Hale

Appellant Tom Hale assisted Debtors Eric and Selina Jones in filing a bankruptcy petition. The bankruptcy court found that, in doing so, Hale failed to honor his legal and ethical obligations as their lawyer. The bankruptcy court denied Hale’s motion requesting judicial recusal, denied his request for a jury trial on the reasonableness of his attorney fees, disgorged him of his attorney fees, and sanctioned him. The district court affirmed those rulings, and Hale timely appealed. On appeal, he raises only the attorney fees and sanction issues. We affirm.

FACTUAL AND PROCEDURAL HISTORY

Hale provided “PRE-FILING legal services” to Debtors pursuant to a signed disclosure agreement. For a $250 fee, he agreed to analyze Debtors’ financial situation and prepare their bankruptcy petition and required exhibits, but disclaimed representing them at the meeting of creditors required under 11 U.S.C. § 341 . In addition, the agreement specified that Hale’s representation “d[id] not include the following services: Adversary proceedings, appeals, and/or conversions, non-dis-chargeability proceedings, or any other representation.” Hale refers to this practice as providing “unbundled” legal…