In the case of John R. Patterson, Trustee v. Joseph B. Shumate, Jr., 1991, the United States Supreme Court addressed whether a debtor's interest in an Employee Retirement Income Security Act (ERISA) qualified pension plan could be excluded from his bankruptcy estate under section 541(c)(2) of the Bankruptcy Code which allows for exclusion of interests that are subject to a restriction on transfer enforceable under "applicable nonbankruptcy law." The court unanimously held that ERISA-qualified pension plans do meet this requirement and therefore can be exempted from bankruptcy estates. This decision was based on their interpretation that ERISA’s anti-alienation provision constitutes a restriction enforceable under “applicable nonbankruptcy law.” Thus, it concluded that such pensions were not part of the bankrupt's estate and were protected from creditors.

The dissenting opinion in the case of John R. Patterson, Trustee v. Joseph B. Shumate, Jr., argued that a debtor's pension plan should not be exempt from bankruptcy estate assets under Section 541(c)(2) of the Bankruptcy Code because it does not meet the requirement for an enforceable transfer restriction as stipulated by applicable non-bankruptcy law. The dissent disagreed with the majority’s interpretation of “applicable nonbankruptcy law” to include federal laws like ERISA (Employee Retirement Income Security Act). They believed this broad interpretation could potentially shield all sorts of property from creditors and undermine bankruptcy policy objectives such as equitable distribution among creditors and giving debtors a fresh start free from overwhelming debts.