claims of creditors.” Id. Judge Payne concluded, If this Court were to hold that ERISA preempted section 34-34 of the Virginia Code, the ability to implement and enforce the goals of the Bankruptcy Code would be impaired and modified because a state — here the Commonwealth of Virginia — would be precluded from setting appropriate exemption levels on retirement benefits even though Congress permitted it to do precisely that. Id. at 402. Although the United States Court of Appeals for the Fourth Circuit has not yet addressed ERISA’s preemptive effects on state exemption statutes like Virginia’s, several other circuits have. The majority of those circuits have held that ERISA’s savings clause precluded preemption of state exemption statutes. See In re Schlein, 8 F.3d 745 (11th Cir.1993) (<HOLDING>); In re Vickers, 954 F.2d 1426 (8th Cir.1992)
holding florida exemption statute for employee benefit plans was not preempted by erisa due to savings clause holding that a state law requiring benefit plans to include minimum benefits related to erisa plans holding texas exemption law was not preempted by erisa due to savings clause holding that selffunded employee benefit plans governed by erisa are not subject to direct state regulation holding that a georgia garnishment statute that solely applied to erisa employee benefit plans was preempted