In re Stewart, 970 F.3d 1255 (10th Cir. Aug. 14, 2020)

Counsel received $348,404.41 for representing debtors in a bankruptcy, but then failed to disclose his fee arrangement as required by statute and rule.  Reversing the bankruptcy court’s $25,000 sanction, the Tenth Circuit held that the presumptive sanction for failure to disclose fee arrangements under section 329(a) of the bankruptcy code would be disgorgement of the entire fee, absent a showing of good cause for a lesser sanction.