In re: Jesslyn Renee Anderson, 613 B.R. 279

Debtor filed chapter 7 in December 2017 and listed a 15% interest in a family-owned residence in Ferndale, WA (valued at $90,000 to her) and claimed a $125,000 Washington homestead exemption.
Debtor occupied the Property as her principal residence on the petition date. Shortly after filing she married and moved out to live with her husband.
Trustee objected, arguing (a) Debtor lacked intent to reside on the petition date and (b) under RCW § 6.13.050 the homestead was presumed abandoned after six months of continuous absence without a filed declaration of nonabandonment.
Debtor relied on the bankruptcy "snapshot rule": exemption rights are fixed as of the petition date, and she occupied the Property on that date.
The bankruptcy court overruled Trustee’s objection; Trustee appealed. The Panel affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Debtor lost homestead exemption by moving out post‑petition and not filing a declaration of nonabandonment within six months	Debtor lacked present intent to reside; RCW presumes abandonment after six months and thus exemption is forfeited	Snapshot rule fixes exemptions on petition date; Debtor occupied the home on that date so entitlement exists regardless of later move	Affirmed: occupancy on the petition date conferred the automatic Washington homestead; the six‑month abandonment presumption is evidentiary and does not automatically strip an exemption fixed at filing
Proper monetary amount of the exemption	Exemption should be limited to Debtor’s $90,000 equity interest	Debtor claimed the statutory homestead amount ($125,000)	Not decided: bankruptcy court made no factual finding on value and Trustee conceded the issue was not properly before the court; left to bankruptcy court to resolve

In re Jacobson, 676 F.3d 1193 (9th Cir. 2012) (post‑petition sale proceeds must be reinvested under California rule; failure can defeat otherwise fixed exemption)
In re Golden, 789 F.2d 698 (9th Cir. 1986) (California reinvestment requirement caused forfeiture of exemption when debtor failed to reinvest proceeds)
In re Gitts, 116 B.R. 174 (9th Cir. BAP 1990) (under Washington law post‑petition declaration of homestead can create protection valid against trustee)
White v. Stump, 266 U.S. 310 (U.S. 1924) (snapshot rule: exemptions determined as of the bankruptcy petition date)
Wilson v. Rigby, 909 F.3d 306 (9th Cir. 2018) (value of an exemption is limited to the amount lawfully claimable on the petition date)