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In Re Zieg, (Bkrtcy.W.D.Mo.)
A Chapter 7 debtor’s digital video disc (DVD) player was a “household good” for lien avoidance purposes, a Missouri bankruptcy court has held. Although the Bankruptcy Code, as amended by the Bankruptcy Abuse Prevention and Consumer Protection Act (BAPCPA), refers to a video cassette recorder (VCR) in the list of household goods set forth in 522(f)(4)(A), and not a DVD player, the court recognized that technology has changed since BAPCPA was drafted. The court agreed with those commentators who have suggested that the reference to a VCR can reasonably be interpreted to include a DVD player.