Bonus not taken when only bare expectancy

In some cases a debtor can have their bonus taken in bankruptcy even if they have not been paid it yet.   However there was some good news for the debtor in the May 2019 case of  In re Brown in Illinois.   In that case the debtor had been receiving bonuses every year that she had been employed, and the trustee argued that there was enough past history so that the future bonus was part of the bankruptcy estate and could be taken to pay creditors.   However, the Court held that the bonus was not part of the bankruptcy estate since the contract showed that it was fully revocable and could be reduced or eliminated at any time.