n 2015 the United States Supreme Court ruled in the case of Harris v. Viegelahn that undistributed funds held by a trustee on the date that a debtor converts from a Chapter 13 to a Chapter 7 belong to the debtor. The debtor, Mr. Harris filed for a Chapter 13 and began making payments into the plan. He was also making regular mortgage payments outside of the plan but fell behind and was foreclosed on. He still kept making his plan payments. About a year later he converted to Chapter 7 and had about $5,500 in undistributed funds. The trustee distributed the money to the creditors and Mr. Harris sued to get his money back. The Court held that the undistributed funds belong to the debtor.
