Balancing the Rights of Debtors and Creditors: $522(f)(1) of the Bankruptcy Code

Through the bankruptcy laws, society attempts to achieve a proper balance between the interests of failed debtors and unfortunate creditors.'The continually changing economic and social environment, however, makes the endeavor to achieve the "right" balance extremely difficult.2 Nevertheless, whether a "right" balance can ever be found, the bankruptcy laws must, at a minimum, set forth clear rules and provide for predictable results so that creditors, debtors and their attorneys can plan their future relationships.3Currently, § 522(f) (1) of the Bankruptcy Code ("Code")-the provision allowing a debtor to avoid a judicial lien where the lien "impairs" the debtor's exempt property-is dramatically failing to provide this clarity and predictability.'The judicial decisions involving the interpretation and application of § 522(f) (1) have consistently contradicted one another.5 Moreover, despite the 1994 Amendments to the I See generally Jane Forbes, In Re Lucas: A Blueprint For Unlimited Exemptions in Bankruptcy, 23 U. Tot.. L.