Eighth Circuit: Critique Services, LLC v. LaToya L. Steward


Bankruptcy, Ethics


Pre-petition motion for equitable disgorgement is maintainable by petitioner so long as the trustee has abandoned the estate.

Insufficient basis to question impartiality of judge who previously headed US Trustee's office that engaged in adversarial process against petitioner LLC.

Court properly construed pro se petition; LLC properly a party; partial payment didn't moot the claim, etc.

Sanctions upheld.




Critique Services, LLC  v.  LaToya L. Steward