On June 12, 2014, the U.S. Supreme Court issued its decision in Clark v. Rameker, 537 U.S. __ (2014), resolving a difference between federal circuit courts on the issue of whether an inherited IRA is excluded from the bankruptcy estate under section 522(b)(3)(C) of the federal Bankruptcy Code, which exempts retirement funds from the bankruptcy estate. Recall that an inherited IRA is one that has come to a beneficiary by reason of surviving the participant whose retirement funds had been amassed during their lifetime for their own retirement.