In the 2004 case of Richard Gerald Rousey, et ux. v. Jill R. Jacoway, the U.S Supreme Court ruled in favor of the petitioners, Mr and Mrs Rousey, who sought to exempt their Individual Retirement Accounts (IRAs) from bankruptcy estate under section 522(d)(10)(E) of Bankruptcy Code which allows debtors to exclude certain benefits that are reasonably necessary for their support during retirement. The court held that IRAs were similar to other forms of retirement savings protected by this provision because they provide income security for retirees and thus could be excluded from a bankruptcy estate if deemed essential for survival post-retirement.

In the dissenting opinion for Rousey v. Jacoway, Justice Stevens argued that the majority's interpretation of Section 522(d)(10)(E) was too broad and inconsistent with Congress' intent. He contended that this section should only apply to funds needed for day-to-day support or necessary living expenses, not retirement accounts which are typically used as a source of income in later life rather than immediate sustenance. He also pointed out that allowing debtors to shield their entire retirement savings from creditors could lead to abuse of bankruptcy protections. Furthermore, he disagreed with the majority's reliance on tax law definitions in interpreting bankruptcy provisions, arguing these two areas have different purposes and thus require separate interpretations.