In re St. Vincent

Bank's refusal to release hold on funds in face of state law liability was not a willful violation of stay.
Procedural posture: 
Chapter 13 debtors moved for sanctions against their non-creditor bank, asserting it refused to provide access to their bank account funds after they notified the bank that they had filed for bankruptcy. Debtors argued that the refusal to release the funds was a willful violation of the automatic stay, and sought attorneys' fees and consequential damages under 11 U.S.C.S. § 362(k).
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Consumer case opionion summary, case decided on April 01,2011, LexisNexis #0511-006