The U.S. Court of Appeals for the Third Circuit has upheld a series of penalties against an attorney who failed to disclose his fee to a U.S. bankruptcy court judge in a Chapter 11 case, and then accused the judge of bias.

The appeals court said the conduct of attorney Kevin Kerveng Tung in the Chapter 11 case of a small company warranted the disgorgement of a $19,400 fee that Tung failed to disclose to the court; as well as the denial of an additional, $31,819 fee application; and a referral to the chief judge for possible discipline.