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15.3.2 Household Goods and Personal Items

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  4. 15.3 Tangible Personal Property: Household Goods, Vehicles, Health Aids, Tools of the Trade; Tenancy by Entireties in Personal Property
  5. 15.3.2 Household Goods and Personal Items

15.3.2 Household Goods and Personal Items

Some exemption statutes list specific items or categories of household goods that are exempt.175 States frequently amend these statutes, so a decision that holds an item non-exempt may have been displaced by an amendment dealing with that item.

Other states exempt all necessary household goods or household furnishings, often subject to a dollar cap. Courts construe “necessary” to include not just what is needed for bare subsistence, but items generally found in the home and used to facilitate day-to-day living.176 The question of what is necessary will depend on local usage and may change over time. For example, televisions and VCRs or DVD players have become so common that they are likely to be considered necessary.177

Some states have amended their exemption statutes to cover computers or other electronics.178 Where the item is not specifically listed as exempt, some cases turn on whether it fits within a general exemption for household goods179—or whether it is similar enough to an outmoded term in a list of specific items that are exempt.180 One court, while declining to exempt a “relatively sophisticated” and “not inexpensive” computer system as “home furnishings,” left the door ajar by observing that a home computer could become “reasonably necessary for the maintenance of the home” if it, like televisions in the 1950s, evolved from an “expensive curiosity” to “a virtual necessity which can be purchased for relatively little.”181 Shortly thereafter, that court exempted a computer system used by members of a debtor’s family for schoolwork.182 For some debtors, a computer may also qualify under an exemption for tools of the trade.183 Since computers, smart phones, and similar devices perform so many functions, it may be possible to fit them into an exemption category for an item such as a television or VCR.184

Courts have varied widely in their treatment of small amenities such as entertainment, hobby, and sports equipment,185 jewelry,186 and decorative items such as knickknacks and art.187 However, some courts decline to extend these exemptions to collectibles and items purchased for investment.188 The Illinois exemption for “necessary wearing apparel, bibles, school books and family pictures” has been construed to require a showing of necessity only for clothing; other items are exempt without limit, so long as not acquired for the purpose of defrauding creditors.189 Virginia has a specific exemption for heirlooms, items of sentimental value that have been inherited at least once, which the debtor intends to leave to the next generation.190 Nebraska exempts “immediate personal possessions.”191 Some states specifically list firearms as exempt,192 and in other states courts have found them covered by more general exemptions.193 Lawnmowers and other equipment for maintaining the property are often found to fall within an exemption for household appliances or furnishings.194

Footnotes

  • 175 See Appx. H, infra; National Consumer Law Center, No Fresh Start in 2019: How States Still Let Debt Collectors Push Families into Poverty (Nov. 2019), available at www.nclc.org (state-by-state comparison of exemptions for household goods). See, e.g., In re Parks, 2018 WL 6603722 (Bankr. D. Kan. Dec. 12, 2018) (gift cards do not fall within exemption for food, clothing, or household goods even though they could be used to purchase those items; they are akin to cash, which is not exempt); In re Rivera, 499 B.R. 175 (Bankr. D. P.R. 2013) (exemption for “home use kitchens” covers stove, microwave, dishes, cookware, and utensils; exemptions for furniture with no cap must be for reasonable amount); In re Cintron, 499 B.R. 209 (Bankr. D. P.R. 2013) (stove may be exempted either as home use kitchen or household furniture); In re Glimcher, 458 B.R. 549 (Bankr. D. Ariz. 2011) (Arizona exemption for “food, fuel and provisions for six months” did not protect gift card from grocery chain that sold food and provisions; only existing goods were protected); In re LeJuerrne, 2004 WL 2192515 (Bankr. D. Kan. July 9, 2004) (detailed history of Kansas household furnishings exemptions; broad enough to cover almost anything in a house, if it is necessary; many items in collection of automotive memorabilia are exempt); Chashoudian v. Pate, 17 So. 3d 49 (La. Ct. App. 2009) (exemption for “all dogs, cats, and other domestic pets” covered only pet dogs and cats; purebred show dogs being boarded at a kennel were not exempt).

  • 176 Robinson v. Hagan, 527 B.R. 314 (S.D. Ill. 2014) (questioning whether Illinois exemption statute requires bibles to be “necessary”; even if it does, 200-year-old Book of Mormon, valued at $10,000, is exempt when owner did not acquire it to defraud creditors, kept it for religious reasons, and had refrained from selling it even when she had financial troubles), aff’d, 811 F.3d 267 (7th Cir. 2016); In re Gentry, 519 B.R. 531 (Bankr. W.D. Mo. 2014) (exemption covers items “convenient or useful to a reasonable existence or necessary to the functioning of a household”; exempting guns used for hunting or self-defense; noting that camping gear, bicycles, and golf clubs have been exempted as household goods); In re Dunnaway, 466 B.R. 515 (Bankr. E.D. Cal. 2012) (standards include whether item is ordinarily found in a household and is of ordinary value; items for comfortable living included, and local community standards must be considered; allowing exemption of firearms used for personal protection, food hunting, or recreation, but not for display); In re Goss, 352 B.R. 309 (Bankr. E.D. Okla. 2006) (large commercial-type safe not a household good; even if family needed safe place for papers, this safe went beyond what was reasonably necessary; cow used for breeding not exempt under statute exempting “milk cow”); In re Heath, 318 B.R. 115 (Bankr. W.D. Ky. 2004) (“functional nexus” test exempts items that foster or help enable daily existence in the household; rifle for deer hunting exempt but not tanning bed); In re LeJuerrne, 2004 WL 2192515 (Bankr. D. Kan. July 9, 2004) (exempting many items in collection of automotive memorabilia—used to furnish and decorate room used for family or business gatherings—under “reasonably necessary” standard); In re Larson, 203 B.R. 176 (Bankr. W.D. Okla. 1996) (home furnishings exemption includes items “reasonably necessary to the maintenance of a home,” not just bare necessities of survival); In re Latham, 182 B.R. 479 (Bankr. W.D. Va. 1995) (exempt furniture must be used for day to day living in debtors’ home; furniture of beach house which was sometimes used for family vacations and sometimes rented out was not exempt); Welsh v. Martinez, 2018 WL 1386232 (Conn. Super. Ct. Feb. 13, 2018) (exemption for goods “reasonably necessary to meet the needs of the exemptioner and his or her dependents” protects DVD player and movie collection but not wine refrigerator, wine collection, hot tub, pool table, treadmill, ping pong table, or home theater seats, receiver, and projector). See also In re Parks, 2018 WL 6603722 (Bankr. D. Kan. Dec. 12, 2018) (gift cards are akin to cash, which is not exempt; they do not fall within exemption for food, clothing, or household goods even though they could be used to purchase those items).

  • 177 Planned Parenthood of Columbus/Willamette, Inc. v. Am. Coal. of Life Activists, 2007 WL 4118597 (S.D. Ohio Nov. 16, 2007) (personal computers, printers, software, VCR, stereo and at least one television are exempt); In re Bushey, 559 B.R. 766 (Bankr. D.N.M. 2016) (television, sound system, and Blue Ray player are “common, everyday furnishings ordinarily found in American homes”); In re Yawn, 2010 WL 599392 (Bankr. S.D. Ga. Feb. 5, 2010) (television and laptop are household goods; second TV and second computer not exempt because statute specifies one of each; camera not a household good); In re Biancavilla, 173 B.R. 930 (Bankr. D. Idaho 1994) (television and VCR were exempt; recreational equipment and computer system were not household goods). See also In re Doss, 298 B.R. 866 (Bankr. W.D. Tenn. 2003) (big screen television was household good within meaning of bankruptcy lien avoidance provision); In re Hicks, 276 B.R. 84 (Bankr. W.D. Va. 2001) (television and VCR exempt); In re Elst, 210 B.R. 790 (Bankr. E.D. Wis. 1997) (second television set falls within federal bankruptcy exemption for household goods, because it provided entertainment for family and guests in the house); In re Sydlowski, 186 B.R. 907 (Bankr. N.D. Ohio 1995) (television, VCR and, for debtor with custody of child, a video game); In re Kinnemore, 181 B.R. 516 (Bankr. D. Idaho 1995) (television and VCR); In re French, 177 B.R. 568 (Bankr. E.D. Tenn. 1995) (VCR).

  • 178 See Appx. H, infra.

  • 179 In re Rhines, 227 B.R. 308 (Bankr. D. Mont. 1998) (computer exempt as household good under federal bankruptcy exemptions); In re Crawford, 226 B.R. 484 (Bankr. N.D. Ga. 1998) (computer used for educational purposes exempt as household good under federal bankruptcy exemptions). But see CSC Holdings, Inc. v. Sams’ Elecs., Inc., 2006 WL 1620242 (W.D. Okla. June 8, 2006) (computer is not a household good; note that debtor provided no evidence of how computer would be used when moved from business premises to home).

  • 180 In re Rivera, 499 B.R. 175 (Bankr. D. P.R. 2013) (exemption for “radio receiving set” covers sound system; DVD player, mobile phone, computer, and printer not exempt because not listed in statute and have no “intrinsic resemblance” to listed items); In re Zieg, 409 B.R. 917 (Bankr. W.D. Mo. 2009) (construing statute’s reference to “one VCR” “in light of changing technology” to exempt a DVD player); In re Irwin, 232 B.R. 151 (Bankr. D. Minn. 1999) (Minnesota exemption for household appliances did not cover computer, which is not usually thought of as an appliance and was not included in statute’s list of entertainment and information items that were exempt).

  • 181 In re Larson, 203 B.R. 176 (Bankr. W.D. Okla. 1996).

  • 182 In re Ratliff, 209 B.R. 534 (Bankr. W.D. Okla. 1997) (computer and printer used by children and one debtor who was a student, to do schoolwork, was exempt under “household and kitchen furniture” exemption). Accord In re Hicks, 276 B.R. 84 (Bankr. W.D. Va. 2001) (computer used for educational purposes was exempt); In re Andrews, 225 B.R. 485 (Bankr. D. Idaho 1998) (one computer is reasonably necessary to household, so is exempt under Idaho exemptions). See § 15.3.5, infra. But cf. In re Liston, 206 B.R. 235 (Bankr. W.D. Okla. 1997) (computer not exempt as home furnishing).

  • 183 See § 15.3.4, infra.

  • 184 See In re Zieg, 409 B.R. 917 (Bankr. W.D. Mo. 2009) (construing statute’s reference to “one VCR” “in light of changing technology” to exempt a DVD player).

  • 185 EXEMPT: In re Lucas, 77 B.R. 242 (B.A.P. 9th Cir. 1987) (golf clubs, camera equipment, and exercise bicycle fall within California household property exemption); In re Gallegos, 226 B.R. 111 (Bankr. D. Idaho 1998) (horse was household pet, within meaning of Idaho exemption, when it was kept as a companion, to be ridden by debtor’s young daughter, even though it was kept outside rather than in house); In re Holzapfel, 262 P.3d 1114 (Mont. 2011) (four-wheel ATV not covered by “firearms and other sporting goods” exemption because it is covered by specific exemption for motor vehicles). See also Fraley v. Commercial Credit, 189 B.R. 398 (W.D. Ky. 1995) (goods need not be “essential for survival” to be household goods; stereo, aquarium and camcorder (the modern equivalent of a photo album) were household goods under federal bankruptcy exemption); In re Harwood, 404 B.R. 366 (Bankr. E.D. Tex. 2009) (amendment replacing “household and kitchen furniture” with “home furnishings” broadened the exemption; reasonable necessity need not be shown; allowing exemption of home office and gym, but not hobby equipment), aff’d on other grounds, 427 B.R. 392 (E.D. Tex. 2010); In re LeJuerrne, 2004 WL 2192515 (Bankr. D. Kan. July 9, 2004) (many but not all items in collection of automotive memorabilia exempt); In re Doss, 298 B.R. 866 (Bankr. W.D. Tenn. 2003) (big screen television was household good within meaning of bankruptcy lien avoidance provision); In re French, 177 B.R. 568 (Bankr. E.D. Tenn. 1995) (camera and accessories used to take family pictures and VCR used for personal entertainment were household goods under federal bankruptcy exemptions); In re Lynch, 139 B.R. 868 (Bankr. N.D. Ohio 1992) (household goods are “items of personal property reasonably necessary for the day-to-day existence of people in their homes”; sound system and recordings were household goods, but not cameras). Cf. In re Hirsch, 338 B.R. 193 (Bankr. W.D.N.Y. 2006) (coin collection exempt up to face value of coins under New York exemption for cash; to extent numismatic value exceeded face value, collection would be sold and exempt amount paid to debtors).

    NON-EXEMPT: Crockett v. Lowe (In re Crockett), 158 F.3d 332 (5th Cir. 1998) (jet ski was not exempt under Texas exemption for “athletic and sporting equipment, including bicycles,” which had been construed in other bankruptcy cases to exclude sailboats and motorboats); In re Bushey, 559 B.R. 766 (Bankr. D.N.M. 2016) (no exemption for sports and hobby equipment; ski boots and gear not exempt clothing; these items may be exempted only as wildcard); In re Thomas, 2005 WL 2429963 (Bankr. C.D. Ill. Sept. 21, 2005) (pool table not household goods for purposes of lien avoidance under 11 U.S.C. § 522(f)); In re Hicks, 276 B.R. 84 (Bankr. W.D. Va. 2001) (movie and video cameras and pool table not exempt as household goods); In re Schreiber, 231 B.R. 17 (Bankr. D. Me. 1999) (pop-up camper not household good within meaning of Maine law, because no nexus with “daily use, maintenance or upkeep of the debtor’s household”); Welsh v. Martinez, 2018 WL 1386232 (Conn. Super. Ct. Feb. 13, 2018) (denying exemption to wine refrigerator, wine collection, hot tub, pool table, treadmill, ping pong table, and theater seats, receiver, and projector for home theater; exempting DVD player and movie collection); Crow v. 2010-1 RADC/CADC Venture, L.L.C., 430 P.3d 1171 (Wyo. 2018) (denying exemption to skis and bicycles). See also In re Elst, 210 B.R. 790 (Bankr. E.D. Wis. 1997) (under federal bankruptcy exemptions, bicycle was not a household good because it was not used in and around the house).

  • 186 In re Chaney, 2016 WL 4446007 (Bankr. D. Me. Aug. 23, 2016) (construing Maine statute to create two separate categories for jewelry: personal jewelry, capped at $750, and wedding and engagement rings; allowing exemption of wedding and engagement rings valued at more than $750); In re Cintron, 499 B.R. 209 (Bankr. D. P.R. 2013) (exemption for necessary wearing apparel protects wedding bands, here of low value); In re Rivera, 499 B.R. 175 (Bankr. D. P.R. 2013) (Puerto Rico exemption for “necessary and proper” wearing apparel protects jewelry if needed for debtor’s “social, business or professional engagements” and was not purchased as an investment); In re Fink, 2009 WL 3015340 (Bankr. S.D. Tex. Sept. 17, 2009) (Texas jewelry exemption limited to 25% of total personal property exemption; debtor entitled to $60,000 head-of-household exemption could exempt up to $15,000 in jewelry); In re Urie, 2006 WL 533514 (Bankr. W.D. Mo. Jan. 31, 2006) (Missouri’s $1500 exemption for “wedding ring” covers engagement ring and may be stacked with $500 jewelry exemption to fully exempt $2000 ring); In re Hazelhurst, 228 B.R. 199 (Bankr. E.D. Tenn. 1998) (some jewelry may be exempted as “necessary and proper wearing apparel,” depending on value, how often it is worn, and for what occasions; diamond engagement ring from former husband, which debtor no longer wore, was not exempt, but amethyst ring inherited from grandmother and worn about once a week was exempt); In re Wilson, 213 B.R. 413 (Bankr. D.R.I. 1997) (championship football ring which player wore daily was “held primarily for personal use” and was exempt when ring had significant sentimental value and had not been bought as investment); In re Meyer, 211 B.R. 203 (Bankr. E.D. Va. 1997) (Virginia exemption for wearing apparel protected cuff links and inexpensive watch that had been bought for everyday wear rather than investment purposes). But see In re Weeden, 306 B.R. 449 (Bankr. W.D.N.Y. 2004) (diamond engagement ring not exempt); In re Tiberia, 227 B.R. 26 (Bankr. W.D.N.Y. 1998) (diamond engagement ring not used in wedding ceremony, was not “wedding ring” within meaning of New York exemption). But cf. In re Lebovitz, 360 B.R. 612 (B.A.P. 6th Cir. 2007) (Tennessee’s unlimited exemption for “necessary and proper” wearing apparel protects “serviceable apparel appropriate to the work performed by the debtor,” but even if some jewelry included, “luxury items,” ranging in price from $1000 to $8000, were not necessary and proper); CSC Holdings, Inc. v. Sams’ Elecs., Inc., 2006 WL 1620242 (W.D. Okla. June 8, 2006) (watch was exempt, ring was not; both worn regularly, but debtor provided evidence that watch had only small value); In re Prosser, 2008 WL 2677863 (Bankr. D. V.I. July 1, 2008) (Virgin Islands personal property exemption explicitly excludes jewelry); In re Stegall, 2007 WL 1125635 (Bankr. S.D. Iowa Apr. 3, 2007) (former Iowa exemption for ring “owned and received by the debtor . . . on or before the date of marriage” would not exempt replacement diamond, bought after original was lost; statute has been amended to delete the operative language); In re Peterson, 280 B.R. 886 (Bankr. S.D. Ala. 2001) (items bought to enhance prestige or display wealth, such as expensive jewelry, not exempt; mink coat not exempt because “monetary value clearly outweighs utility value”; less expensive of two watches exempt); In re Lynch, 139 B.R. 868 (Bankr. N.D. Ohio 1992) (watch and diamond and ruby jewelry not exempt as household goods); Merrill Lynch Interfunding, Inc. v. Argenti, 2001 Conn. Super. LEXIS 1992 (Conn. Super. Ct. July 20, 2001) (diamond ring given to wife on twelfth anniversary was neither wedding nor engagement ring and was not necessary apparel when it was large, expensive, and not worn regularly); In re Winters, 40 P.3d 1231 (Wyo. 2002) (mother’s wedding ring that unmarried debtor inherited not exempt as wedding ring under Wyoming law).

  • 187 In re Lucas, 77 B.R. 242 (B.A.P. 9th Cir. 1987) (applying California household property exemption; Hummel figurines exempt); In re Westen, 2018 WL 1174888 (Bankr. E.D. Tex. Mar. 5, 2018) (distinguishing between exempt furnishings and non-exempt collectibles; exempting artwork used to decorate the home); In re Bushey, 559 B.R. 766 (Bankr. D.N.M. 2016) (wall art is exempt furniture unless it “has a sufficiently high value that it would no longer fall within the category of furniture”). But see In re Pullman, 317 B.R. 324 (Bankr. E.D. Va. 2004) (sports memorabilia that were not received from ancestor not heirlooms, and thus not exempt, despite intent to pass them on to children); Estate of Hersh v. Schwartz, 959 N.E.2d 1061 (Ohio Ct. App. 2011) (must show something more than sentimental value, but not absolute necessity; art, antiques and collectibles not exempt household goods); Crow v. 2010-1 RADC/CADC Venture, L.L.C., 430 P.3d 1171 (Wyo. 2018) (exemption for pictures only covers photos of family or life events having “high sentimental value”; art collection not protected).

  • 188 See, e.g., In re Lawson, 2006 WL 2130650 (E.D. Okla. June 21, 2006) (Oklahoma firearms exemption applies only to guns for personal or household use, not to valuable collection held for investment or used in business as bail bondsman).

  • 189 Robinson v. Hagan, 811 F.3d 267 (7th Cir. 2016) (Ill. law) (allowing exemption of first edition Mormon bible, valued at $10,000, given to librarian by her employer after she saved it from destruction; note that debtor owned other bibles used in day-to-day practice of religion).

  • 190 In re Sempeles, 471 B.R. 178 (Bankr. W.D. Va. 2012) (may be used to exempt intangible property—here, shares in a hunting preserve—inherited from father when debtor had hunted with father and now hunted with son, to whom he intended to leave the shares).

  • 191 In re Anthony, 2012 WL 1207421 (Bankr. D. Neb. Apr. 11, 2012) (noting lack of authority construing this section; holding that items covered by other specific exemptions—here, furniture—not covered; allowing exemption of athletic awards, photo albums and antique camera; foreign coins are non-exempt cash in hand if valuable but are exempt souvenirs if of minimal value).

  • 192 See In re Wilkinson, 402 B.R. 756 (Bankr. W.D. Tex. 2009) (Texas specifically exempts two firearms, and additional firearms may not be exempted under other categories; criminal code definition, which excludes antiques, not applicable to exemption statute; mounting antique firearms on plaques for display does not turn them into home furnishings); In re McCabe, 280 B.R. 841 (Bankr. N.D. Iowa 2002) (when exemption for one firearm had no cap, debtor could exempt costly shotgun bought on eve of bankruptcy); In re Maynard, 139 P.3d 803 (Mont. 2006) (statute protects required military equipment plus one gun; debtor not in National Guard or militia may use wildcard to exempt second gun). But see In re Lawson, 2006 WL 2130650 (E.D. Okla. June 21, 2006) (Oklahoma firearms exemption applies only to guns for personal or household use, not to valuable collection held for investment or used in business as bail bondsman). But cf. In re Brown, 189 B.R. 653 (Bankr. M.D. La. 1995) (Louisiana exemption for arms and military accoutrements applies only to weapons kept for military purposes, not those kept for hunting or collectibles); Welsh v. Martinez, 2018 WL 1386232 (Conn. Super. Ct. Feb. 13, 2018) (firearms not covered by militia exemption because debtor did not belong to state militia or federal armed forces).

  • 193 In re Gentry, 519 B.R. 531 (Bankr. W.D. Mo. 2014) (guns used for hunting or self-defense are exempt household goods); In re Dunnaway, 466 B.R. 515 (Bankr. E.D. Cal. 2012) (firearms are exempt household goods if used for self-protection, food hunting, or recreation, not merely for display); In re Heath, 318 B.R. 115 (Bankr. W.D. Ky. 2004) (in rural area where adult son hunted deer for family table, one rifle suitable for deer hunting was exempt household good); In re Karaus, 276 B.R. 227 (Bankr. D. Neb. 2002) (firearm kept for self-defense is household good, but gun collection acquired for historical or aesthetic interest is not exempt as “immediate personal possession”); In re Mason, 254 B.R. 764 (Bankr. D. Idaho 2000) (firearm may be exempt as household good, even though Idaho also has separate exemption for firearms; use of firearm for hunting or home defense favors exemption); In re Rhines, 227 B.R. 308 (Bankr. D. Mont. 1998) (rifle and shotgun were household goods under federal bankruptcy exemptions when debtor regularly hunted and game was main source of meat for family); In re Crawford, 226 B.R. 484 (Bankr. N.D. Ga. 1998) (rifle kept to defend home was household good under federal bankruptcy exemptions); In re Maynard, 139 P.3d 803 (Mont. 2006) (debtors may exempt one gun under firearms exemption and another under wildcard). See also In re Shell, 295 B.R. 129 (Bankr. D. Alaska 2003) (only one gun may be exempted under Alaska’s household goods exemption); In re Raines, 161 B.R. 548 (Bankr. N.D. Ga. 1993) (handgun kept for defense had sufficiently strong “functional nexus” with the home to make it an exempt household good under federal bankruptcy exemptions), aff’d, 170 B.R. 187 (N.D. Ga. 1994). But see In re Debias, 1999 U.S. App. LEXIS 29860 (10th Cir. Nov. 15, 1999) (handgun not an exempt household good under Colorado law because it was “not akin” to any items on statutory list of exempt items). But cf. In re McGreevy, 955 F.2d 957 (4th Cir. 1992) (shotgun and rifle used primarily for sport away from home do not support and facilitate day-to-day living within the home so are not “household goods” for purposes of lien avoidance under bankruptcy law); In re French, 177 B.R. 568 (Bankr. E.D. Tenn. 1995) (revolver kept for self-defense was not a household good under federal bankruptcy exemptions when debtor lived with sister who already owned a handgun for that purpose, nor was shotgun when husband testified that wife needed it to protect home in his absence, but wife did not know how to load or fire it).

  • 194 In re Yawn, 2010 WL 599392 (Bankr. S.D. Ga. Feb. 5, 2010) (lawnmower exempt as household goods); In re Irwin, 232 B.R. 151 (Bankr. D. Minn. 1999) (Minnesota exemption for household appliances covers lawn mower, which was necessary to maintain home); In re Andrews, 225 B.R. 485 (Bankr. D. Idaho 1998) (hand tools were reasonably necessary household goods); In re Payne, 215 B.R. 889 (Bankr. N.D. Okla. 1997) (both riding lawn mower and push lawn mower were exempt as “household and kitchen furniture,” as both were reasonably necessary to keep lawn acceptable and avoid nuisance citation by municipality).