Small Case Roundup

8th Circuit Briggs v. LaBarge (03/24/06 - No. 05-6054) Bankruptcy Appellate Panel. An order granting a bankruptcy trustee's motion for an order denying attorney's fees and disgorgement of certain fees is affirmed where there was no error in a finding that a bankruptcy attorney's dual representation of a debtor and a bank was an impermissible conflict of interest. 9th Circuit Sherman v. Sec. & Exch. Comm'n (03/23/06 - No. 03-56601) A decision reversing a bankruptcy court's denial of a motion brought by the SEC to dismiss debtors' bankruptcy petition is reversed where, although the SEC had standing and the case was not moot, the bankruptcy petition could not, under established precedent, be dismissed for "cause" under 11 U.S.C. section 707(a). 11th Circuit Amend v. 485 Properties, LLC (03/22/06 - No. 04-14635) Based on prior decisions entered in this case and based on the Georgia Supreme Court's answer to the certified question about whether procuring cause is an element of a quantum meruit claim, the district court's grant of summary judgment on plaintiff's quantum meruit claim for brokerage services is affirmed.