Martinson v. Michael (In Re Michael)

185 B.R. 830, 1995 Bankr. LEXIS 1546, 1995 WL 493084
United States Bankruptcy Court, D. Montana·Decided August 14, 1995·No. 19-60221·Published·Cited by 5 cases

Opinion

ORDER

JOHN L. PETERSON, Chief Judge.

In this Chapter 7 case and adversary proceeding the Trustee’s objection to the Debtors’ homestead exemption and complaint for turnover are once again before this Court on remand from the Ninth Circuit Court of Appeals to consider the issue of whether the Debtors can amend their Schedules post-petition under the Federal Rules of Bankruptcy Procedure to claim a homestead exemption. Michael v. Martinson, (In re Michael ), 49 F.3d 499, 502 (9th Cir.1995) (per curiam). 1 These matters have been under advisement since this Court denied approval of a compromise between the parties on June 15, 1995. In re Michael, 183 B.R. 230 (Bankr.D.Mont.1995). They are now ready for decision. 2 For the reasons set forth below, the Trustee’s objections are sustained, the Debtors’ claimed homestead exemption is disallowed, and the Debtors are ordered to turn over the real property to the Trustee.

There are no disputed material issues of fact in this case, and the facts are set forth *833 by the Ninth Circuit in Michael v. Martinson as follows:

When the Michaels filed their voluntary Chapter 7 bankruptcy petition, they had not yet recorded a Declaration of Homestead as required by Mont.Code Ann. §§ 70-82-105, 106, 107. They also faded to list their home as exempt property on their bankruptcy Schedule B-4. Several months later, after the bankruptcy court had ordered the Michaels’ debts discharged, they recorded a Declaration of Homestead in Yellowstone County and filed an amended Schedule B-4 with the bankruptcy court, listing their home as exempt property. The trustee objected to the amendment and brought this adversary proceeding to obtain possession of the home.

Michael v. Martinson, 49 F.3d at 500.

The Ninth Circuit specifically left open the question whether the Debtors could amend their Schedules under the Rules to claim the homestead exemption. Id. at 502.

The material facts are uneontroverted that the Debtors failed to record a Declaration of Homestead as required by Montana law to establish their right to a homestead exemption by the bankruptcy petition date. Mont.Code Ann. § 70-32-105, 106, 107; Michael, 49 F.3d at 500. Under Montana law on the petition date, then, the Debtors did not have a valid homestead exemption. In re Peterson, 106 B.R. 229, 231-32 (Bankr.D.Mont.1989) (construing §§ 70-32-105 through 107).

In fact, they did not assert a homestead exemption on the petition date or in their original Schedule B^t, filed February 15, 1991. Only after the § 341 meeting of creditors on March 14, 1991, and after Trustee filed the complaint in this adversary proceeding on November 26, 1991, and after the Trustee filed the objection to exemption on April 10, 1992, did the Debtors finally get around to filing an amended Schedule B-4 on May 14, 1992, asserting the homestead exemption more than a year alter the petition date. 3

In deciding whether the Debtors may amend their Schedules to claim a homestead exemption when no Declaration of Homestead was filed as of the petition date, the analysis must begin with the general rule that the “right to exemptions under the Bankruptcy Code, like the Bankruptcy Act, is generally determined by facts as they existed on the date bankruptcy was filed.” In re Gitts, 116 B.R. 174, 178 (9th Cir. BAP 1990), aff'd and adopted 927 F.2d 1109 (9th Cir.1991); In re Combs, 101 B.R. 609, 613-14 (9th Cir. BAP 1989); In re Magallanes, 96 B.R. 253, 255 (9th Cir. BAP 1988); Love v. Menick, 341 F.2d 680, 682 (9th Cir.1965). If this general rule is to apply, the Trustee’s objections to the Debtors’ homestead exemption must be sustained because the Debtors did not have a valid homestead exemption under Montana law on the petition date. The Court looks to state law, i.e., Montana homestead law to determine the estate’s interest in property such as the homestead. In re Campbell, 14 Mont. B.R. 132, 141 (9th Cir. BAP 1995).

Washington has an automatic homestead exemption by statute based upon possession alone. Gitts, 116 B.R. at 178, 180. That automatic homestead exemption, plus the fact the debtors’ original schedules claimed a homestead exemption, provided the basis in Gitts for the BAP to hold the debtors in that case had a valid homestead exemption on the petition date. Id. California law also provides for a non-declared or automatic homestead exemption by statute. Amiri v. Collection Bureau of San Jose (In re Amiri), 184 B.R. 60, 62-63 (9th Cir. BAP 1995). In contrast with California and Washington law, Montana has no automatic homestead exemption by possession alone. If there is not compliance with the recordation statutes, §§ 70-32-106 and 107, there is no valid homestead exemption. Harvey v. Havener, 135 Mont. 437, 443, 340 P.2d 1084, 1087 (1959) (“The spirit of all recordation acts is notice to protect others against secret equi *834 ties. If the record is not necessary to create the estate (as it is in the manner of homestead exemptions and mechanics’ hens) the statute providing for recording is but a direction to do certain acts and does not create conditions subsequent.”) (Emphasis added). Not having filed a Declaration of Homestead as of the petition date, under Montana law the Debtors did not have a valid homestead exemption on the petition date.

If there is an applicable exception to the general rule that the petition date controls whether there is a valid exemption, it is the Debtors’ burden to support such an exception. The Court finds no credible support in the record for such an exception. Debtors contend they have the right to file a Declaration of Homestead as a substantive right under Montana law allowing a valid homestead exemption to be filed up to the actual date of an execution sale, 4 citing Myers v. Matley, 318 U.S. 622, 63 S.Ct. 780, 87 L.Ed. 1043 (1943). See, Gitts, 116 B.R. at 179. To resolve this issue requires a background discussion of the procedure for claiming exemptions and amendments under both former and current bankruptcy law, and applicable Montana state law.

The Montana homestead exemption statutes which require recordation, §§ 70-32-105, 106, and 107 were enacted by the Montana legislature to give effect to the Montana Constitution, which provides that “[t]he legislature shall enact liberal homestead and exemption laws.” Mont. Const, art. XIII, § 5. Montana law allows a homestead declaration to be filed up to the actual day of an execution sale. Gitts, 116 B.R. at 179; Peterson, 106 B.R. at 232; In re Whidden, 1 Mont. B.R. 219, 232 (Bankr.Mont.1985).

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Martinson v. Michael (In Re Michael), 185 B.R. 830, 1995 Bankr. LEXIS 1546, 1995 WL 493084 (Mont. 1995).

185 B.R. 830 (Martinson v. Michael (In Re Michael)) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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