In Re Lowe
This is a Chapter 7 bankruptcy case involving a Trustee's objection to the Debtor's claim of exemption for accrued funds from a General Motors-United Auto Workers profit-sharing plan. The central legal question was whether these funds qualify for exemption under New York's "opt-out" exemption statutes, specifically Debtor and Creditor Law § 282 or CPLR § 5205(c), or as a spendthrift trust under federal bankruptcy law. The Debtor presented six arguments, including claims of express statutory exemption, exclusion from the bankruptcy estate, and a cash exemption, along with arguments based on the de minimis amount and equitable considerations. The Court meticulously analyzed New York's convoluted exemption schema and ultimately rejected each of the Debtor's proposed arguments, emphasizing that exemptions must be statutory and cannot be created by the court. Consequently, the Court sustained the Trustee's objection, ordering the Debtor to turn over the profit-sharing funds to the Trustee.