Task: Text Completion
Input (English): court order was in violation of the stay because, as the courts below concluded, it ordered Johnston to pay arrears or go to jail without focusing on Johnston’s non-estate property. See Johnston II, 321 B.R. at 275-80; Johnston I, 308 B.R. at 478, 480; see also 11 U.S.C. § 362. Sternberg recognized this but did not say anything to the appellate court because he did not think it was his duty “to practice law on [Johnston’s] behalf.” That did not, however, authorize him to act in violation of the automatic stay. To comply with his “affirmative duty” under the automatic stay, Sternberg needed to do what he could to relieve the violation. He could not simply rely on the normal adversarial process. See Johnston Envtl. Corp. v. Knight (In re Goodman), 991 F.2d 613, 615-16 (9th Cir.1993) (<HOLDING>). At a minimum, he had an obligation to alert 
 Holding statements: (A) holding rule 11 sanction proceeding was exempt from automatic stay (B) holding that the protections of the automatic stay apply only to actions against the debtor (C) holding that although the automatic stay only applies to proceedings against the debtor  counterclaims seeking affirmative relief against a debtor implicate the automatic stay (D) 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 (E) holding that parties who attempted to exempt a debtor from their unlawful detainer action with a unilateral stipulation still violated the automatic stay because the stipulation might not have accompished its intended purpose and thus the parties could have and should have pursued the orthodox remedy relief from the automatic stay
Output (English): (E)