In a recent case decided by the 9th circuit (In re Defrantz), the court ruled that the debtor has an absolute right to convert his chapter 13 case to a chapter 7 case. The creditor argued that the court should have considered the creditor’s motion to dismiss before converting the case and that the right to convert was not absolute. However, the court stated the plain language of section 1307(a) of the bankruptcy code allowed conversion.