In Wolfe v. Jacobson (In re Jacobson), 2012 U.S. App. LEXIS 8103 (9th Cir. Apr. 23, 2012), the Ninth Circuit Court of Appeals held that bankruptcy debtors who successfully asserted a homestead exemption nevertheless lost the protected layer of value (here, $150,000), because a judgment creditor forced a postpetition execution sale of the house, and the debtors failed to reinvest their share of the proceeds in a new dwelling within six months. The court effectively reasoned that whenever a California exemption is allowed in a bankruptcy case, the debtor’s right to postpetition proceeds from the exempt value is subject to California’s time-limited protection of proceeds.