Breaking with a Sixth Circuit decision to the contrary, in a March 2021 decision in Stewart v. Holland, the District Court for the Western District of Pennsylvania held that unfair labor claims brought by the Department of Labor against a debtor under the Fair Labor Standards Act ("FLSA") were not barred by the automatic stay but could instead proceed under the "police powers exception." A debtor's bankruptcy filing triggers the "automatic stay," which immediately enjoins, among other things, the commencement and continuation of most litigation against the debtor. 2 The purpose of the automatic stay is to afford the debtor "breathing room" either to