See, e.g., In re Grant, 29 B.R. 375, 376 (Bankr. M.D. Pa. 1983) (denying stay relief and finding secured creditor was adequately protected where the debtor's equity exceeded the secured claim by approximately $27,000). U.S. Bank's Brief, at §III.
However, if an equity cushion exists in the property such may be sufficient to constitute adequate protection for the secured creditor. In re Schockley Forest, 5 B.R. 160, 2 C.B.C.2d 756 (Bankr.N.D.Ga., 1980); In re Grant, 29 B.R. 375, 8 C.B.C.2d 982 (Bankr.M.D.Pa. 1983). Here, the equity cushion is relatively small ($36,000) which in percentage terms is less than 5%.