Peake v. Ayobami (In Re Ayobami), 879 F.3d 152

Debtor Yemisi Ayobami filed Schedule C in a Chapter 13 case checking boxes to exempt "100% of fair market value, up to any applicable statutory limit" for most claimed exemptions and cited 11 U.S.C. § 522(d)(1), (3)–(5).
The Chapter 13 trustee, Peake, objected; the bankruptcy court and district court engaged in multiple rounds of objections and orders before allowing amended exemptions after Ayobami also listed specific dollar amounts within statutory limits.
The bankruptcy court certified the question for direct appeal under 28 U.S.C. § 158(d)(2): whether a debtor claiming federal exemptions under § 522 may ever exempt a 100% interest in an asset.
The Fifth Circuit limited its review to the certified question and did not resolve related factual or procedural disputes about Ayobami’s particular Schedule C completion.
The court emphasized that § 522(d) caps the value that may be exempted (a dollar cap), not the percentage interest the debtor may claim, and therefore answering the certified question was a legal one about the scope of § 522(d).

Issue	Plaintiff's Argument	Defendant's Argument	Held
May a debtor claiming federal exemptions under § 522 exempt a 100% interest in an asset?	Ayobami: She claimed 100% interest exemptions (with listed statutory dollar amounts) and contends the form and § 522 allow such claims.	Peake (trustee): Allowing a 100% in-kind exemption would remove the whole asset from the estate contrary to § 522(d)’s monetary caps; exemptions must be limited to specific dollar amounts, not an indefinite in-kind claim.	Yes — a debtor may in certain circumstances exempt a 100% interest, because § 522(d) limits value exempted, not the percentage interest; but exemption cannot exceed the statutory dollar cap.
Does claiming a 100% interest entitle the debtor to clear title to the asset and post-petition appreciation?	Ayobami: Implicitly suggests full in-kind retention where allowed.	Peake: Opposes debtor retaining asset/title and post-petition appreciation when estate rights exist.	Not decided — the court declined to address whether a successful 100% exemption grants clear title or post-petition appreciation, leaving that for another case.

Schwab v. Reilly, 560 U.S. 770 (2010) (discusses a debtor claiming a full or 100% interest as exempt and questions whether that yields clear title to the asset)
Campaign for S. Equal. v. Bryant, 791 F.3d 625 (5th Cir. 2015) (noting weight of Supreme Court dicta when interpreting law)