Timothy Russell Hoffman v. Signature Bank of Georgia, 22 F.4th 1341

Timothy Hoffman guaranteed a $432,000 loan to a restaurant, defaulted, and filed Chapter 7 bankruptcy.
He listed as exempt: a Traditional IRA, a Roth Conversion IRA, a Roth Contributory IRA, and a Fidelity 401(k).
Signature Bank objected to the claimed exemptions; the bankruptcy court sustained the objection as to both Roth IRAs but overruled the objection as to the Traditional IRA and 401(k).
Hoffman sought exclusion of his Roth IRAs from the bankruptcy estate under 11 U.S.C. § 541(c)(2), arguing Georgia law (garnishment exemptions) prohibits transfer; he also invoked a state necessity exemption but did not appeal that alternative ruling.
The district court affirmed the bankruptcy court; the Eleventh Circuit reversed, holding Roth IRAs are excluded from a Georgia debtor’s bankruptcy estate because Georgia’s garnishment statute exempts "individual retirement account[s]," encompassing § 408 and § 408A accounts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are Roth IRAs excluded from a Georgia debtor's bankruptcy estate under 11 U.S.C. § 541(c)(2)?	Hoffman: Roth IRAs are "individual retirement account[s]" exempt from garnishment under Georgia law, so § 541(c)(2) excludes them from the estate.	Bank: Roth IRAs are not covered by the prior statutory language and thus may be included in the estate.	The court held Roth IRAs are excluded: Georgia's amended garnishment statute protects "individual retirement account[s]," and § 541(c)(2) applies.

Patterson v. Shumate, 504 U.S. 753 (1992) ("applicable nonbankruptcy law" may be federal or state for § 541(c)(2) purposes)
In re Meehan, 102 F.3d 1209 (11th Cir. 1997) (traditional IRAs excluded from bankruptcy estate under Georgia garnishment exemption and § 541(c)(2))
In re Bramlette, 333 B.R. 911 (Bankr. N.D. Ga. 2005) (declined to extend Meehan to Roth IRAs before Georgia amended statute)
In re Brown, 742 F.3d 1309 (11th Cir. 2014) (standard of appellate review in bankruptcy appeals)