United States Supreme Court held on May 18, 2015, in the case of HARRIS v. VIEGELAHN, that when a chapter 13 case is converted to chapter 7, any undistributed funds that the chapter 13 trustee is holding, must be returned to the debtor.

The court noted that chapter 13 is a voluntary procedure. Even there was only about $5,000 at stake here, the Supreme Court nevertheless accepted the issue, due to inconsistent rulings among the various circuits.