In re Birchall

Ruling: 
Incarceration for civil contempt was within scope of automatic stay.
Procedural posture: 
A judgment creditor of a chapter 7 debtor filed a motion for a determination that the automatic stay of 11 U.S.C. § 362 did not apply to the debtor's incarceration for civil contempt. The debtor filed a motion to order the creditor to take all steps necessary to secure the immediate release of the debtor from incarceration.
Issue: 
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