11 Bankruptcy Decisions Continued from Page 9 this interpretation cannot be reconciled with Sec- tion 330a1s text and that bearing the cost of fee litigation provides no disincentive to bankrupt- cy counsel. The impact the Baker Botts decisions will have on bankruptcy counsel in the Ninth Circuit is as yet unknown. Prior to these rulings the Ninth Circuit has long interpreted 11 U.S.C. 330a as placing fee-defense compensation within the Bankruptcy Courts discretion allowing it to award fees for reasonable and necessary work. See In re Nu- corp Energy Inc. 764 F.2d 655 656 9th Cir. 1985 In re Riverside-Linden Investment Co. 945 F.2d 3209th Cir. 1991 In re Smith 317 F.3d 918 9th Cir. 2002 In re Wind N Wave 509 F.3d 938 9th Cir. 2007. The Baker Botts decision howev- er makes clear that litigation challenges to the al- lowance of professional fees are encouraged and that counsel should take this into consideration before representing an administrator of the bank- ruptcy estate. __________________________________ Melissa Davis Lowe and Elyza P. Eshaghi are associate attorneys at the Irvine California office of Shulman Hodges Bastian LLP. The views expressed here are the authors and not those of Shulman Hodges Bastian its clients or the FBAOC. United States Magistrate Judge Robert N. Block United States Magistrate Judge Robert N. Block retired this year after twenty years on the bench. Appointed by his colleagues in 1995 he served as the Chief Magistrate Judge from 2000 through 2005. Judge Block was not only a valued judicial officer but an active member of the Federal Bar AssociationOrange County Chapter where he served on the board of di- rectors. The Orange County Chapter of the Federal Bar Association thanks Judge Block for his many contributions and wishes him well in his retirement.