Wolfe v. Jacobson (In Re Jacobson), 676 F.3d 1193

Cunningham sued the Jacobsons in California state court for torts related to a beach home; bankruptcy petition filed in 1995 stayed the state case.
In 1997 the bankruptcy court denied Myrna a discharge for fraud but gave Donald a discharge due to mental disability; Cunningham later obtained a $1.3 million judgment.
Cunningham sought to foreclose on the Kensington property; a judicial sale ensued and proceeds were subject to California homestead exemptions.
Myrna claimed a $150,000 homestead exemption from the Kensington sale proceeds, with reinvestment required within six months; they did not reinvest.
In 2007 the Chapter 7 trustee filed an adversary seeking turnover of Kensington proceeds, Enterprise property (title in Donald’s name), and related income; the bankruptcy court denied turnover.
The Bankruptcy Appellate Panel affirmed; the Ninth Circuit reversed in part and affirmed in part, holding Kensington proceeds not exempt and Enterprise property issues dependent on title and separate-property analysis.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Kensington proceeds remained exempt despite reinvestment failure	Jacobsons argue Golden exempts proceeds regardless of reinvestment	Trustee argues reinvestment rule forfeits exemption	Proceeds forfeited exemption; assets belong to estate
Whether Enterprise property is Donald's separate property and subject to turnover	Estate may have interest due to community property rules and joint operation	Donald’s sole title and inheritance traceable as Donald’s separate property	Donald's separate-property status; trustee failed to prove entitlement to turnover
Whether Myrna has standing to challenge inheritance-based claims from the 1990s case	Trustee has standing to pursue estate-related turnover	Trustee lacks standing to challenge inheritance from a separate, older estate	Trustee lacks standing
Whether collateral or judicial estoppel doctrine supports turnover of Enterprise property	Estoppel could compel turnover based on prior findings	Estoppel does not compel turnover of Donald’s property based on Myrna's actions	Estoppel doctrines do not compel turnover

Myers v. Matley, 318 U.S. 622 (1943) (homestead exemption scope analyzed through reinvestment context)
In re Golden, 789 F.2d 698 (9th Cir. 1986) (reinventment period governs exemption despite post-petition proceeds)
Lane, 364 B.R. 760 (Bankr. D. Or. 2007) (post-petition proceeds reinvestment and finality concerns)
Herman, 120 B.R. 127 (B.A.P. 9th Cir. 1990) (debtor's exemption treatment in post-petition homestead sales; policy)
Owen v. Owen, 500 U.S. 305 (1991) (state exemptions sovereignty and reinvestment restrictions)