtUnited States Bankruptcy Court, E.D. California
DecidedJune 27, 2023
Docket23-02025
StatusUnknown

This text of RKF Global PLLC v. Nuti Hart LLP (RKF Global PLLC v. Nuti Hart LLP) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
RKF Global PLLC v. Nuti Hart LLP, (Cal. 2023).

Opinion

1 FOR PUBLICATION UNITED STATES BANKRUPTCY COURT 2 EASTERN DISTRICT OF CALIFORNIA 3 In re: ) ) 4 SUNERGY CALIFORNIA LLC, ) Case No. 21-20172 ) 5 ______________________________D_e_b_t_o_r_._______________) ) 6 RKF GLOBAL, PLLC, an Illinois ) Adv. No. 23-02025 Professional Limited Liability ) 7 Company, ) DCN No. NH-1 Plaintiff, ) 8 v. ) ) 9 NUTI HART LLP, a California ) Limited Liability Partnership, ) 10 GREGORY C. NUTI, a California ) Resident, CHRISTOPHER H. HART, a) 11 California Resident, HANK ) SPACONE, a California Resident ) 12 and Post-Confirmation ) Trustee, and JEFFREY PEREA, a ) 13 California Resident and Chapter ) 11 Trustee, ) 14 Defendants. ) ________________________________) 15 16 CHRISTOPHER M. KLEIN, Bankruptcy Judge: 17 Special counsel employed under 11 U.S.C. § 327(e) by the 18 debtor before it was ousted from debtor-in-possession status took 19 so much umbrage at objections to its $447,658.50 fee application 20 that it sued the chapter 11 trustee, the post-confirmation 21 trustee, and counsel for abuse of process, fraud, conspiracy, 22 promissory estoppel, and breach of contract, demanding damages 23 measured by any fees that are disallowed plus punitive damages 24 for the insult and trial by jury. The doctrine of conflict 25 preemption spells doom for special counsel. 26 Congress has provided in the Bankruptcy Code a comprehensive 27 system for employing and paying professionals for services in the 28 administration of bankruptcy estates. Bankruptcy Code §§ 326-331 1 govern employment and compensation. Professional fees and 2 expenses are awarded under standards prescribed by § 330 and paid 3 as administrative expenses under § 503(b)(2). Objections to fee 4 applications are “contested matters” pursuant to Rule 9014 in 5 which trial procedures, including testimony, evidence, and 6 findings characteristic of an adversary proceeding are available. 7 The fee application process established by Congress serves 8 as the exclusive remedy for professionals employed by an estate. 9 To permit disaffected professionals to sue trustees and their 10 counsel on common-law theories that are inextricably intertwined 11 with a pending fee application would circumvent and constitute an 12 obstacle to the accomplishment and execution of the full purposes 13 and objectives of Congress. 14 The common-law theories that special counsel alleges in its 15 adversary proceeding complaint conflict with the Congressional 16 fee award scheme in a manner that dictates application of the 17 doctrine of conflict preemption. Special counsel can present its 18 evidence when prosecuting its pending contested fee application. 19 There being no jurisdiction, this adversary proceeding is 20 DISMISSED. 21 22 Jurisdiction 23 Jurisdiction is founded on 28 U.S.C. § 1334(a). Fee 24 applications are core proceedings concerning administration of 25 the estate that a bankruptcy judge may hear and determine. 28 26 U.S.C. § 157(b)(2)(A). This adversary proceeding designed to 27 circumvent the fee application process by alleging preempted 28 causes of action is likewise a core proceeding a bankruptcy judge 1 may hear and determine regardless of consent. 2 There is no Seventh Amendment right to trial by jury on fee 3 applications by employed professionals who, by definition, have 4 submitted to the equitable jurisdiction of the bankruptcy court. 5 Hale v. U.S. Trustee, 509 F.3d 1139, 1147 (9th Cir. 2007); cf. In 6 re Wood & Henderson, 210 U.S. 246, 250 (1908) (Bankruptcy Act – 7 professional fees not “legal” in nature). 8 There is no jurisdiction over preempted causes of action. 9 Ingersoll-Rand Co. v. McClendon, 498 U.S. 133, 142 (1990). This 10 court has jurisdiction to determine its own jurisdiction. 11 12 Facts 13 Sunergy California LLC, a photovoltaic module manufacturer, 14 filed this chapter 11 case in January 2021. After six months of 15 poor performance, this court granted the creditor’s committee’s 16 motion to appoint a chapter 11 trustee in July 2021. 17 Jeffrey Perea was appointed chapter 11 trustee. Perea hired 18 Nuti Hart LLP as counsel. 19 The Chapter 11 trustee eventually agreed with the committee 20 that liquidation was warranted. 21 A Joint Plan of Liquidation was confirmed July 28, 2022. 22 Hank Spacone was appointed as Post-Confirmation Trustee. 23 After confirmation, fee applications by Sunergy’s counsel 24 and its special counsel seeking a total of $587,254.52 in fees 25 and costs drew objections from the United States trustee and the 26 Post-Confirmation Trustee (“liquidating trustee”). 27 Sunergy’s primary counsel employed under § 327(a), Gonzalez 28 & Gonzalez Law, P.C., seeks $139,635.92. 1 The United States trustee and the liquidating trustee each 2 objected to $25,606.00 of the Gonzalez fee application for the 3 period after the chapter 11 trustee was appointed as not 4 permitted in light of Lamie v. U.S. Trustee, 540 U.S. 526 (2004). 5 The liquidating trustee also objected to Gonzalez fees for: 6 lack of benefit to the estate; untruthful schedules and statement 7 of financial affairs; inaccurate monthly operating reports; 8 improper listing of prepetition obligations as postpetition 9 accounts payable; and the dubious relationship with RKF. 10 This court bifurcated the Gonzalez fee contest and ruled 11 that fees are not available to § 327(a) DIP counsel for services 12 rendered after appointment of a chapter 11 trustee. In re Sunergy 13 California LLC, 646 B.R. 840 (Bankr. E.D. Cal. 2022). The 14 Bankruptcy Appellate Panel affirmed. No. 22-1230, (9th Cir BAP 15 2023). The rest of the Gonzalez fee application is pending. 16 Plaintiff RKF was employed as § 327(e) special counsel to: 17 represent Sunergy in five lawsuits (including its Ninth Circuit 18 appeal challenging an arbitration award in favor of DEPCOM Power, 19 Inc.); coordinate state cases; and “draft[] and review[] 20 contracts in the regular course of business, and provide[] legal 21 advice and counseling that would be customarily required for any 22 supply chain and transactionally based business similar to 23 Debtor.”1 Dkt. 59 at p. 4. 24 The Chapter 11 trustee, concluding that liquidation was 25 appropriate, elected not to pursue litigation over unsecured 26 27 1Debtor and Debtor-In-Possession’s Application for an Order 28 to Employ RKF PLLC as Special Counsel For Litigation and Selection [sic] Transaction Work, Dkt. 59, at p. 4. 1 claims, including the DEPCOM Power appeal. Hence, he did not 2 require RKF’s special counsel services. 3 Plaintiff RKF filed a fee and cost application for 4 $447,668.60 for services as special counsel under § 327(e). 5 The United States trustee and the liquidating trustee 6 objected to the RKF fees on multiple grounds focused on § 330 7 standards, disclosure requirements, and whether RKF overstepped 8 the bounds of its § 327(e) employment. Those objections remain to 9 be adjudicated in the contested RKF fee application. 10 RKF counterattacked by filing an adversary proceeding and 11 demanding a jury trial.

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Related

In Re Wood and Henderson
210 U.S. 246 (Supreme Court, 1908)
Savage v. Jones
225 U.S. 501 (Supreme Court, 1912)
Ingersoll-Rand Co. v. McClendon
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Medtronic, Inc. v. Lohr
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Crosby v. National Foreign Trade Council
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Lamie v. United States Trustee
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Hibbs v. Winn
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Richard Stengel v. Medtronic Incorporated
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544 B.R. 886 (Ninth Circuit, 2016)
In re Scoggins
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Bluebook (online)
RKF Global PLLC v. Nuti Hart LLP, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rkf-global-pllc-v-nuti-hart-llp-caeb-2023.