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§ 522(b)(3)

In re Bingham

Ruling
Debtor who did not meet residency requirement could not claim state homestead exemption.
Procedural posture

The chapter 7 trustee filed an objection to the debtor's claim of a homestead exemption under Kansas law, asserting that the debtor had not been domiciled in Kansas for the 730 days (2 years) prior to her filing a bankruptcy petition.

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Consumer opinion summary, case decided on January 18, 2008 , LexisNexis #0208-115

In re Caudill

Ruling
Avoidance of lien as impairing debtor's homestead exemption granted where creditor's objection was untimely.
Procedural posture

Debtor, an individual who filed a chapter 7 case, moved for an order avoiding a judgment lien on her homestead that was asserted by claimant, a lienholder, who had objected to avoidance of the lien on the ground that the property was not an exempt homestead by reason of debtor's alleged abandonment thereof. At issue, inter alia, was whether the lien impaired debtor's exemptions under state law and 11 U.S.C. 522(b)(3).

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Consumer opinion summary, case decided on October 25, 2007 , LexisNexis #1107-113

In re Adams

Ruling
Debtors who formerly resided in Florida could not claim Florida homestead exemption in property located in another state where they now resided.
Procedural posture

Bankruptcy debtors claimed a Florida homestead exemption in property located in another state where the debtors now resided, asserting that Florida's exemption laws applied under 11 U.S.C. § 522(b)(3)(A) based on their prior residence in Florida. The trustee objected to the claimed exemption.

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Consumer opinion summary, case decided on September 11, 2007 , LexisNexis #1007-077

Drummond v. Urban (In re Urban)

Ruling
Debtor who recently moved could also claim exemptions of prior domicile state and was not required to make federal exemptions.
Procedural posture

Appellant, the chapter 13 trustee, challenged a final order of the Bankruptcy Court for the District of Montana, that rejected the trustee's challenge to the constitutionality of 11 U.S.C. § 522(b)(3) on uniformity grounds, and overruling the trustee's objection to the debtor's claimed exemptions based on California law, where the case was filed in Montana.

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Court :
Judge or Jurisdiction information not available
Consumer opinion summary, case decided on August 29, 2007 , LexisNexis #1007-112

Holland v. Safanda (In re Holland)

Ruling
Bankruptcy court erred in denying Illinois debtor's exemption in Florida property owned by the entirety with spouse.
Procedural posture

Debtor in a chapter 7 bankruptcy appealed from a final order of the bankruptcy court upholding the trustee's objection to an exemption the debtor claimed for real property in Florida.

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opinion summary, case decided on March 30, 2007 , LexisNexis #0507-042

In re Urban

Ruling
Bankruptcy Code exemption scheme did not violate uniformity requirements of the U.S. Consitution.
Procedural posture

Chapter 13 trustee filed a motion for a certification of unconstitutionality, claiming that 11 U.S.C. § 522(b)(3) violated the uniformity requirement found in U.S. Const. art. 1, § 8, Cl. 4.

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opinion summary, case decided on January 31, 2007 , LexisNexis #0307-008

In re Schwarz

Ruling
Property owned in tenancy by the entireties which was exempt from process under state law was also entitled to bankrupty exemption.
Procedural posture

A chapter 7 trustee filed an objection after a chapter 7 debtor claimed a homestead exemption in his Florida home, which he owned as a tenant by the entireties with his wife. The trustee argued that, pursuant to 11 U.S.C. § 522(b)(3)(A), Maryland law, rather than Florida law, determined the homestead exemption that the debtor could claim and that he could not claim a homestead exemption under Maryland law.

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opinion summary, case decided on January 26, 2007 , LexisNexis #0307-043

Zebley v. Davis (In re Davis)

Ruling
Property owned by the enirety on petition date could be exempted despite pending divorce and equitable distribution.
Procedural posture

The chapter 7 trustee objected to the debtor's claimed exemption of residential realty. The basis for the trustee's exemption objection was that, as of the date of the debtor's bankruptcy petition filing, a divorce action was pending between the debtor and his wife, and that the filing of such divorce action, according to the trustee, immediately terminated the tenancy by the entirety.

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opinion summary, case decided on November 27, 2006 , LexisNexis #0107-048

In re Jewell

Ruling
Debtors were not entitled to exemptions in state of former residence where law required debtors reside in that state at time of filing.
Procedural posture

Before the court in a chapter 7 matter was the Chapter 7 Trustee's Objection to the allowance of debtors'claimed exemptions.

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opinion summary, case decided on August 08, 2006 , LexisNexis #0906-003

In re Underwood

Ruling
Debtor could only claim federal exemptions since debtor could only claim state exemptions for a state of residence for which debtor had resided two or more years prior to filing.
Procedural posture

The case came on for hearing on the chapter 7 trustee's objection to debtor's claimed exemptions.

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opinion summary, case decided on May 24, 2006 , LexisNexis #0606-044