On March 4, 2014, the United States Supreme Court decided Law v. Siegel, No. 12-5196. The Court held that the bankruptcy court violated the express terms of § 522 of the Bankruptcy Code when it ordered that the $75,000 protected by a debtor's homestead exemption be available to pay a trustee's attorney's fees as an administrative expense. The order exceeded the limits of the bankruptcy court's authority under § 105(a) of the Code and its inherent powers.

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On May 13, 2013, the Supreme Court decided Bullock v. BankChampaign, N.A., No. 11-1518. Under 11 U.S.C.

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