In City of Chicago v. Fulton, 141 S. Ct. 585 (2021), the Supreme Court held that a creditor had no affirmative duty to turn over a vehicle impounded prepetition. A concurring opinion noted that a turnover request may require an adversary proceeding but that bankruptcy courts may find it prudent to expedite proceedings or order preliminary relief requiring a temporary turnover. This may be critical if a debtor needs a vehicle to earn income used to fund a chapter 13 plan.

Attached here is a suggested complaint for turnover of property, together with a motion for a temporary restraining order and preliminary injunction and proposed order that may be helpful in expediting a turnover request. These forms must be modified to suit the facts of each case. The court does not guarantee that they will produce the desired result in any case.