Clark v. Rameker (573 U.S. 122)

U.S. Supreme Court · decided June 12, 2014 · Supreme Court Database (Spaeth)

Citation
573 U.S. 122 · 134 S. Ct. 2242
Decided
June 12, 2014
Term
October Term 2013
Vote
9–0
Majority author
Justice Sotomayor
Issue area
Economic Activity
Disposition
Affirmed
Outcome
Petitioning party lost
Ideological direction
Conservative

Opinion excerpt

Justice SOTOMAYOR delivered the opinion of the Court. When an individual files for bankruptcy, she may exempt particular categories of assets from the bankruptcy estate. One such category includes certain “retirement funds.” 11 U.S.C. § 522(b)(3)(C). The question presented is whether funds contained in an inherited individual retirement account (IRA) qualify as “retirement funds” within the meaning of this bankruptcy exemption. We hold that they do not. I A When an individual debtor files a bankruptcy petition, her “legal or equitable interests ... in property” become part of the bankruptcy estate. § 541(a)(1). “To help the debtor obtain a fresh start,” however, the Bankruptcy Code allows debtors to exempt from the estate limited interests in certain kinds of property. Rousey v. Jacoway, 544 U.S. 320, 325, 125 S.Ct. 1561, 161 L.Ed.2d 563 (2005). The exemption at issue in this case allows debtors to protect “retirement funds to the extent those funds are in a fund or account that is exempt from taxation under section 401, 403, 408, 408A, 414, 457, or 501(a) of the Internal Revenue Code.” §§ 522(b)(3)(C), (d)(12). The enumerated sections of the Internal Revenue Code cover many types of accounts, three of which are relevant here. The first two are traditional and Roth IRAs, which are created by 26 U.S.C. § 408 and § 408A, respectively. Both types of accounts offer tax advantages…

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