Yes.
As reported by Robin Miller of CBAR, in In re Ulrich, 517 B.R. 77 (Bankr. E.D. Mich., Sept. 5, 2014), Chief Bankruptcy Judge Phillip J. Shefferly, held that despite the Chapter 13 debtor’s law firm’s “demonstrated skill and expertise in many bankruptcy cases before this Court, and its success in confirming the second amended plan in this case,” the court awarded the firm $5,375 in fees for pre-confirmation work, rather than the $7,784.50 requested, since, given the absence of any difficult or complex issues, and taking into account all of the other factors specified in Code §§330(a)(3), (4), the court found that 20–25 hours represented a range of the reasonable number of hours needed to represent the debtor in the case through confirmation of the debtor’s plan. The court noted that a local bankruptcy rule required that a fee application in a Chapter 13 case for more than $3,500.00 must “specifically identify the circumstances of the case that make the amount requested reasonable.”
(case no. 2:13-bk-59610)