Pablo Correa and Esther Correa, 24-25099

Background

Debtors, Pablo and Esther Correa, are a married couple on a fixed, below-median income, who sold their primary home and used the proceeds to purchase a 2018 Flagstaff towable travel trailer.
The Flagstaff is parked in a mobile home park, on land leased by the Debtors, with fixed utility connections and a mailing address; they have continuously lived there as their permanent residence and never used it for travel.
The Debtors filed for Chapter 13 bankruptcy and listed the Flagstaff on their schedules, claiming it as a homestead exemption under Utah Code § 78B-5-503.
The Chapter 13 Trustee objected to the Debtors’ homestead exemption claim, arguing the Flagstaff did not qualify as a “mobile home.”
All relevant facts regarding the Flagstaff’s use, utility connections, and fixed location were undisputed at trial.

Issues

Issue	Correa (Debtors'): Argument	Trustee's Argument	Held
Whether the Flagstaff is a "mobile home" under Utah law and thus exempt as a homestead	The Flagstaff meets the statutory definition of "mobile home"—it is a transportable structure with its own utilities, established as their residence	The Flagstaff is a recreational vehicle, not a "structure," and thus not a “mobile home” as contemplated by the exemption statute	The Flagstaff is a “mobile home” under § 57-16-3(4) and is an exempt homestead under § 78B-5-503.
Whether a towable travel trailer can be a homestead	The trailer is their permanent and primary residence, qualifying it for the homestead exemption	The trailer is not real property or a constructed home, and therefore ineligible	A mobile home need not be real property or built on a permanent foundation; use and site establishment are sufficient
Which statutory definition governs “mobile home” for exemption purposes	Section 78B-5-503 incorporates definition from § 57-16-3; other statutes are not relevant	Broader or alternative vehicle code definitions should apply	The court must apply § 57-16-3(4), which specifically defines “mobile home” for this context
Whether the homestead exemption should be construed liberally in favor of debtors	Homestead statutes are remedial and should be liberally construed; the exemption should protect against destitution	Strict construction is warranted to limit exemptions to traditional homes	Homestead laws are to be liberally construed in favor of debtors, supporting exemption

Key Cases Cited

P.I.E. Emps. Fed. Credit Union v. Bass, 759 P.2d 1144 (Utah 1988) (homestead exemptions protect citizens from destitution, and statutes should be construed liberally)
Panagopulos v. Manning, 69 P.2d 614 (Utah 1937) (explaining the protective purpose of homestead exemptions)
Fink v. O’Neil, 106 U.S. 272 (1882) (exemption statutes must be liberally interpreted in favor of the debtor)
In re Lampe, 331 F.3d 750 (10th Cir. 2003) (exemption laws are to be construed liberally in favor of the debtor)
In re Stephens, 402 B.R. 1 (B.A.P. 10th Cir. 2009) (most courts require liberal construction of homestead statutes)
In re Busch, 294 B.R. 137 (B.A.P. 10th Cir. 2003) (property interests in bankruptcy are determined by state law)