Circuit precedent. Doc. 5 at 10,17. In In re Jacobson, 676 F.3d 1193 (9th Cir.2012), the Court of Appeals was asked to decide the applicability of California’s homestead exemption reinvestment requirement, which compelled a debtor to turn over proceeds from the sale of her exempt homestead after she failed to reinvest those proceeds within the six months permitted by the statute. In re Jacobson, 676 F.3d at 1198-99. Before Jacobson, California had elected to opt out of the Bankruptcy Code’s list of default property exemptions outlined in § 522(d), and defined their own exemptions as permitted by § 522(b)(2). Id. at 1198. California provided a homestead exemption similar to the exemption provided by many states, including Arizona. Id.; In re White, 377 B.R. 633, 643 (Bankr.D.Ariz. 2007) (<HOLDING>). The debtor in Jacobson argued that the
recognizing similar duties recognizing similar analysis applies to discrimination and retaliation claims recognizing that the ada is interpreted in a manner similar to title vii recognizing that californias homestead exemption is similar to ars  331101 recognizing a similar exception to its rule with respect to corporations