Exemption: Personal injury causes of action - NO LONGER EXEMPT as of September 4, 2007 - no "common law" exemptions in Missouri. Must all be statutory, according to In re Mahony (W.D.Mo.), citing In re Benn (8th Cir).
(The Debtors here argue that, unlike income tax refunds, Missouri courts have long held that unliquidated personal injury claims are exempt and that the Eighth Circuit could not have intended to change that precedent in Benn. Unfortunately for the Debtors,)