Robb v. Harder (In re Robb), 534 B.R. 354

Jessica Robb filed Chapter 7 on March 6, 2014; Janice Harder was appointed trustee and discovered a defect in the deed of trust on the debtor's home.
Robb moved to convert to Chapter 13; the court granted the motion and the case converted on June 24, 2014.
Robb filed a Chapter 13 plan using the model "liquidation analysis pot" treatment, requiring $590/month to the trustee for plan duration.
Trustee Harder filed a $450 unsecured priority proof of claim for time spent investigating avoidance of lien, exemption issues, and related work; Robb objected, arguing trustee compensation must follow 11 U.S.C. § 326 and that no money was disbursed pre-conversion.
The bankruptcy court overruled the objection, reasoning § 326(a) is not the exclusive source of trustee compensation and that allowing the claim promotes diligence and discourages concealment of assets.
The debtor appealed; the panel concluded Robb lacked appellate standing because she failed to show she was "aggrieved"—the trustee's claim did not diminish her property, increase her burdens, or impair her rights under the plan.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Robb has standing to appeal allowance of trustee's claim	Robb argued trustee's claim is improper under § 326 and should be disallowed; she appealed the allowance	Trustee maintained the claim is permissible despite § 326 and was properly allowed	Robb lacked appellate standing; appeal dismissed for lack of jurisdiction
Whether § 326(a) is the exclusive basis for trustee compensation	Robb contended § 326 governs trustee compensation and applies only to disbursements, so no compensation was due pre-conversion	Court and trustee argued § 326 is not exclusive and a trustee may be compensated for services even if no moneys were disbursed	Bankruptcy court held § 326(a) is not the only compensation method and allowed the claim (substantive ruling upheld but not reached on appeal due to lack of standing)

Nebraska v. Strong (In re Strong), 305 B.R. 292 (8th Cir. BAP) (discussing the panel's duty to examine jurisdiction)
Sears v. Badami (In re AFY), 734 F.3d 810 (8th Cir.) (person-aggrieved appellate-standing standard in bankruptcy)
Weihs v. Kenkel (In re Weihs), 229 B.R. 187 (8th Cir. BAP) (jurisdictional review principles)
LaBarge v. Benda (In re Merrifield), 214 B.R. 362 (8th Cir. BAP) (appellant's burden to show they are aggrieved)
Williams v. Marlar (In re Marlar), 267 F.3d 749 (8th Cir.) (defining "person aggrieved" as those pecuniarily and directly affected)
Kieffer v. Riske (In re Kieffer-Mickes), 226 B.R. 204 (8th Cir. BAP) (debtor generally lacks standing to object to claims absent a surplus)