Hanson v. Seaver (In re Hanson)

SALADINO, Bankruptcy Judge

The debtor appeals from an order of the bankruptcy court1 sustaining the trustee’s objection to an exemption claimed by the debtor. Specifically, the bankruptcy court held that a Minnesota property tax refund under Minn. Stat. Ann. § 290A.04 (West) is not exempt under Section 550.37 (Subd. 14) of the Minnesota statutes as “government assistance based on need,” following this panel’s decision in Manty v. Johnson (In re Johnson), 509 B.R. 213 (8th Cir. BAP 2014). The debtor appeals, asserting that Johnson was implicitly overruled by a subsequent decision of the Eighth…