does not apply to actions to recover for necessities contracted for after the accrual of the benefits. Mich. Comp. Laws Ann. § 600.6023(2) limits the exemptions under Mich. Comp. Laws Ann. § 600.6023. It states: “The exemptions provided in this section shall not extend to any lien thereon excluded from exemption by law.” Under Michigan common law, a debtor may not exempt property against a valid consensual lien. The voluntary granting of a security interest in exempt property has been construed as a waiver of the right to claim an exemption in the property, as against the security interest. Under longstanding Michigan law, a debt- or can freely waive his right to an exemp tion, and grant a security interest in exempt property. See In re National Grocer Co., 181 F. 33, 35 (6th Cir.1910) (<HOLDING>); Church v. First Nat. Bank, 255 Mich. 595, 238
recognizing that exempt property ceases to be property of the estate holding that the debtor could retain exempt property because it was not property of the estate holding that bankruptcy court is without jurisdiction to control disposition of chapter 13 debtors property that is not property of the bankruptcy estate unless the property is related to the bankruptcy proceedings of the code holding that property seized by a creditor prior to debtors bankruptcy was property of the estate even though creditor  the irs  held a secured interest  a tax lien  in the property holding that the mortgaging or conveying of exempt property to a creditor is not against the public policy of the state of michigan and that that the bankrupt had the power to convey to a creditor his existing exemptions resulting in the exempt property not being property of the debtor or the debtors bankruptcy estate