On January 14, 2021, the Supreme Court of the United States resolved a circuit split by unanimously holding that the “mere retention of property” by a creditor after the time a debtor files its bankruptcy petition does not violate the automatic stay under § 362(a)(3) of the United States Bankruptcy Code, 11 U.S.C. §§ 101, et seq. (“Bankruptcy Code”). In City of Chicago v.

A recent decision from the United States Bankruptcy Court for the Central District of Illinois (“Court”) is a stark reminder of the importance of paying attention to notices received from bankruptcy cases and the need for creditors to consider retaining counsel to protect their interests in such cases. In In re Kevin R. Gaffney, after Kevin Gaffney (“Debtor”) filed a petition for relief under chapter 7 of the United States Bankruptcy Code, 11 U.S.C.