There is an 11th Circuit case specifically on point and I'll try to find it (again). It was specifically where the creditor refused to release the title, unless the person PAID the creditor. While the creditor didn't try to "collect" the loan, they nonetheless were enforcing a debt by refusing to come and get the property or surrendering the title.

It is true that just not giving you the title is one thing. The other is that they "conditioned" the release of the title with "paying" the underlying debt, after their refusal to repossess the collateral. That's akin to blackmail. There's is a subtle difference but it's distinguishable. There's a difference between not giving someone the title, and holding the title hostage, saying you'll neither come to repossess the vehicle nor release the title.

There is one strategy where if they refuse to release the lien (title) and wont' come and get the collateral, that your attorney re-open the case and file a Motion to Redeem. In the Redemption Motion you offer something stupid like $100. You serve this on negative notice (or judicial notice) and hope they don't respond. Then you just redeem it and have a court order forcing (compelling them) to quiet the title.

Here's the Case... In Re Pratt, Pratt v GMAC. This went all the way to the 1st Circuit Court of appeal. And although this was in Massachusetts, the ruling also talked about State non-bankruptcy law remedies, but found that GMAC's refusal to come get the car because it wasn't worth it, made their statement that they'll only release the lien if the debtor "paid in full", to be coercive.

While Pratt isn't controlling (precedence) in the 11th Circuit, it is certainly