In re Robinson

Summarized by Kurt Carlson , Carlson Dash LLC
10 years 3 weeks ago

Citation:

In re Robinson, Court of Appeals, 7th Circuit 2016 (unpublished)

Tag(s):

Ruling:

The plain language of the Illinois personal property exemption statute does not impose a dollar-value limitation on the items available for exemption, and a debtor is therefore not precluded from claiming an exemption for a valuable first-edition religious text.

Procedural context:

On February 25, 2013, Anna Robinson (the “Debtor”) filed a Chapter 7 bankruptcy petition in the Southern District of Illinois seeking to discharge an unsecured debt in the amount of $23,834.00. The trustee filed an objection to the Debtor’s claimed exemption of a valuable first-edition Book of Mormon. On August 20, 2013, the bankruptcy court entered an order sustaining the trustee’s objection. The Debtor moved to reconsider, but the bankruptcy court denied her motion. The Debtor appealed. The district court ruled in favor of the debtor, and held that a bible is exempt without regard to its value because the legislature did not place a monetary restriction on the items exempted under the Illinois personal property exemption statute. The trustee appealed, and the Court of Appeals affirmed the lower court’s decision.

Facts:

The Illinois personal property exemption statute provides an exemption for a “bible.” 735 ILCS 5/12-1001(a). Pursuant to this statute, the Debtor included an “old Morm[o]n bible” of unknown value among her scheduled personal property in her Chapter 7 bankruptcy. The appointed Trustee inquired about the bible at the creditors meeting. The Debtor confirmed that the bible was in fact a rare 1830 first edition Book of Mormon and that she had several copies in print or digital form. The trustee filed an objection to the claimed exemption, arguing that the valuable first edition should be used for the benefit of the creditors given that the Debtor owned many other copies. As a matter of statutory interpretation, the Court of Appeals began its analysis with the plain language of the Illinois personal exemption statute, which provides in relevant part: “[t]he following personal property, owned by the debtor, is exempt from judgment, attachment, or distress for rent: (a) [t]he necessary wearing apparel, bible, school books, and family pictures of the debtor and the debtor’s dependents…” 735 ILCS 5/12-1001(a). The Court of Appeals noted that the term bible means “a religious text,” and that the Book of Mormon undisputedly falls within this meaning. The Court of Appeals further emphasized that “there is nothing in the wording of subsection (a) that imposes a dollar limit on the items listed therein.” In concluding that the statute is unambiguous, the Court of Appeals looked to other subsections of the statute which did include dollar-value limitations and reasoned that because the legislature did not include such language in subsection (a), it clearly did not intend to limit that subsection to items under a certain value. Thus, while the Court of Appeals agreed with the trustee’s argument that the exemption applies to one bible, the Court discredited the trustee’s attempt to limit the Debtor to one bible of negligible monetary value. Finally, because the Court of Appeals found the statute to be unambiguous, it did not need to look beyond the statutory language to ascertain the legislature’s intent.

Judge(s):

Wood, Easterbrook, Ripple

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