Yes.
As reported by Robin Miller of CBAR, agreeing with In re Frambes, 454 B.R. 437 (Bankr. E.D. Ky. 2011) and disagreeing with Motichko v. Premium Asset Recovery Corp., 395 B.R. 25, 29 (Bankr. N.D. Ohio 2008), the court in In re Stevens, 2011 WL 6812807 (Bankr. E.D. Tenn., Dec. 28, 2011)held that an action for contempt, based on a violation of the discharge injunction, must be prosecuted by filing a motion in the debtor’s main bankruptcy case, not by filing an adversary proceeding.
In re Moore, 521 B.R. 280 (Bankr. E.D. Tenn., Sept. 29, 2014)
(case no. 1:13-bk-11325; adv. proc. no. 1:14-ap-1011) (Bankruptcy Judge Shelly D. Rucker)