In re Cobb, No. 12-01124, 2012 Bankr. LEXIS 6072 (Bankr. N.D. Iowa 2012).

Overview of Facts: Richard and Celeste Cobb (the Debtors) filed a voluntary Chapter 7 bankruptcy petition. They owned a John Deere tractor with an agreed fair market value of $12,000. The Debtors claimed an exemption in the tractor for $10,800 as a “household good” under Iowa Code § 627.6(5). The Debtors argued that because they had a long, steep, unpaved driveway, the tractor was essential for clearing trees, removing snow, applying gravel, and allowing them to access public roads to get to work. The Chapter 7 Trustee objected to the exemption, claiming the tractor was a luxury item that was more than necessary to maintain the household and that a smaller, cheaper tractor could perform the same tasks .

Legal Issue: Whether the Tractor fits within the definition of “household goods” under Iowa’s exemption provisions.

Holding: The court held that the debtors were entitled to claim an exemption in a tractor as a household good pursuant to Iowa Code § 627.6(5) because there was no evidence that the tractor was used for any commercial purposes, and, based on the debtors’ exhibits which confirmed that their driveway was very long and difficult to maintain, the tractor enabled them to access their property and reach their jobs.