18 U.S.C. § 155
Fee agreements in cases under title 11 and receiverships
Whoever, being a party in interest, whether as a debtor, creditor, receiver, trustee or representative of any of them, or attorney for any such party in interest, in any receivership or case under title 11 in any United States court or under its supervision, knowingly and fraudulently enters into any agreement, express or implied, with another such party in interest or attorney for another such party in interest, for the purpose of fixing the fees or other compensation to be paid to any party in interest or to any attorney for any party in interest for services rendered in connection therewith, from the assets of the estate, shall be fined under this title or imprisoned not more than one year, or both.
Notes of Decisions
Cited in 14
cases (2 in the last 5 years), 1968–2025 · leading case: In Re Gianulias
In Re Gianulias (1989)
“Appellant believes that the exchange of such information in compliance with the court’s order exposes fee applicants to criminal prosecution for fee fixing under 18 U.S.C. § 155 and to liability under federal antitrust laws.”
In Re Printing Dimensions, Inc. (1993)
“18 U.S.C. § 155 . Counsel may file interim fee applications only once every 120 days, unless the court permits more frequent applications.”
United States v. Shulman (1979)
“Indeed, it is a federal misdemeanor for a district judge to approve payment of legal fees settled by agreement among the attorneys following a dispute in a bankruptcy case ( 18 U.S.C. § 155 ). As a matter of policy, the Court should hold the Congress to a precise statement of…”
In Re One City Centre Associates (1990)
“The court finds the allegations to be incredible (especially in light of 18 U.S.C. § 155 which renders such agreements criminal), and the supporting declaration of James Kassis unbelievable.”
Knapp v. Seligson (1968)
“As the Referee rightly said, the papers “are replete with invective and mutual recrimination”; we add that some of the objections, such as that the proposed purchase would violate 18 U.S.C. § 155 , § 488 of the New York Judiciary Law, McKinney’s Consol.”
Stipe v. Mullendore (1975)
“A hearing was held; before evidence was presented on this application, the trial judge indicated the contingent fee contract would not be considered in arriving at a fee because of 18 U.S.C. § 155 and 11 U.S.C. § 96 (d), and that the allowance would be considered on a quantum…”
In the Matter of Cybern Education, Inc., Debtor. United States of America v. Harry A. Ash (1973)
“Each of the three applicants for allowance executed an affidavit swearing (1) that there was no agreement or understanding for a division of compensation and (2) that there was no agreement with any other parties or attorneys in the proceeding to fix fees contrary to 18 U.S.C. §…”
Harris v. Ben-Ezra & Katz, P.A. (In Re Harris) (2011)
“The Complaints assert ten different causes of action against all of the Defendants: (i) Abuse of the Bankruptcy Process, (ii) Fraud on the Court, (iii) Declaratory and Injunctive Relief, (iv) Violation of the Automatic Stay, (v) Contempt of the Bankruptcy Code, (vi) Contempt of…”
Lutheran Hospitals & Homes Society v. Cracchiolo (1970)
“Reliance on 18 U.S.C. § 155 is misplaced. No agreement violating that section was made.”
Boy Scouts of America - Adversary Proceeding (2023)
“Those provisions were: (i) “a pact that refused to settle even a single sex abuse claim, and even associate with any lawyer who represents a sex abuse victim, unless that lawyer joined their pact;” Gi) an agreement that Debtors would pay certain of the Coalition’s attorneys’…”
McLean v. Bondi (2025)
“” 2 The indictment under 18 U.S.C. § 155 (a)(1) alleges that McLean threatened an Immigration Judge by threatening to “BF**k up’ the judge, and to Bbash in her f**king head.”
Barkley v. Prommis Solutions Holding Corp. (In Re Thorne) (2012)
“Violation of 18 U.S.C. § 155 Proscription Against Fixing Attorney’s Fees in a Bankruptcy Proceeding.”
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