In 1984, the year following the decision in this case, Congress amended Bankr. Code 362(a)(3) to read that the automatic stay prohibits "any act to obtain possession of property of the estate or of property from the debtor or to exercise control over property of the estate (language in italics added)."   Subsequent cases have therefore confronted and split on the question of whether a creditor's refusal to honor a debtor's request that the creditor return collateral (usually an automobile) repossessed prior to the filing of a Chapter 13 constitutes a violation of the stay.  Compare In re Zaber, 223 Bkrtcy. Rptr.102 (Bkrtcy. N.D. Tex. 1998) (violation of stay; creditor can protect collateral when faced with request for turnover by seeking adequate protection after turnover or through emergency motion for relief from stay, if necessary) with In re Spears, 223 Bkrtcy. Rptr. 159 (Bkrtcy. N.D. Ill. 1998)(no violation of stay; debtor can move for turnover pursuant to Bkry. Code 542).