She contends that the First Circuit’s discussion of 11 U.S.C. § 362, was not essential to its hold ing and, therefore, is non-binding dicta. Indeed, she asserts there is cause to distinguish the two because 11 U.S.C. § 362(k)(l) expressly provides for the recovery of “actual damages,” which, based upon the First Circuit’s decision in Fleet Mortgage Group, Inc. v. Kaneb, 196 F.3d at 269, includes damages for emotional distress. Moreover, while admitting that the law governing the recoverability of emotional distress damages for violations of the automatic stay and discharge injunction is unsettled, the Debtor cites a number of cases that she believes indicate a trend towards allowing such damages against the federal government. See, e.g., In re Griffin, 415 B.R. 64 (Bankr.N.D.N.Y.2009) (<HOLDING>); Atkins v. United States (In re Atkins), 279
holding in wrongful pregnancy suit that expenses of raising and educating child were not recoverable elements of damages but emotional distress was recoverable element holding that the plaintiff had standing even though automatic stay had terminated and his claims for declaratory and injunctive relief were moot because he also sought actual damages for violation of the automatic stay holding that emotional distress damages are not recoverable under section 504 holding judgment in violation of automatic stay void holding emotional distress damages for a willful violation of the automatic stay were recoverable against the social security administration