us revisit the integrity of his conviction, we decline to do so. Similarly, Appellant’s third contention suffers from the same fatal flaw as his second. During the pendency of Rash-id’s appeal of the forfeiture order, but after Rashid filed for bankruptcy, the United States recorded a lien on Rashid’s Philadelphia property. During the proceedings in the Bankruptcy Court, the Government conceded that Rashid had some interest in his Philadelphia property during the pendency of his appeal of the forfeiture order. The Government’s post-petition filing of its judgment was then improper under 11 U.S.C. § 362(a). An injured debtor may only recover actual damages including attorneys’ fees for a willful violation of a stay and, in appropriate circumstances, may recover punitive dam 3d Cir.1985) (<HOLDING>). 3 . Towers concerns a civil rather than
holding that because the restitution was ordered as part of a state criminal prosecution it was excepted from discharge in bankruptcy holding that restitution ordered pursuant to the vwpa was not a separate civil proceeding that required a jury trial but a criminal penalty that was an integral part of the sentencing process holding that criminal defendant was not entitled to a jury trial on the issue of restitution under the oregon vehicle code holding civil restitution judgment that was originally imposed as part of a criminal sentence nondisehargeable holding that restitution under the vwpa was more akin to compensation for actual loss than a criminal penalty that may not bear interest