Debtors sought sanctions from a worker's compensation insurer for violating the automatic stay provisions of 11 U.S.C. § 362. Insurer was paying benefits to debtor husband when the bankruptcy petition was filed. Prior to the filing, insurer had determined that it had overpaid some of debtor's previous benefits, and thereafter began deducting set amounts from debtor's benefit payments in order to recoup the overpayments. Although insurer received actual notice of debtors' bankruptcy filing, it continued to reduce the benefit payments post-petition, and the parties stipulated that insurer had deducted a total of $1,300 from debtor's post-petition benefit payments. In defense of the stay violation claim, insurer asserted the doctrine of "recoupment." Although § 362(a)(7) prohibits setoff of a prepetition debt owed to the debtor against a claim against the debtor, the equitable doctrine of recoupment allows a creditor to make such an offset when both the creditor's and the debtor's claims arose from the same transaction. The court determined that the automatic stay does not prohibit such recoupment in this jurisdiction. Adopting the view that the "same transaction" prong of recoupment was controlled, in the case before it, by the source of the injury, the court found that insurer had proven that both its claim and debtor's arose from the same transaction. However, the court concluded that the recoupment doctrine was not applicable because a right to recoupment must be created by contract, and there were no contracts between insurer and debtor. The court granted debtors' motion, and awarded them their actual damages based on insurer's willful violation of the stay.