In January 2020, we analyzed a split among the Circuit Courts regarding whether a non-debtor holding a debtor’s property on the petition date has an affirmative obligation under section 362(a)(3) of the Bankruptcy Code to return that property to the debtor immediately following the filing of the bankruptcy petition.

At the request of the FTC and the State of Florida, last week, the Southern District Court of Florida temporarily shut down two major telemarketing operations.