Clark v. Rameker

PETITIONER: Brandon C. Clark and Heidi Heffron-Clark
RESPONDENT: William J. Rameker, Trustee, et al.
LOCATION: Bankruptcy Court for the Western District of Wisconsin

DOCKET NO.: 13-299
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT:

CITATION: 573 US (2014)
GRANTED: Nov 26, 2013
ARGUED: Mar 24, 2014
DECIDED: Jun 12, 2014

ADVOCATES:
Danielle Spinelli - for the respondents
Kannon K. Shanmugam - for the petitioners

Facts of the case

In 2001, Heidi Heffron-Clark inherited a $300,000 individual retirement account (IRA) from her mother's estate. The U.S. tax code provides special rules for IRAs that are inherited by someone other than the spouse of the deceased. These rules prohibit additional contributions to the inherited account and require the beneficiary to withdraw, and pay taxes on, a minimum amount from the account each year. Heidi and her husband (the "Clarks"), filed for bankruptcy in 2010 and claimed the inherited IRA was exempt from creditor claims. A bankruptcy judge ruled that retirement funds must be held for the current owner's retirement in order to qualify as an exempt retirement fund under Section 522 of the U.S. Bankruptcy Code. Because the Clarks were required to withdraw money from the inherited IRA before their retirement, the judge held that the account was subject to creditor claims in the bankruptcy proceeding. The federal district court reversed and held that Heidi's inheritance of the IRA did not change its status as a protected retirement fund. The U.S. Court of Appeals for the Seventh Circuit reversed.

Question

Does the U.S. Bankruptcy Code exempt an inherited IRA from a debtor's estate in bankruptcy?

Media for Clark v. Rameker

Audio Transcription for Opinion Announcement - June 12, 2014 in Clark v. Rameker

Justice Sotomayor has our opinion this morning in case 13-299, Clark v. Rameker.

Petitioners are a married couple who filed for bankruptcy 2010.

During their bankruptcy proceedings, petitioners sought to claim an exemption for $300,000 held in an inherited IRA which the wife had inherited from her mother.

Petitioners argued that the funds were exempt under §522(b)(3)(C) of the Bankruptcy Code which covers retirement funds to the extent those funds are in an account that is exempt from taxation under various sections of the Tax Code.

The question presented is whether the funds in inherited IRAs are retirement funds within the meaning of this provision.

The Seventh Circuit held that they are not in conflict with the Fifth Circuit.

We think the Seventh Circuit got it right and we therefore affirm.

The ordinary meaning of retirement funds is “sums of money set aside for the day an individual stops working”.

To determine whether a pot of money meets this definition, we look at the objective legal characteristics of the account in which the money is held.

Applying that test, these characteristics lead us to whole 01:28 but inherited IRAs do not contain retirement funds.

First, the owner of an inherited IRA can never contribute money to the account.

Second, an owner must withdraw her money from her inherited IRA no matter how far away she may be from her retirement years.

Third, an individual can withdraw the entire amount of money from her inherited IRA at anytime and use it for any purpose without paying a penalty.

Funds in an inherited IRA can thus be used freely for current consumption and are not set aside for the day that person stops working.

Petitioner's main argument is that the funds in an inherited IRA are exempt because they use to be held in a retirement account at an earlier point in time.

But the ordinary understanding of retirement funds encompasses funds currently set aside for retirement not funds that used to be set aside for retirement by a different person at a different point in time.

Petitioner's interpretation would also render the statute's use of the term “retirement funds” superfluous.

A reading we are reluctant to accept and although petitioners are correct that the interpretation we adopt has the limited effect of carving out just inherited IRAs from the retirement funds exemption.

We think a reading that treats the term retirement funds as meaningful but modest is more faithful to the statute.

The judgment of the United States Court of Appeals for the Seventh Circuit is accordingly affirmed.

This opinion is for unanimous court.

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