BK Court lacks Jurisdiction to Approve a Professionals Fees in a Dismissed Chapter 11 Case - Illinois BK Court

After a Chapter 11 case was dismissed and closed, a professional filed his second and final application for compensation.  The Court determined that because there is no longer a bankruptcy estate, there is no longer an estate from which compensation can be paid.  With the estate's disappearance, the court's duty to oversee its administration has disappeared.  The determination of reasonableness of the compensation would be pointless and a purely academic exercise.  As the federal court has no authority to "give opinions...upon abstract propositions" The Court found that the motions were moot and were denied based upon lack of jurisdiction.

In re Sweports, Ltd.

United States Bankruptcy Court for the Northern District of Illinois, Eastern Division

June 18, 2014, Decided

Chapter 11, No. 12 B 14254