In Re Lillard

38 B.R. 433, 1984 Bankr. LEXIS 6108
CourtUnited States Bankruptcy Court, W.D. Arkansas
DecidedMarch 12, 1984
DocketBankruptcy FA 83-29F
StatusPublished
Cited by5 cases

This text of 38 B.R. 433 (In Re Lillard) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, W.D. Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re Lillard, 38 B.R. 433, 1984 Bankr. LEXIS 6108 (Ark. 1984).

Opinion

ORDER SUSTAINING CREDITOR’S OBJECTION TO CONFIRMATION OF CHAPTER 13 PLAN

ROBERT F. FUSSELL, Bankruptcy Judge.

Pending before the court is an objection to the confirmation of the debtors’ joint Chapter 13 plan of arrangement filed by Westark Production Credit Association *434 (hereinafter “Westark”). The matter came on for hearing September 6, 1983. The following relevant facts are not disputed.

The debtors, Charles and Beverly Lillard, propose pursuant to their Chapter 13 plan to retain possession of a Datsun 310X automobile titled to “Charles or Beverly Lil-lard”, the admitted value of which is $2900.00. The plan reveals that both debtors have claimed state exemptions, among which is a $1200.00 per debtor exemption in this automobile. They propose to apply these exemptions against the ear’s $2900.00 value and pay Westark the $500.00 difference over the life of the plan. 1 Westark *435 has a nonpossessory nonpurchase money security interest in the vehicle. The debtors owe Westark more than $19,000 and the Datsun automobile is the only remaining security originally pledged against the indebtedness. The debtors owned the car prior to granting Westark a security interest, and it was but one of many items of collateral taken as security when Westark refinanced a loan on real property for the debtors. All other collateral has been returned to this creditor including a house and acreage and a pickup truck. The plan also calls for payment of $1,518.00 over the life of the plan to Westark as partial payment of the unsecured portion of its claim.

Westark asserts that the debtors should be required to relinquish the security or pay out the full $2,900.00 value of the collateral over the term of the plan. The creditor specifically argues that since the outstanding indebtedness exceeds the value of the car there is no equity to which the debtors’ exemptions may attach and hence the automobile exemption is unavailable to them. Westark also contends that valid liens are preserved despite the claimed exemption by the debtors unless the lien can be avoided. They assert that the debtors have filed no motion to avoid Westark’s valid lien and, even if such motion had been properly filed, the creditor contends that the subject lien is not one which may be avoided.

The debtors do not challenge the validity of Westark’s lien nor have they filed a motion to avoid the lien but argue instead that they should be allowed to claim exemptions in the automobile even though they have no equity therein. They contend no equity is necessary because, pursuant to Arkansas’ exemption statute, their “interest” in the first $1200.00 (or $2,400.00 for both) of value of the automobile is exempt from Westark’s nonpurchase money security interest. They thus assert that their plan can be confirmed as proposed.

Upon a review of all the files and pleadings in this Chapter 13 proceeding as well as the briefs submitted by both parties the court concludes that Westark’s objection to confirmation of the debtors’ proposed Chapter 13 plan must be sustained. The court uniquely is not agreeing per se with the primary arguments of either side as set out above but relies on the plain language of the Bankruptcy Code in reaching its conclusion.

In the Bankruptcy Reform Act of 1978, Congress made a fundamental change in the approach to exempt property by providing that it first passes into the bankruptcy estate and then is exempted from it. Section 522(b) of the Bankruptcy Code authorizes an individual debtor to “exempt from property of the estate” either property specified in the new federal bankruptcy exemption list (11 U.S.C. Section 522(d)) or property exempt from execution under non-bankruptcy law. 2 The provision in the old *437 Act under Section 70(a) specifically excepting exempt property from the estate has been deleted, so that the estate is now compromised of “all legal or equitable interests of the debtor in property as of the commencement of the case.” 11 U.S.C. Section 541(a)(1). The committee report's of • both Houses of Congress specifically point out:

Paragraph (1) [of 11 U.S.C. 541(a)] has the effect of overruling Lockwood v. Exchange Bank, 190 U.S. 294 [23 S.Ct. 751, 47 L.Ed. 1061] (1903), because it includes as property of the estate all property of the debtor, even that needed for afresh start. After the property comes into the estate, then the debtor is permitted to exempt it under proposed 11 U.S.C. 522, and the court will have jurisdiction to determine what property may be exempted and what remains as property of the estate, [emphasis added]

S.Rep. No. 95-989, 95th Cong. 2d Sess. 82 (1978), U.S.Code Cong. & Admin.News 1978, pp. 5787, 5868; H.Rep. No. 95-595, 95th Cong. 1st Sess. 368 (1977), U.S.Code Cong. & Admin.News 1978, pp. 5787, 6324. Thus, Section 541 takes every possible “interest” of the debtor under consideration when the estate is created, but Section *438 522(b) 3 qualifies and limits that section by permitting the debtor to exempt certain property from the reach of Section 541.

The next step then is for the debtor to claim his exemptions. The Code provides that he may choose the exemptions under the Code listed in Section 522(d) unless the state wherein he resides has chosen to enumerate its own exemptions by specifically forbidding the use of the federal exemptions. Arkansas chose to “opt out” of the federal exemptions provided in 11 U.S.C. Section 522(d) by providing that an individual debtor who is a resident of the state of Arkansas is prohibited from using the federal exemptions provided in Section 522(d), the applicable exemptions to be only those permitted by the Constitution and laws of the State of Arkansas. Acts 1981, No. 419, Sec. 1, p. 743 See, Ark.Stat.Ann. Section 36-210 et seq., and Article 9, Section 1, Arkansas Constitution. 4

Thus, under the new Code, the debtor may look to a specified list of possible exemptions and enumerate those he wishes to claim. Provisions of the Bankruptcy Code, however, also now require that a more careful analysis of the claimed exemptions be made where that “exemption” is encumbered. Ordinarily liens survive the bankruptcy, however Section 522(f) of the Code specifically permits a debtor to avoid judicial liens and certain nonpossesso-ry, nonpurchase money security interests in certain types of exempt property notwithstanding any waiver of exemptions.

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Bluebook (online)
38 B.R. 433, 1984 Bankr. LEXIS 6108, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-lillard-arwb-1984.