In re Dunaway, Nos. 11-60514-B-13, 11-17278-B-13, 11-61974-B-13, 11-61580-B-13, 2012 WL 759494 (Bankr. E.D. Cal. Mar. 6, 2012)

(consolidated opinion regarding four identical objections by trustee to debtors claimed exemptions for firearms; debtors listed one or more firearms as exempted “household goods” under California’s statutory exemptions; evidence presented that firearms used for personal protection and hunting and recreation; trustee requested court to find firearms per se are not exempt household goods; in its holding, court distinguished earlier cases, In re Thornton and In re Eveland, and held firearms can be exempt under broad California statute when evidence shows personal use and purpose of firearms, potential recreational value, reasonable necessity, and community standards establishing firearms “ordinarily found in household”; trustee in these cases failed to rebut debtors’ presumptions regarding firearms, so all debtors entitled to exemption).