In Re Balderas
This decision addresses post-confirmation attorneys' fees in Chapter 13 bankruptcy cases, using the Balderas case as a factual background. The debtors in the Balderas case sought modification of their plan due to payment defaults and requested $350 in attorney's fees for the motion. The court outlines the history of the Balderas' numerous modifications, moratoriums, and associated attorney fee awards, totaling $3,495, highlighting how these fees were paid out of plan distributions at the expense of creditors. The court analyzes sections 1326(b)(1) and 330(a)(4)(B) of the Bankruptcy Code to determine the reasonableness and payment method of such fees. Ultimately, the court establishes new rules for post-confirmation attorney fee awards in the Western District of Texas, San Antonio Division, including a $2,500 prima facie base fee, a $100 per month payment rate for additional fees, and specific guidelines for various types of motions. The current $350 fee request for the Balderas case's moratorium is approved but with caution against future similar requests.