L.Ed.2d 27 (1991)). “Bankruptcy courts ... have express authority under the Code and the Rules to sanction attorneys, including disbarment or suspension from practice” Id. at 281 (citing Price v. Lehtinen (In re Lehtinen), 564 F.3d 1052, 1058, 1062 (9th Cir.2009)); 11 U.S.C. § 105(a) (2012) (“The court may issue any order, process, or judgment that is necessary or appropriate to carry out the provisions of [the Bankruptcy Code].”). “The bankruptcy court has wide discretion in determining the amount of a sanctions award.” In re Kayne, 453 B.R. at 386 (internal quotation marks and citation omitted); see In re Withrow (BAP), 405 B.R. at 514. The BAP has endorsed the use of the ABA Standards to determine the appropriate sanctions for attorney misconduct. See In re Nguyen, 447 B.R. at 277 (<HOLDING>). The ABA Standards includes a non-exhaustive
holding that the failure to follow the burk directives in awarding an attorney fee constitutes an abuse of discretion holding that where party had reasonable grounds to believe conduct was in compliance with the district courts order imposition of sanctions was not warranted and constituted an abuse of discretion holding failure to exercise discretion is abuse of discretion holding that although failure to follow the aba standards is not an abuse of discretion they remain a helpful guide in the imposition of sanctions holding that the imposition of sanctions is reviewed for abuse of discretion