In re Carter, 466 B.R. 468 (B.A.P. 8th Cir. 2012)

(state court judgment entered for estate against debtor and writ of execution issued which ordered sheriff to sell debtor’s vehicle to satisfy judgment; estate paid creditor amount of loan secured by vehicle and sheriff schedule sale which never occurred because debtor filed Chapter 7; debtor claimed portion of their interest in vehicle exempt under Iowa law and filed motion to avoid estate’s judgment lien which is avoidable under 11 U.S.C. §522(f)(1); bankruptcy court denied debtor’s motion; on appeal B.A.P. affirmed on basis that lien not judgment lien but consensual lien under Iowa law; when loan paid off, estate stepped into shoes of bank under Iowa Code §626.37 and held non-avoidable consensual lien; thus, amount estate advance to pay off loans secured by bank’s lien against debtor’s vehicle not secured by judicial lien).