Case Summary:
The Chapter 13 Debtors’ attorney filed an application for additional fees shortly before the Debtors obtained a discharge. The Debtors objected. The Court concluded that it had “arising under” jurisdiction pursuant to 28 U.S.C. § 1334(a) to consider the attorney’s request as to the estate. The request for compensation was denied because the estate was already closed, and no fees could be awarded from the closed estate. The Court also concluded that the attorney’s post-confirmation fees were not discharged in bankruptcy. The Court expressed no opinion as to whether it had jurisdiction to consider the attorney’s claim against the Debtors personally, or whether it would grant such a request.

Statute/Rule References:
11 U.S.C. § 330 (a)(4)(A) and (B) -- Compensation of Officers
11 U.S.C. § 503(b)(2)
11 U.S.C. § 507(a)(2)
11 U.S.C. § 1322(a)(2)
11 U.S.C. § 1328(a) -- Discharge
28 U.S.C. § 1334(a)
28 U.S.C. § 1334(b)
28 U.S.C. § 1334(c)(1)
Fed. R. Bankr. P. 2016 (b) -- Disclosure of Compensation Paid or Promised to Attorney for Debtor
Fed. R. Bankr. P. 2017
Fed. R. Bankr. P. 7001 -- Adversary Proceedings

Key Terms:
Attorney Fees - Award in Dischargeability Action
Compensation of Professionals
Discharge 
Dischargeability
Fee Dispute
Jurisdiction