In a recently published decision, the U.S. Bankruptcy Court for the Eastern District of North Carolina held that a creditor violated both the automatic stay and discharge injunction when the creditor made a criminal referral against a debtor on account of a bounced rent check. The creditor contended that its actions fell within an exception to the automatic stay for the "commencement or continuation of a criminal action or proceeding" against a debtor. The court, however, rejected this contention, concluding that the creditor's "primary purpose" in commencing the criminal proceeding was to recover a debt. See, In re Kimbler, 624 B.R. 774 (Bankr. E.D.N.C. 2020).