151857P.pdf   07/07/2016  Critique Services, LLC  v.  LaToya L. Steward
   U.S. Court of Appeals Case No:  15-1857
                          and No:  15-1988
   U.S. District Court for the Eastern District of Missouri - St. Louis   
   [PUBLISHED] [Kelly, Author, with Loken and Gruender, Circuit Judges] 
   Civil case - Bankruptcy. The Chapter 7 trustee effectively abandoned the 
   claim for disgorgement of attorneys' fees based on ineffective assistance 
   of counsel, and debtor had standing to bring the claim; Critique's motions 
   to recuse the bankruptcy judge were untimely under 28 U.S.C. Sec. 455(a), 
   and, in any event, they failed to demonstrate that the judge's 
   impartiality might reasonably be questioned; no error in docketing 
   debtor's pro se motion as a motion to disgorge; Critique was properly 
   served and debtor's discovery requests were properly directed to it; 
   Critique's alleged attempt to tender a portion of the fees debtor had paid 
   did not moot this action; the matter never settled and the court did not 
   err in denying, without prejudice, a motion to approve a settlement; 
   unclean hands doctrine had no applicability to the case; sanctions imposed 
   on Critique and its counsel, while substantial, were proportionate to 
   their bad faith conduct in this matter; no error in imposing civil 
   contempt penalties against counsel or in suspending them from practice 
   before the bankruptcy court.