The following excerpt is from In re Fowler, 493 B.R. 148 (Bankr. E.D. Cal. 2012):
The Constitutional analysis, however, is the same. Section 522(b) allows the States to define what property a debtor may exempt from the bankruptcy estate that will be distributed among his creditors. Owen v. Owen, 500 U.S. 305, 306, 111 S.Ct. 1833, 114 L.Ed.2d 350 (1991).
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