In Re Flitter

181 B.R. 938, 1995 Bankr. LEXIS 657
CourtUnited States Bankruptcy Court, D. Minnesota
DecidedApril 25, 1995
Docket14-30047
StatusPublished
Cited by10 cases

This text of 181 B.R. 938 (In Re Flitter) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, D. Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re Flitter, 181 B.R. 938, 1995 Bankr. LEXIS 657 (Minn. 1995).

Opinion

ORDER GRANTING DEBTORS’ MOTION FOR LIEN AVOIDANCE, IN PART, AND OVERRULING TRUSTEE’S OBJECTION TO DEBTORS’ CLAIM OF EXEMPTION, IN PART

GREGORY F. KISHEL, Bankruptcy Judge.

This Chapter 7 case came on before the Court for hearing on the Debtors’ motion for hen avoidance. The Debtors appeared personally and by their attorney, Perry A. Berg. Chapter 7 Trustee Mark C. Halverson appeared for the bankruptcy estate. Upon the moving and responsive documents, the record made at the hearing, and the post-hearing memoranda submitted by counsel, the Court makes the following order.

The Debtors filed a voluntary petition under Chapter 7 on January 10, 1994. They are engaged in farming in Waseca County, Minnesota. On their Schedule B, they in- *940 eluded entries for livestock 1 of a total value of $5,175.00, and farming equipment 2 of a total value of $6,395.00. On their Schedule D, for creditors holding secured claims, they included an entry for Vern and Irma Flitter, of Pemberton, Minnesota. 3 They stated the amount of those persons’ secured claim as $3,000.00 and identified the collateral as “MACHINERY” and “TRACTOR AND SKID LOADER.” On their Schedule C, the Debtors claimed exemptions for all of their livestock and farming equipment, citing Minn.Stat. § 550.37 subd. 5 4 as their authority.

On March 24, 1994, the Trustee of their bankruptcy estate filed a paper entitled “Notice and Objection to Claimed Exempt Property.” In it, he objected to the Debtors’ claim of exemption in, inter alia, their equipment and livestock, on the following ground:

The trustee’s preliminary investigation reveals that these items may be subject to an unperfected security interest voidable by the trustee, in which case the debtors cannot exempt the items that they recovered by the trustee and are subject to a voluntary transfer — as would be the case with the grant of a security agreement [sic].

Contrary to the requirements of Loc. R.BankR.P. (D.Minn.) 702 and 1202 and Local Form 1202, the Trustee did not give notice of a hearing on this objection. He has not yet done so.

On July 7, 1994, the Debtors filed the motion at bar. In its text, they averred that the elder Flitters claim a security interest against the Debtors’ livestock, machinery, equipment, and all crops, under color of a security agreement and accompanying UCC-1 financing statement filed on September 1, 1989. Asserting that the existence of this security interest impairs any allowable claim of exemption in those items to which they would entitled, they request that it be avoided pursuant to 11 U.S.C. § 522(f)(2)(B). 5

Though he is not a named party-respondent to this motion, the Trustee has filed an objection to it. He asserts that the Debtors’ hypothetical equity interest in the elder Flit-ters’ collateral is not subject to exemption in this case, and therefore cannot be recovered by the Debtors via a remedy that is dependent on exemptibility like § 522(f) is. He bases his argument on a sequence of four propositions:

1. The Debtors voluntarily granted the security interest to the elder Flitters.
2. The elder Flitters’ security interest is presently unperfeeted and hence is subject to avoidance or subordination at his instance pursuant to 11 U.S.C. § 544(a). 6
*941 3. Were he to take his avoidance remedies, the Debtors could not use 11 U.S.C. § 522(g) to claim an exemption for the value in the collateral that he would have recovered.
4. Because in such an instance the Debtors would not be able to claim any recovered value as exempt, they should not be allowed to “prejudice” the estate’s avoidance powers by exercising their own remedy before he does.

As framed by the pleadings for this motion, then, the issue is an interesting one: as between a debtor’s right of lien avoidance under § 522(f)(2) and a trustee’s avoidance and recovery powers under 11 U.S.C. §§ 544, 550, and 551, which one trumps? There is very little published caselaw that addresses this question, even in passing.

Ultimately, the Trustee’s argument is flawed by its failure to recognize a nuance inherent in the very structure of § 522(g). He is correct in the first several premises of his argument: if the elder Flitters’ lien was not perfected as of the commencement of this ease, the Trustee could have exercised his strong-arm powers against the liens. Then, had he been successful, 11 U.S.C. § 551 would have preserved the Debtors’ original transfer for the benefit of the estate, 7 and 11 U.S.C. § 550(a) 8 would have enabled him to recover the full unencumbered ownership in the subject assets from the elder Flitters.

After that, however, it gets a bit more complicated than the Trustee acknowledges.

11 U.S.C. § 522(g) gives debtors a right to reclaim such recovered property back from the estate in certain cases. 9 Congress afforded this right to give debtors an enhanced benefit from statutory exemption rights. H.R.REP. No. 595, 95th Cong. 1st Sess. 362-363 (1977); S.REP. No. 989, 95th Cong., 2d Sess. 76-77 (1978), U.S.Code Cong. & Admin.News 1978, pp. 5787, 5861-5863, 6317-6319. As the Trustee points out, § 522(g) imposes one significant limitation on this right, by negative implication: where in the first place a debtor voluntarily parted with the value that the trustee has recovered — as, for example, by a consensual grant of security interest — he cannot meet the requirement of § 522(g)(1)(A), and cannot use § 522(g)(1) as the basis for his claim of exemption. However, § 522(g)(2) opens the debtor’s right back out again, for the classes of assets that are subject to a debtor’s lien avoidance powers under § 522(f). In re Hollinsed, 54 B.R. 155, 156 (Bankr.W.D.Wis.1984); In re Dipalma, 24 B.R. 385, 387-88 (Bankr.D.Mass.1982). For this source of secondary exemption rights, it is irrelevant

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Cite This Page — Counsel Stack

Bluebook (online)
181 B.R. 938, 1995 Bankr. LEXIS 657, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-flitter-mnb-1995.