In re: Brittany Nicole Williams v. Timothy R. Kurtz, solely in his capacity as Chapter 7 Trustee of the bankruptcy estate of the above-referenced Debtor

CourtUnited States Bankruptcy Court, D. Idaho
DecidedMarch 13, 2026
Docket25-00264
StatusUnknown

This text of In re: Brittany Nicole Williams v. Timothy R. Kurtz, solely in his capacity as Chapter 7 Trustee of the bankruptcy estate of the above-referenced Debtor (In re: Brittany Nicole Williams v. Timothy R. Kurtz, solely in his capacity as Chapter 7 Trustee of the bankruptcy estate of the above-referenced Debtor) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, D. Idaho primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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In re: Brittany Nicole Williams v. Timothy R. Kurtz, solely in his capacity as Chapter 7 Trustee of the bankruptcy estate of the above-referenced Debtor, (Idaho 2026).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO

In re:

BRITANNY NICOLE WILLIAMS, Case No. 1:25-cv-00549-BLW Debtor. MEMORANDUM DECISION ________________________________

TIMOTHY R. KURTZ, solely in his capacity as Chapter 7 Trustee of the bankruptcy estate of the above- referenced Debtor,

Appellant, v. BRITTANY NICOLE WILLIAMS, Appellee.

INTRODUCTION Chapter 7 Trustee Timothy R. Kurtz appeals the bankruptcy court’s order overruling his objection to Debtor Brittany Nicole Williams’s exemption in her 2020 Kia Sorento. The issue on appeal is narrow: May Ms. Williams claim Idaho’s motor-vehicle exemption in the Sorento—even though it was unregistered on the petition date? The Court concludes that she may and will therefore affirm. BACKGROUND Ms. Williams filed a Chapter 7 bankruptcy petition on April 16, 2025. On Schedule C, she claimed a $10,000 exemption in a 2020 Kia Sorento pursuant to Idaho Code § 11-605(3). The Sorento was unregistered on the petition date. The bankruptcy court overruled the Trustee’s objection to the exemption. This appeal

ensued. STANDARD OF REVIEW District courts review bankruptcy court decisions in the same manner as would the Ninth Circuit. See, e.g., In re George, 177 F.3d 885, 887 (9th Cir.

1999). In this case, the Court considers a question of statutory interpretation— namely whether an unregistered vehicle may qualify as a “motor vehicle” for purposes of Idaho Code § 11-605(3). That question is a legal one, subject to de

novo review. See generally Jones v. U.S. Trustee, 736 F.3d 897, 899 (9th Cir. 2013). ANALYSIS When a debtor files a bankruptcy petition, a bankruptcy estate is

automatically created, which includes all of the debtor’s legal and equitable property interests. 11 U.S.C. § 541(a). The estate property is available for distribution to creditors, Rousey v. Jacoway, 544 U.S. 320, 325 (2005), though

there are exceptions. One such exception is the debtor’s ability to exempt certain property from the estate, such as a car or a home, up to certain values. Id.; 11 U.S.C. § 522(d). The general idea behind exemptions is to promote the debtors’ ability to make a fresh financial start. Idaho has opted out of the federal exemptions, so Idaho’s exemption laws are applicable in this case. See Idaho Code § 11-609. If the trustee objects to a

claimed exemption, he bears the burden of proving the exemption is improper. See Fed. R. Bank. P. 4003(c). In shouldering that burden, the trustee must of course be cognizant of the fact that exemption statutes are to be liberally construed in the

debtor’s favor. See Tober v. Lang (In re Tober), 688 F.3d 1160, 1163 (9th Cir. 2012). Here, Debtor Brittany Williams claimed an exemption in her 2020 Kia Sorento pursuant to Idaho Code § 11-605(3). That statute—codified in Title 11 of

the Idaho Code—provides that “[a]n individual is entitled to exemption . . . of one (1) motor vehicle to the extent of a value not exceeding ten thousand dollars ($10,000).” Idaho Code § 11-605(3). Because the term “motor vehicle” is not

defined in Title 11 of the Idaho Code, bankruptcy courts in this district have looked to definitions contained in Title 49. There, a “motor vehicle” is defined as follows: Motor Vehicle. Every vehicle that is self-propelled, and for the purpose of titling and registration meets federal motor vehicle safety standards as defined in section 49-107, Idaho Code. Motor vehicle does not include vehicles moved solely by human power, electric personal assistive mobility devices, personal delivery devices, electric-assisted bicycles, and motorized wheelchairs or other such vehicles that are specifically exempt from titling or registration requirements under title 49, Idaho Code.

Idaho Code § 49-123(2)(h). A “vehicle,” in turn, is defined as “[e]very device in, upon, or by which any person or property is or may be transported or drawn upon a highway, excepting devices used exclusively upon stationary rails or tracks.” Idaho Code § 49-123(2)(a).

Neither definition requires a vehicle to be registered to qualify as a vehicle or motor vehicle. The definition of a “motor vehicle” does exclude certain vehicles or devices from the definition—including, for example, electric bicycles and

motorized wheelchairs or “other such vehicles that are specifically exempt from titling or registration requirements.” § 49-123(2)(h). But that exclusion certainly doesn’t mean that vehicles that are subject to registration requirements, but not actually registered, fail to qualify as “motor vehicles.”

And the broader definition of a “vehicle” doesn’t say anything at all about registration. See Idaho Code § 49-123(2)(a). The definition of a “vehicle” includes (with exceptions not relevant here) devices that are capable of transporting people

and things upon a highway. Notably, the legislature did not say it was actually referring to two separate capabilities: (1) a device’s physical ability to transport people and things along the highway; and (2) a device’s ability to travel along the highway lawfully (i.e., by having complied with registration requirements).

In this case, the Debtor’s Kia Sorento easily satisfies the relevant statutory definitions in Title 49. And the exemption statute in Title 11 (Idaho Code § 11- 605(3)) says only that debtors may exempt a “motor vehicle.” It does not say that

debtors may exempt a “registered motor vehicle.” Had the Idaho Legislature wished to condition the exemption on current registration status, it could have said so. It did not.

The Court’s interpretation of the definitional statutes in Title 49 of the Idaho Code is reinforced by Idaho appellate authority. As the bankruptcy court correctly noted, the Idaho Supreme Court has not addressed this precise question. But two

relatively recent Idaho Court of Appeals decisions have, and both hold that a motor vehicle is any self-propelled vehicle, regardless of registration status. See State v. Trusdall, 318 P.3d 955, 959-60 (Idaho Ct. App. 2014); State v. McKie, 417 P.3d 1001, 1005-06 (Idaho Ct. App. 2018).

In the first of these decisions, State v. Trusdall, 318 P.3d 955 (Idaho Ct. App.

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Related

Rousey v. Jacoway
544 U.S. 320 (Supreme Court, 2005)
Tober v. Lang (In Re Tober)
688 F.3d 1160 (Ninth Circuit, 2012)
Ryman v. Sears, Roebuck and Co.
505 F.3d 993 (Ninth Circuit, 2007)
Jerry Jones v. US Trustee, Eugene
736 F.3d 897 (Ninth Circuit, 2013)
State v. Rhonda Trusdall
318 P.3d 955 (Idaho Court of Appeals, 2014)
State v. McKie
417 P.3d 1001 (Idaho Court of Appeals, 2018)

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In re: Brittany Nicole Williams v. Timothy R. Kurtz, solely in his capacity as Chapter 7 Trustee of the bankruptcy estate of the above-referenced Debtor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-brittany-nicole-williams-v-timothy-r-kurtz-solely-in-his-capacity-idb-2026.