The following excerpt is from In re Siller, 427 B.R. 872 (Bankr. E.D. Cal. 2010):
Under Bankruptcy Code 502(b), a claim for prepetition attorney's fees for counsel for a debtor is, if state law also requires reasonableness in its own attorney's fee structure, subject to two tiers of reasonableness scrutiny. First, if the claim does not surmount whatever reasonableness standard state law imposes, then it will be disallowed under 502(b)(1) as being "unenforceable" as not being "reasonable" under "applicable law." 11 U.S.C. 502(b)(1). This is consistent with the doctrine that state law governs the substance of claims in bankruptcy "unless some federal interest requires a different result." Butner v. United States, 440 U.S. 48, 54-55, 99 S.Ct. 914, 59 L.Ed.2d 136 (1979).
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