## Facts

- Marie Erickson, a Wisconsin farmer, filed for bankruptcy.
- Dorchester State Bank held security interests in Erickson’s baler (about $400) and haybine (about $1,500).
- The parties agreed Erickson could claim as exempt any asset exempt under Wis. Stat. § 815.18(6), which lists specific farm implements, including “one mower” and “one hay loader,” but does not name balers or haybines.
- The bankruptcy court treated the baler as a “hay loader” and the haybine as a “mower,” allowing exemption; the district court affirmed.
- The bank appealed, arguing the implements were not covered because they performed additional functions beyond the older machines named in the statute.
- The Seventh Circuit accepted appellate jurisdiction because the district court’s order left nothing further to resolve in the bankruptcy case.

## Issues

1. Whether, under Wis. Stat. § 815.18(6), a haybine may be treated as a “mower” and a baler as a “hay loader” for exemption purposes even though each performs additional functions beyond the older listed implements.

## Decision

- The Seventh Circuit affirmed.
- A haybine qualified as a “mower” and a baler qualified as a “hay loader” under Wis. Stat. § 815.18(6).
- The court rejected a restrictive approach that would confine exemptions to implements as they existed when the statute’s terms were added.

## Legal Principles

- Exemption statutes listing specific implements may be construed to cover modern “technological successors” that perform the same core function as the listed tools.
- Functional equivalence, informed by the statute’s protective purpose, can control over a historically frozen reading that would make exemptions obsolete as technology changes.
- Additional or improved functions do not disqualify a tool when its primary role corresponds to an exempt listed implement and it serves the same basic function on the debtor’s farm.

## Conclusion

Because the haybine and baler performed the essential functions of a mower and hay loader in modern farming, they fell within Wisconsin’s enumerated farm-implement exemptions, and the bank’s appeal was denied.


In re Erickson, 815 F.2d 1090 (7th Cir. 1987)