Aguina Aguina

CourtUnited States Bankruptcy Court, C.D. California
DecidedJanuary 11, 2021
Docket6:17-bk-17472
StatusUnknown

This text of Aguina Aguina (Aguina Aguina) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Aguina Aguina, (Cal. 2021).

Opinion

3 FILED & ENTERED

4 JAN 11 2021 5

6 CLERK U.S. BANKRUPTCY COURT Central District of California BY g o o c h DEPUTY CLERK 7

8 UNITED STATES BANKRUPTCY COURT

9 CENTRAL DISTRICT OF CALIFORNIA

10 RIVERSIDE DIVISION

12 In re: Case No.: 6:17-bk-17472-WJ

13 AGUINA AGUINA, CHAPTER 7

14 Debtor. MEMORANDUM OF DECISION 15 REGARDING AN OBJECTION TO EXEMPTIONS AND OTHER MATTERS 16

17 Hearings: Date: January 12, 2021 18 Time: 1:30 p.m. Crtrm.: 304 19 20 21 22 23 24 25 26 27 28 2 at 1:30 p.m. However, having reviewed the case, the moving papers, the responses and other 3 relevant pleadings, the Court hereby finds that no oral argument regarding the matters is necessary 4 and, pursuant to Rule 9013-1(j)(3) of the Local Bankruptcy Rules, the Court hereby takes off 5 calendar the hearings and waives appearances. No hearings shall occur. 6 7 I. The Objection To Exemptions 8 Prior to filing his bankruptcy case, the debtor, Aguina Aguina (“Debtor”) was married to 9 Choong-Dae Kang a/k/a Mitsuyo Okamoto, a.k.a. KC Kang (“Kang”). Prior to filing his 10 bankruptcy case, they divorced. However, the divorce proceeding remains pending in state court 11 and has been continuing for many, many years. It is acrimonious. 12 After filing his bankruptcy case in 2017, the Debtor filed amended schedules on October 6, 13 2020 which (among other things) included an amended schedule C which asserted a new set of 14 exemptions. See Docket #231. Thereafter, on November 6, 2020, Kang filed a motion objecting to 15 the amended exemptions entitled “Motion Objecting To Amended Exemptions” [docket #238] 16 (“Exemption Objection”) along with supporting documents. See Docket #239 & 240. The Debtor 17 filed opposition to the Exemption Objection [docket #252] and Kang filed a reply [docket #260]. 18 Having reviewed all the pleadings, the Court shall deny the Exemption Objection for three 19 reasons. First, the Debtor has argued that the Exemption Objection is clearly untimely, and the 20 Court agrees. As set forth in the opposition of the Debtor, Kang did not file the Exemption 21 Objection by the deadline of November 5, 2020. Kang filed the Exemption Objection a day late on 22 November 6, 2020 and, therefore, the objection is untimely and must be denied on that basis alone. 23 This Court is bound by the decision of the United States Supreme Court which is directly on point: 24 Taylor v. Freeland & Kronz, 503 U.S. 638, 644; 112 S.Ct. 1644, 1648 (1992).1 25

26 1 Kang’s reply brief [docket #260] entirely ignores the discussion by the Debtor in his opposition brief regarding the Supreme Court decision in Taylor. Kang’s reply brief only mentions the timeliness objection in one 27 sentence and does not attempt to respond to the significant issues raised in the Debtor’s opposition regarding Taylor and the applicable rules. Simply stated, the reply brief by Kang does not contain any bona fide attempt to refute the 28 timeliness argument raised by the Debtor. 2 Kang does not argue that Kang was not properly served. Instead, Kang argues that other 3 (unspecified) creditors were improperly served. As to Kang, because Kang does not argue that 4 Kang was not properly served, there is no prejudice. As to other creditors, the Court order denying 5 the Exemption Objection will provide that the ruling is binding on Kang but not on any other 6 creditors who were not properly served with amended schedules (if any). 7 Finally, the Court denies the Exemption Objection on the merits based (again) on a decision 8 of the United States Supreme Court. Kang argues that the Debtor cannot switch his exemptions 9 later in a bankruptcy case based on equitable grounds (i.e. estoppel). However, this argument fails 10 for three reasons. First, the trustee has not raised it and (in the first instance) the trustee would be 11 prejudiced by the hypothetical turnover request argued by Kang. 12 Second, even if the bankruptcy estate is prejudiced by the switch in exemptions, the 13 prejudice is no different than the normal prejudice that exists in every bankruptcy case and with 14 every exemption. Every exemption prejudices creditors. An exemption, by its very nature, 15 allows a debtor to keep an asset (in whole or in part) to the detriment of creditors. It is an inherent 16 feature of all exemptions. The entire point of an exemption is to deprive creditors of an asset from 17 which they can be satisfied. An exemption is designed to be prejudicial against creditors. Its very 18 existence is prejudicial to creditors. 19 So Kang’s prejudice argument lacks weight. If an exemption is otherwise valid, the fact 20 that it may result in loss to the estate is not additional prejudice. Rather, it is the normal prejudice 21 that is a common (and accepted) feature of all valid exemptions asserted in bankruptcy cases. 22 Third, on the merits, Kang’s argument cannot be reconciled with the decision of the United 23 States Supreme Court in Law v. Siegel, 571 U.S. 415 (2014). Prior to that case, some bankruptcy 24 courts had ruled that a debtor cannot exempt an asset which the debtor conceals. If a debtor filed a 25 bankruptcy case and concealed an asset, some bankruptcy courts disallowed any exemption later 26 asserted by a debtor if the trustee later found the hidden asset. Some courts held that they had 27 equitable power to disallow the exemption asserted later with respect to concealed assets. 28 2

3 Siegel points out that a handful of courts have claimed authority to disallow an exemption (or to bar a debtor from amending his schedules to claim an 4 exemption, which is much the same thing) based on the debtor’s fraudulent concealment of the asset alleged to be exempt. See, e.g., In re Yonikus, 996 F.2d 5 866, 872–873 (C.A.7 1993); In re Doan, 672 F.2d 831, 833 (C.A.11 1982) (per curiam ); Stewart v. Ganey, 116 F.2d 1010, 1011 (C.A.5 1940). He suggests that 6 those decisions reflect a general, equitable power in bankruptcy courts to deny 7 exemptions based on a debtor’s bad-faith conduct. For the reasons we have given, the Bankruptcy Code admits no such power. It is of course true that when a 8 debtor claims a state-created exemption, the exemption’s scope is determined by state law, which may provide that certain types of debtor misconduct warrant 9 denial of the exemption. E.g., In re Sholdan, 217 F.3d 1006, 1008 (C.A.8 2000); see 4 Collier on Bankruptcy ¶ 522.08[1]–[2], at 522–45 to 522–47. Some of the 10 early decisions on which Siegel relies, and which the Fifth Circuit cited in Stewart, 11 are instances in which federal courts applied state law to disallow state-created exemptions. See In re Denson, 195 F. 857, 858 (N.D.Ala.1912); Cowan v. 12 Burchfield, 180 F. 614, 619 (N.D.Ala.1910); In re Ansley Bros., 153 F. 983, 984 (E.D.N.C.1907). But federal law provides no authority for bankruptcy courts to 13 deny an exemption on a ground not specified in the Code.

14 Law v. Siegel, 571 U.S. at 425 (emphasis added). 15

16 As a result, based on Law, it is clear that bankruptcy courts lack equitable power to 17 disallow an exemption asserted by a debtor later in a bankruptcy case on an asset that was 18 originally concealed. A fortiori, the bankruptcy court lacks power to disallow an exemption 19 asserted by a debtor later in a case in which the asset was always disclosed. 20 In this case, the Debtor disclosed the exempt asset from the beginning of the case but did 21 not originally exempt it. Later, he decided to exempt it.

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Related

Taylor v. Freeland & Kronz
503 U.S. 638 (Supreme Court, 1992)
Odessa Nunnally v. Charles MacCausland
996 F.2d 1 (First Circuit, 1993)
In Re Sholdan
217 F.3d 1006 (Eighth Circuit, 2000)
Stewart v. Ganey
116 F.2d 1010 (Fifth Circuit, 1940)
Law v. Siegel
134 S. Ct. 1188 (Supreme Court, 2014)
In re Ansley Bros.
153 F. 983 (E.D. North Carolina, 1907)
Cowan v. Burchfield
180 F. 614 (N.D. Alabama, 1910)
In re Denson
195 F. 857 (N.D. Alabama, 1912)

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