Jason Braswell of Morgan & Morgan in Athens, Georgia passed along is case of In re Carter , Case No. 3:07-CV-50, Ch. 13 Case No. 06-30846 (M.D. Ga.) (click here for .pdf), wherein Judge Land affirmed the Bankruptcy Court’s ruling that surrender of "910 vehicles" constitutes full satisfaction of the claim.
Update 2/19/08 – The Eighth Circuit Court of Appeals has held that the creditor retains the right to assert a deficiency claim.