Satinder Singh

CourtUnited States Bankruptcy Court, E.D. California
DecidedJanuary 3, 2024
Docket23-22540
StatusUnknown

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

Bluebook
Satinder Singh, (Cal. 2024).

Opinion

1 2 FOR PUBLICATION 3 4 UNITED STATES BANKRUPTCY COURT 5 EASTERN DISTRICT OF CALIFORNIA 6 7 8 In re ) Case No. 23-22540-E-13 ) Docket Control No. RLL-1 9 SATINDER SINGH, ) ) 10 Debtor. ) ) 11 MEMORANDUM OPINION AND DECISION 12 SUSTAINING OBJECTION TO EXEMPTION CLAIMED IN LIQUOR LICENSE 13 Creditor Placerville Investment Group, LLC (“Creditor”), objects to Satinder Singh’s 14 (“Debtor”) claimed exemption under California law in a liquor license.1 Creditor argues that a liquor 15 license is not a tool of the trade and should not be exempt under California Code of Civil Procedure 16 § 703.140(b)(6). Debtor has claimed two exemptions in the liquor license: 17 A. First, $29,586.88 exempt pursuant to California Code of Civil Procedure § 703.140(b)(5) (the “Wildcard Exemption”2), and 18 B. Second, $9,525.00 exempt pursuant to California Code of Civil Procedure 19 § 703.140(b)(6) [the implements, books, and tools of the trade exemption]. 20 21 1 The Objection to Claimed Exemptions has been set for hearing on the notice required by Local Bankruptcy Rule 9014-1(f)(1). Proper notice was given and defaults of the non-responding 22 parties and other parties in interest are entered. 23 2 The “Wildcard Exemption” is a bankruptcy concept found in 11 U.S.C. § 522(d)(5) which 24 allows a debtor to use up to one-half of the $27,900 residence exemption under the federal statute, plus an additional $1,475, to claim an exemption in any assets of the debtor, whether or not an 25 exemption is provided for such assets in 11 U.S.C. § 522. 26 The California Legislature adopted that concept in the California Code of Civil Procedure 27 § 703.140 alternative bankruptcy exemptions that may be elected by the debtor. However, California Code of Civil Procedure § 703.140(b)(5) more “generously” allows a debtor to use all or any 28 portion of the $28,275 exemption for a residence, § 703.140(b)(1), plus an additional $1,550 as a 1 Schedule C, Dckt. 29. Creditor does not object to the $29,586.88 Wildcard Exemption claimed by 2 Debtor. 3 In objecting to the exemption in the amount of $9,525.00, Creditor cites the court to 4 California Code of Civil Procedure § 703.140(b)(6) which states: 5 The debtor's aggregate interest, not to exceed eight thousand seven hundred twenty-five dollars ($8,725) in value, in any implements, professional books, or tools 6 of the trade of the debtor or the trade of a dependent of the debtor. 7 Creditor argues that this exemption, known as the tools of the trade exemption, should not apply to 8 Debtor’s liquor license because the license is not an implement, professional book, or tool. Obj., 9 Dckt. 62. 10 According to Creditor, the tools of the trade exemption should only exempt tangible items 11 of property used in the business. Id. Creditor cites to two opinions supporting its contention. In 12 re Johnson, 255 B.R. 554 (Bankr. S.D. of Ohio 2000) (holding that a license confers a right or 13 privilege to transact a type of business and is not a tool of the trade within the meaning of that 14 exemption); In re Nickeas, 503 B.R. 453 (Bankr. W.D. Wisc. 2013) (concurring with In re Johsnon). 15 Creditor also directs the court to an unreported decision out of the Central District of 16 California, In re Gonzalez, No. 2:15-bk-25283, 2016 WL 3910323 (Bankr. C. D. Cal. July 12, 17 2016). In that case, Bankruptcy Judge Kwan was addressing a claim of exemption in bank accounts 18 and accounts receivable as a tool of the trade. 19 Creditor further cites to C.F. Nielsen, Inc., which addressed the tools of the trade exemption 20 stated in California Code of Civil Procedure § 704.060(a)(1) and (a)(3), stating: 21 Subdivisions (a)(1) and (a)(3) of Code of Civil Procedure section 704.060 expressly exempt only those items of personal property “reasonably necessary to and 22 actually used” in the exercise of a trade, business or profession. 23 The usual and ordinary meaning of the above quoted language and the relevant case law pertaining to personal property exemptions indicate subdivisions 24 (a)(1) and (a)(3) of Code of Civil Procedure section 704.060 were intended to protect only those tools, equipment, and other items of tangible property which are 25 reasonably necessary and actually used by a judgment debtor in pursuing his livelihood. See, e.g., Sun Ltd. v. Casey (1979) 96 Cal.App.3d 38, 40-42; Lopp v. 26 Lopp (1961) 198 Cal.App.2d 474, 476-478; Peebler v. Danziger (1951) 104 Cal.App.2d 490, 490-491; Twining v. Taylor (1959) 170 Cal.App.2d Supp 842, 27 843-845. To construe subdivisions (a)(1) and (a)(3) otherwise would be inconsistent with the apparent purpose and intent of the Legislature and would lead to unjust 28 results. 1 We conclude appellant was not entitled to a personal property exemption for his business bank account under subdivision (a)(1) or (a)(3) of Code of Civil 2 Procedure section 704.060. 3 C.F. Nielsen, Inc., 15 Cal. Reptr. 2d 676 (Cal. Ct. App. 1992). 4 Debtor’s Initial Opposition 5 Debtor filed an Opposition to Creditor’s Objection on November 6, 2023. Dckt. 76. In his 6 Opposition, Debtor argues: 7 1. The tools of the trade exemption should be interpreted broadly, and so the In 8 re Johnson court got it wrong. 9 2. In the sale of liquor, a liquor license is the same as any other tool commonly exempted. There is no justification in finding that a tool is confined to a 10 physical object. 11 Dckt. 76. Debtor submits his own Declaration in support of the Opposition, testifying that a liquor 12 license is a tool in the sale of liquor business. Decl., Dckt. 77. 13 Continued Hearing and Supplemental Pleadings 14 The court continued the hearing, requesting that the Parties provide supplemental briefing 15 on these issues. 16 Creditor’s Supplemental Briefing 17 Creditor submitted its supplemental briefing on November 30, 2023. Dckt. 89. In its 18 supplemental brief, Creditor asserts: 19 1. California Code of Civil Procedure § 703.140(b)(6), the “tools of the trade” exemption, does not describe or anticipate being applied to a liquor license. 20 2. Creditor provides the following quote from a bankruptcy court in Wisconsin 21 to hear this same issue: 22 Debtors may be right that as the economy becomes more technology-based, the definition of tools may have to expand to 23 accommodate intangibles that a technology worker uses in his business. However, this argument does not advance the position of a 24 liquor license as a tool of the trade. Liquor licenses have been in existence since before the founding of this country. See, e.g., Sidney 25 and Beatrice Webb, The History of Liquor Licensing in England Principally from 1700 to 1830 (Longmans, Green and Co. 1903). 26 Even if there are modest intangibles that have become “tools” for the modern worker, a liquor license would not fall into that category. 27 In re Nikeas, 503 B.R. 453, 457 (Bankr. W.D. Wisc. 2013) 28 (emphasis added; 11 U.S.C. § 522(d)(5), (6)); see also In re Caylor, 1 31 B.R. 821 (Bankr. W.D. Penn. 1983) (holding the same). 2 3. A liquor license is not the same as a new tool used in the modern era. Liquor licenses have been around for hundreds of years and have been expressly 3 excluded from the language of California Code of Civil Procedure § 703.140(b)(6). The legislature could have explicitly provided for an 4 intangible license under the tools of the trade exemption if it so desired. 5 4. California Code of Civil Procedure § 704.060, an alternate tools of the trade exemption, is less restrictive than California Code of Civil Procedure 6 § 703.140(b)(6), the tools of the trade exemption that Debtor has elected.

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