Bill No. 12 does not, in practice, conflict with the Bankruptcy Code's treatment of creditors. 162 . In re Gifford, Case No. 11-40589, Doc. 44 at 33. 163 . The following cases have upheld Supremacy Clause challenges of bankruptcy only exemption statutes: In re Regevig, 389 B.R. 736, 740 (Bankr.N.D.Ariz.2008) (finding Supremacy Clause violation based on controlling 9th Circuit precedent, Kanter); In re Cross, 255 B.R. 25, 34 (Bankr.N.D.Ind.2000) (concluding bankruptcy only exemption is preempted because it "changes the distribution of assets between debtors and creditors and, thus, frustrates the full effectiveness of federal law by changing the balance between debtors and creditors that Congress created in the Bankruptcy Code”); In re Reynolds, 24 B.R. 344, 347 (Bankr.S.D.Ohio 1982) (<HOLDING>). The following cases have rejected Supremacy
holding that  522 permits states only to adopt uniform exemptions holding that because a police department regulation prohibiting beards allowed for medical exemptions but not religious exemptions it was not generally applicable under smith holding states may make nondiscriminatory religious practice exemptions but that such exemptions are not constitutionally required holding that congress specifically allowed states to use their own exemptions instead of the federal exemptions listed in  522d and new yorks bankruptcy only exemption scheme is not so inconsistent with the exemptions listed in  522d as to render it invalid under the supremacy clause holding that dol regulations related to flsa exemptions are enforceable