were dischargeable and, in fact had been discharged; the debt Johnson owes Edin-boro College is not dischargeable. Consequently we can find no basis in the Bankruptcy Code to nullify [the college’s] policy of withholding transcripts from those students who ... have not had their debts discharged. Id. at 166 Johnson was decided under § 525 and nowhere even cites 11 U.S.C. § 362. Yet afterwards, some courts applied the decision to debtors’ claims that a university’s refusal to provide a transcript upon request violated § 362(a), finding Johnson’s distinction regarding nondischargeable debts to be outcome determinative under § 362(a). See In re Gustafson, 111 B.R. at 285 (where debts declared or presumed nondischargeable remain subject to the automatic stay); Parker, 334 B.R. at 536 (<HOLDING>). 3. In Billingsley and Najafi, the two
holding that although the automatic stay only applies to proceedings against the debtor  counterclaims seeking affirmative relief against a debtor implicate the automatic stay holding that student debt declared nondischargeable remains subject to the automatic stay holding judgment in violation of automatic stay void holding nondischargeable postpetition interest on debt that was determined to be nondischargeable under section 523a2 as obtained by fraud holding that the automatic stay did not bar the filing of a proof of claim where the debtor actively litigated a separate action during the pending bankruptcy proceeding because to permit the automatic stay provision to be used as a trump card played after an unfavorable result was reached  would be inconsistent with the underlying purpose of the automatic stay