On January 14, 2021, the U.S. Supreme Court held in City of Chicago v. Fulton, 592 U.S. __ (2021), that a creditor in possession of a debtor's property does not violate the automatic stay, specifically section 362(a)(3) of the Bankruptcy Code, by retaining the property after the filing of a bankruptcy petition. The Court's decision provides important guidance to bankruptcy courts, practitioners, and parties on the scope of the automatic stay's requirements. Fulton arose from four separate bankruptcy cases. In each case, the City of Chicago ("City") had impounded the debtor's vehicle due to the debtor's failure to pay fines for motor vehicle infractions. Each debtor filed a chapter 13 bankruptcy petition and requested that the vehicle be returned. When the City refused, the bankruptcy court sanctioned the City for violating the automatic stay. In a consolidated appeal of the four cases, the Seventh Circuit affirmed, reasoning that the City had acted "to exercise control over property of the estate," 11 U.S.C. § 362(a)(3), especially in light of the Bankruptcy Code's turnover obligation under 11 U.S.C. § 542(a), which mandates that an entity in possession of estate property "shall deliver" the property to the trustee. A majority of circuits to address this question reached the same conclusion.