## Facts

- Chapter 7 debtors Theodore Roosevelt Johnson, Sr., and Linda Faye Johnson claimed as exempt a 1969 Dodge bus under Kentucky’s personal property exemption for “one motor vehicle.”
- The bus had a seating capacity of approximately 60 passengers.
- The debtor used the bus occasionally to transport members of a church congregation.
- The trustee objected, arguing that “motor vehicle” in Ky. Rev. Stat. § 427.010 should be read narrowly as synonymous with “automobile,” excluding a large bus.
- The record did not establish any special household need requiring a bus, such as family size or unusual transportation necessity.

## Issues

1. Whether a 60-passenger bus qualifies as “one motor vehicle” under Ky. Rev. Stat. § 427.010 for purposes of the debtor’s exemption, subject to the statute’s value cap.

## Decision

- The court held that the 1969 Dodge bus is a “motor vehicle” within the meaning of Ky. Rev. Stat. § 427.010.
- The trustee’s objection to the claimed exemption was overruled.
- The debtors were permitted to exempt the bus up to the statutory dollar limit.

## Legal Principles

- Statutory exemption terms are interpreted according to their ordinary, generic meaning unless the text clearly limits the category.
- “Motor vehicle” is a broad classification that includes buses as well as automobiles; both are types within the larger category of motor vehicles.
- Where the legislature has removed use-based restrictions from an exemption statute, courts should not reintroduce limits based on how the vehicle is used or on its passenger capacity.
- A party urging a narrowing construction must point to statutory language supporting that limitation; absent such language, courts apply the statute as written.

## Conclusion

The bankruptcy court construed Kentucky’s “one motor vehicle” exemption broadly and allowed the exemption for a 60-passenger bus, rejecting a textually unsupported attempt to confine “motor vehicle” to ordinary automobiles and treating size and non-household use as irrelevant to statutory coverage (subject to the value cap).


In re Johnson, 14 B.R. 14 (Bankr. W.D. Ky. 1981)