Slip opinion

NOTE: Where it is feasible, a syllabus
(headnote) will be released, as is being
done in connection with this case, at
the time the opinion is issued.  The
syllabus constitutes no part of the
opinion of the Court but has been pre-
pared by the Reporter of Decisions for
the convenience of the reader.  See
United States v. Detroit Lumber Co., 200
U. S. 321, 337.

SUPREME COURT OF THE UNITED STATES

              Syllabus

    PATTERSON, TRUSTEE v. SHUMATE
 certiorari to the united states court of ap-
 peals for the fourth circuit
No. 91-913.   Argued April 20, 1992"Decided June
              15, 1992

Respondent Shumate was a participant in his
employer's pension plan, which contained the
anti-alienation provision required for tax qua-
lification under the Employee Retirement Income
Security Act of 1974 (ERISA).  The District Court
rejected his contention that his interest in the
plan should be excluded from his bankruptcy
estate under 541(c)(2) of the Bankruptcy Code,
which excludes property of the debtor that is
subject to a restriction on transfer enforce-
able under ``applicable nonbankruptcy law.''  The
court held, inter alia,  that the latter phrase
embraces only state law, not federal law such
as ERISA, and that Shumate's interest in the
plan did not qualify for protection as a spend-
thrift trust under state law.  The court or-
dered that Shumate's interest in the plan be
paid over to petitioner, as trustee of Shumate-
's bankruptcy estate.  The Court of Appeals
reversed, ruling that the interest should be
excluded from the bankruptcy estate under 541(c)(2).
Held:The plain language of the Bankruptcy Code
and ERISA establishes that an anti-alienation
provision in a qualified pension plan consti-
tutes a restriction on transfer enforceable
under ``applicable nonbankruptcy law'' for pur-
poses of 541(c)(2).  Pp.4-12.
(a)Plainly read, 541(c)(2) encompasses any
relevant nonbankruptcy law, including federal
law such as ERISA.  The section contains no
limitation on ``applicable nonbankruptcy law''
relating to the source of the law, and its text
nowhere suggests that that phrase refers, as
petitioner contends, exclusively to state law.
Other sections in the Bankruptcy Code reveal
that Congress knew how to restrict the scope
of applicable law to ``state law'' and did so with
some frequency.  Its use of the broader phrase
``applicable nonbankruptcy law'' strongly sug-
gests that it did not intend to restrict 541(c)-
(2) in the manner petitioner contends.  Pp.4-5.
(b)The anti-alienation provision contained in
this ERISA-qualified plan satisfies the literal
terms of 541(c)(2).  The sections of ERISA and
the Internal Revenue Code requiring a plan to
provide that benefits may not be assigned or
alienated clearly impose a ``restriction on the
transfer'' of a debtor's ``beneficial interest''
within 541(c)(2)'s meaning, and the terms of the
plan provision in question comply with those
requirements.  Moreover, the transfer restric-
tions are ``enforceable,'' as required by 541(c)-
(2), since ERISA gives participants the right to
sue to enjoin acts that violate that statute or
the plan's terms.  Pp.5-7.
(c)Given the clarity of the statutory text,
petitioner bears an ``exceptionally heavy'' bur-
den of persuasion that Congress intended to
limit the 541(c)(2) exclusion to restrictions on
transfer that are enforceable only under state
spendthrift trust law.  Union Bank v. Wolas, 502
U.S. ___, ___.  He has not satisfied that bur-
den, since his several challenges to the Court's
interpretation of 541(c)(2)"that it is refuted
by contemporaneous legislative materials, that
it renders superfluous the 522(d)(10)(E) debto-
r's exemption for pension payments, and that it
frustrates the Bankruptcy Code's policy of
ensuring a broad inclusion of assets in the
bankruptcy estate"are unpersuasive.  Pp.7-12.
943 F.2d 362, affirmed.

Blackmun, J., delivered the opinion for a unani-
mous Court.  Scalia, J., filed a concurring opin-
ion.
Opinion
NOTICE: This opinion is subject to formal
revision before publication in the pre-
liminary print of the United States
Reports.  Readers are requested to
notify the Reporter of Decisions, Su-
preme Court of the United States, Wash-
ington, D.C. 20543, of any typographical
or other formal errors, in order that
corrections may be made before the
preliminary print goes to press.
SUPREME COURT OF THE UNITED STATES--------
             No. 91-913
              --------
JOHN R. PATTERSON, TRUSTEE, PETITIONER v.
            JOSEPH B. SHUMATE, Jr.
  on writ of certiorari to the united states
    court of appeals for the fourth circuit
                [June 15, 1992]

  Justice Blackmun delivered the opinion of the
Court.
  The Bankruptcy Code excludes from the bank-
ruptcy estate property of the debtor that is
subject to a restriction on transfer enforceable
under  applicable nonbankruptcy law.  11 U. S. C.
541(c)(2).  We must decide in this case whether an
anti-alienation provision contained in an ERISA-
qualified pension plan constitutes a restriction
on transfer enforceable under  applicable nonba-
nkruptcy law, and whether, accordingly, a debtor
may exclude his interest in such a plan from the
property of the bankruptcy estate.
                       I
  Respondent Joseph B. Shumate, Jr., was employed
for over 30 years by Coleman Furniture Corpo-
ration, where he ultimately attained the position
of president and chairman of the board of direc-
tors.  Shumate and approximately 400 other
employees were participants in the Coleman Furni-
ture Corporation Pension Plan (Plan).  The Plan
satisfied all applicable requirements of the
Employee Retirement Income Security Act of 1974
(ERISA) and qualified for favorable tax treatment
under the Internal Revenue Code.  In particular,
Article 16.1 of the Plan contained the anti-alien-
ation provision required for qualification under
206(d)(1) of ERISA, 29 U. S. C. 1056(d)(1) ( Each
pension plan shall provide that benefits provided
under the plan may not be assigned or alienated).
App. 342.  Shumate's interest in the plan was
valued at $250,000.  App. 93-94.
  In 1982, Coleman Furniture filed a petition for
bankruptcy under Chapter 11 of the Bankruptcy
Code.  The case was converted to a Chapter 7
proceeding and a trustee, Roy V. Creasy, was
appointed.  Shumate himself encountered financial
difficulties and filed a petition for bankruptcy in
1984.  His case, too, was converted to a Chapter 7
proceeding, and petitioner John R. Patterson was
appointed trustee.
  Creasy terminated and liquidated the Plan,
providing full distributions to all participants
except Shumate.  Patterson then filed an adver-
sary proceeding against Creasy in the Bankruptcy
Court for the Western District of Virginia to
recover Shumate's interest in the Plan for the
benefit of Shumate's bankruptcy estate.  Shumate
in turn asked the United States District Court for
the Western District of Virginia, which already
had jurisdiction over a related proceeding, to
compel Creasy to pay Shumate's interest in the
Plan directly to him.  The bankruptcy proceeding
subsequently was consolidated with the district
court action.  App. to Pet. for Cert. 53a-54a.
  The District Court rejected Shumate's conten-
tion that his interest in the Plan should be
excluded from his bankruptcy estate.  The court
held that 541(c)(2)'s reference to  nonbankruptcy
law embraced only state law, not federal law such
as ERISA.  Creasy v. Coleman Furniture Corp., 83 B.R.
404, 406 (1988).  Applying Virginia law, the court
held that Shumate's interest in the Plan did not
qualify for protection as a spendthrift trust.
Id., at 406-409.  The District Court also rejected
Shumate's alternative argument that even if his
interest in the Plan could not be excluded from
the bankruptcy estate under 541(c)(2), he was
entitled to an exemption under 11 U. S. C. 522(b)(-
2)(A), which allows a debtor to exempt from proper-
ty of the estate  any property that is exempt
under Federal law.  Id., at 409-410.  The District
Court ordered Creasy to pay Shumate's interest
in the Plan over to his bankruptcy estate.  App. to
Pet. for Cert. 54a-55a.
  The Court of Appeals for the Fourth Circuit
reversed.  943 F. 2d 362 (1991).  The court relied
on its earlier decision in Anderson v. Raine (In re
Moore), 907 F. 2d 1476 (1990), in which another
Fourth Circuit panel was described as holding,
subsequent to the District Court's decision in the
instant case, that  ERISA-qualified plans, which
by definition have a non-alienation provision,
constitute `applicable nonbankruptcy law' and
contain enforceable restrictions on the transfer
of pension interests.  943 F. 2d, at 365.  Thus,
the Court of Appeals held that Shumate's interest
in the Plan should be excluded from the bankruptcy
estate under 541(c)(2).  Ibid.  The court then
declined to consider Shumate's alternative argu-
ment that his interest in the Plan qualified for
exemption under 522(b).  Id., at 365-366.
  We granted certiorari, ___ U. S. ___ (1992), to
resolve the conflict among the Courts of Appeals
as to whether an anti-alienation provision in an
ERISA-qualified pension plan constitutes a re-
striction on transfer enforceable under  applica-
ble nonbankruptcy law for purposes of the
541(c)(2) exclusion of property from the debtor's
bank-ruptcy estate.
                      II
                       A
  In our view, the plain language of the Bankruptcy
Code and ERISA is our determinant.  See Toibb v.
Radloff, 501 U. S. ___, ___ (1991) (slip op. 3).
Section 541(c)(2) provides the following exclusion
from the otherwise broad definition of  property
of the estate contained in 541(a)(1) of the Code:
 A restriction on the transfer of a beneficial
interest of the debtor in a trust that is
enforceable under applicable nonbankruptcy law
is enforceable in a case under this title
(emphasis added).

The natural reading of the provision entitles a
debtor to exclude from property of the estate any
interest in a plan or trust that contains a trans-
fer restriction enforceable under any relevant
nonbankruptcy law.  Nothing in 541 suggests that
the phrase  applicable nonbankruptcy law refers,
as petitioner contends, exclusively to state law.
The text contains no limitation on  applicable
nonbankruptcy law relating to the source of the
law.
  Reading the term  applicable nonbankruptcy law
in 541(c)(2) to include federal as well as state
law comports with other references in the Bank-
ruptcy Code to sources of law.  The Code reveals,
significantly, that Congress, when it desired to
do so, knew how to restrict the scope of applica-
ble law to  state law and did so with some fre-
quency.  See, e.g., 11 U. S. C. 109(c)(2) (entity may
be a debtor under chapter 9 if authorized  by
State law); 11 U. S. C. 522(b)(1) (election of
exemptions controlled by  the State law that is
applicable to the debtor); 11 U. S. C. 523(a)(5) (a
debt for alimony, maintenance, or support deter-
mined  in accordance with State or territorial
law is not dischargeable); 11 U. S. C. 903(1) ( a
State law prescribing a method of composition of
indebtedness of municipalities is not binding on
nonconsenting creditors); see also 11 U. S. C.
362(b)(12) and 1145(a).  Congress' decision to
use the broader phrase  applicable nonbankruptcy
law in 541(c)(2) strongly suggests that it did not
intend to restrict the provision in the manner
that petitioner contends.
  The text of 541(c)(2) does not support petition-
er's contention that  applicable nonbankruptcy
law is limited to state law.  Plainly read, the
provision encompasses any relevant nonbankrupt-
cy law, including federal law such as ERISA.  We
must enforce the statute according to its terms.
See United States v. Ron Pair Enterprises, Inc., 489
U. S. 235, 241 (1989).                       B
  Having concluded that  applicable nonbankruptcy
law is not limited to state law, we next determine
whether the anti-alienation provision contained
in the ERISA-qualified plan at issue here satis-
fies the literal terms of 541(c)(2).
  Section 206(d)(1) of ERISA, which states that
 [e]ach pension plan shall provide that benefits
provided under the plan may not be assigned or
alienated, 29 U. S. C. 1056(d)(1), clearly imposes
a  restriction on the transfer of a debtor's
 beneficial interest in the trust.  The coordi-
nate section of the Internal Revenue Code, 26
U. S. C. 401(a)(13), states as a general rule that
 [a] trust shall not constitute a qualified trust
under this section unless the plan of which such
trust is a part provides that benefits provided
under the plan may not be assigned or alienated,
and thus contains similar restrictions.  See also
26 CFR 1.401(a)-13(b)(1) (1991).
  Coleman Furniture's pension plan complied with
these requirements.  Article 16.1 of the Plan
specifically stated:  No benefit, right or inter-
est of any participant  shall be subject to
alienation, sale, transfer, assignment, pledge,
encumbrance or charge, seizure, attachment or
other legal, equitable or other process.  App.
342.
  Moreover, these transfer restrictions are
 enforceable, as required by 541(c)(2).  Plan
trustees or fiduciaries are required under ERISA
to discharge their duties  in accordance with the
documents and instruments governing the plan.
29 U. S. C. 1104(a)(1)(D).  A plan participant, bene-
ficiary, or fiduciary, or the Secretary of Labor
may file a civil action to  enjoin any act or
practice which violates ERISA or the terms of the
plan.  29 U. S. C. 1132(a)(3) and (5).  Indeed, this
Court itself vigorously has enforced ERISA's
prohibition on the assignment or alienation of
pension benefits, declining to recognize any
implied exceptions to the broad statutory bar.
See Guidry v. Sheet Metal Workers Pension Fund, 493
U. S. 365 (1990).
  The anti-alienation provision required for
ERISA qualification and contained in the Plan at
issue in this case thus constitutes an enforce-
able transfer restriction for purposes of 541(c-
)(2)'s exclusion of property from the bankruptcy
estate.
                      III
  Petitioner raises several challenges to this
conclusion.  Given the clarity of the statutory
text, however, he bears an  exceptionally heavy
burden of persuading us that Congress intended
to limit the 541(c)(2) exclusion to restrictions on
transfer that are enforceable only under state
spendthrift trust law.  Union Bank v. Wolas, 502
U. S. ___, ___ (1991) (slip op. 4).
                       A
  Petitioner first contends that contemporaneous
legislative materials demonstrate that 541(c)(2-
)'s exclusion of property from the bankruptcy
estate should not extend to a debtor's interest in
an ERISA-qualified pension plan.  Although courts
 appropriately may refer to a statute's legisla-
tive history to resolve statutory ambiguity,
Toibb v. Radloff, 501 U. S., at ___ (slip op. 5), the
clarity of the statutory language at issue in this
case obviates the need for any such inquiry.  See
ibid.; United States v. Ron Pair Enterprises, Inc.,
489 U. S., at 241; Davis v. Michigan Dept. of Trea-
sury, 489 U. S. 803, 809, n. 3 (1989).
    Even were we to consider the legislative
materials to which petitioner refers, however, we
could discern no  clearly expressed legislative
intention contrary to the result reached above.
See Consumer Product Safety Comm'n v. GTE Sylvania,
Inc., 447 U. S. 102, 108 (1980).  In his brief, peti-
tioner quotes from House and Senate reports
accompanying the Bankruptcy Reform Act of 1978
that purportedly reflect  unmistakable congres-
sional intent to limit 541(c)(2)'s exclusion to
pension plans that qualify under state law as
spendthrift trusts.  Brief for Petitioner 38.
Those reports contain only the briefest of dis-
cussions addressing 541(c)(2).  The House Report
states:  Paragraph (2) of subsection (c) . . .
preserves restrictions on transfer of a spend-
thrift trust to the extent that the restriction is
enforceable under applicable nonbankruptcy law.
H. R. Rep. No. 95-595, p. 369 (1977); see also S. Rep.
No. 95-989, p. 83 (1978) (541(c)(2)  preserves
restrictions on a transfer of a spendthrift
trust).  A general introductory section to the
House Report contains the additional statement
that the new law  continues over the exclusion
from property of the estate of the debtor's
interest in a spendthrift trust to the extent the
trust is protected from creditors under applica-
ble State law.  H. R. Rep. No. 95-595, p. 176.  These
meager excerpts reflect at best congressional
intent to include state spendthrift trust law
within the meaning of  applicable nonbankruptcy
law.  By no means do they provide a sufficient
basis for concluding, in derogation of the statut-
e's clear language, that Congress intended to
exclude other state and federal law from the
provision's scope.
                       B
  Petitioner next contends that our construction
of 541(c)(2), pursuant to which a debtor may
exclude his interest in an ERISA-qualified pension
plan from the bankruptcy estate, renders 522(d)-
(10)(E) of the Bankruptcy Code superfluous.  Brief
for Petitioner 24-33.  Under 522(d)(10)(E), a
debtor who elects the federal exemptions set
forth in 522(d) may exempt from the bankruptcy
estate his right to receive  a payment under a
stock bonus, pension, profitsharing, annuity, or
similar plan or contract . . . , to the extent rea-
sonably necessary for the support of the debtor
and any dependent of the debtor.  If a debtor's
interest in a pension plan could be excluded in
full from the bankruptcy estate, the argument
goes, then there would have been no reason for
Congress to create a limited exemption for such
interests elsewhere in the statute.
  Petitioner's surplusage argument fails, howev-
er, for the reason that 522(d)(10)(E) exempts from
the bankruptcy estate a much broader category of
interests than 541(c)(2) excludes.  For example,
pension plans established by governmental enti-
ties and churches need not comply with Subchapter
I of ERISA, including the anti-alienation require-
ment of 206(d)(1).  See 29 U. S. C. 1003(b)(1) and
(2); 26 CFR 1.401(a)-13(a) (1991).  So, too, pension
plans that qualify for preferential tax treatment
under 26 U. S. C. 408 (individual retirement
accounts) are specifically excepted from ERISA's
anti-alienation requirement.  See 29 U. S. C.
1051(6).  Although a debtor's interest in these
plans could not be excluded under 541(c)(2)
because the plans lack transfer restrictions
enforceable under  applicable nonbankruptcy law,
that interest nevertheless could be exempted
under 522(d)(10)(E).  Once petitioner concedes
that 522(d)(10)(E)'s exemption applies to more
than ERISA-qualified plans containing anti-alien-
ation provisions, see Tr. of Oral Arg. 10-11; Brief
for Petitioner 31, his argument that our reading
of 541(c)(2) renders the exemption provision
superfluous must collapse.
                       C
  Finally, petitioner contends that our holding
frustrates the Bankruptcy Code's policy of ensur-
ing a broad inclusion of assets in the bankruptcy
estate.  See Brief for Petitioner 37; 11 U. S. C.
541(a)(1) (estate comprised of  all legal and
equitable interests of the debtor in property as
of the commencement of the case).  As an initial
matter, we think that petitioner mistakes an
admittedly broad definition of includable property
for a  policy underlying the Code as a whole.  In
any event, to the extent that policy consider-
ations are even relevant where the language of
the statute is so clear, we believe that our
construction of 541(c)(2) is preferable to the one
petitioner urges upon us.
  First, our decision today ensures that the
treatment of pension benefits will not vary based
on the beneficiary's bankruptcy status.  See
Butner v. United States, 440 U. S. 48, 55 (1978)
(observing that  [u]niform treatment of property
interests prevents  a party from `receiving a
windfall merely by reason of the happenstance of
bankruptcy,' quoting Lewis v. Manufacturers
National Bank, 364 U. S. 603, 609 (1961)).  We previ-
ously have declined to recognize any exceptions
to ERISA's anti-alienation provision outside the
bankruptcy context.  See Guidry v. Sheet Metal
Workers Pension Fund, 493 U. S. 365 (1990) (labor
union may not impose constructive trust on
pension benefits of union official who breached
fiduciary duties and embezzled funds).  Declining
to recognize any exceptions to that provision
within the bankruptcy context minimizes the
possibility that creditors will engage in strate-
gic manipulation of the bankruptcy laws in order
to gain access to otherwise inaccessible funds.
See Seiden, Chapter 7 Cases:  Do ERISA and the
Bankruptcy Code Conflict as to Whether a Debtor's
Interest in or Rights Under a Qualified Plan Can be
Used to Pay Claims?, 61 Am. Bankr. L.J. 301, 317
(1987) (noting inconsistency if  a creditor could
not reach a debtor-participant's plan right or
interest in a garnishment or other collection
action outside of a bankruptcy case but indirect-
ly could reach the plan right or interest by filing
a petition . . . to place the debtor in bankruptcy
involun-tarily).
  Our holding also gives full and appropriate
effect to ERISA's goal of protecting pension
benefits.  See 29 U. S. C. 1001(b) and (c).  This
Court has described that goal as one of ensuring
that  if a worker has been promised a defined
pension benefit upon retirement"and if he has
fulfilled whatever conditions are required to
obtain a vested benefit"he actually will receive
it.  Nachman Corp. v. Pension Benefit Guaranty
Corp., 446 U. S. 359, 375 (1980).  In furtherance of
these principles, we recently declined in Guidry,
notwithstanding strong equitable considerations
to the contrary, to recognize an implied exception
to ERISA's anti-alienation provision that would
have allowed a labor union to impose a construc-
tive trust on the pension benefits of a corrupt
union official.  We explained:

 Section 206(d) reflects a considered con-
gressional policy choice, a decision to safe-
guard a stream of income for pensioners (and
their dependents, who may be, and perhaps
usually are, blameless), even if that decision
prevents others from securing relief for the
wrongs done them.  If exceptions to this policy
are to be made, it is for Congress to under-
take that task.  493 U. S., at 376.

These considerations apply with equal, if not
greater, force in the present context.
  Finally, our holding furthers another important
policy underlying ERISA: uniform national treat-
ment of pension benefits.  See Fort Halifax Pack-
ing Co. v. Coyne, 482 U. S. 1, 9 (1987).  Construing
 applicable nonbankruptcy law to include federal
law ensures that the security of a debtor's
pension benefits will be governed by ERISA, not
left to the vagaries of state spendthrift trust
law.
                      IV
  In light of our conclusion that a debtor's inter-
est in an ERISA-qualified pension plan may be
excluded from the property of the bankruptcy
estate pursuant to 541(c)(2), we need not reach
respondent's alternative argument that his
interest in the Plan qualifies for exemption under
522(b)(2)(A).
  The judgment of the Court of Appeals is af-
firmed.

                             It is so ordered.

Concur
      SUPREME COURT OF THE UNITED STATES--------
             No. 91-913
              --------
JOHN R. PATTERSON, TRUSTEE, PETITIONER v.
            JOSEPH B. SHUMATE, Jr.
  on writ of certiorari to the united states
    court of appeals for the fourth circuit
                [June 15, 1992]

  Justice Scalia, concurring.
  The Court's opinion today, which I join, prompts
several observations.
  When the phrase  applicable nonbankruptcy law
is considered in isolation, the phenomenon that
three Courts of Appeals could have thought it a
synonym for  state law is mystifying.  When the
phrase is considered together with the rest of
the Bankruptcy Code (in which Congress chose to
refer to state law as, logically enough,  state
law), the phenomenon calls into question whether
our legal culture has so far departed from atten-
tion to text, or is so lacking in agreed-upon
methodology for creating and interpreting text,
that it any longer makes sense to talk of  a
government of laws, not of men.
  Speaking of agreed-upon methodology: It is good
that the Court's analysis today proceeds on the
assumption that use of the phrases  state law
and  applicable nonbankruptcy law in other
provisions of the Bankruptcy Code is highly
relevant to whether  applicable nonbankruptcy
law means  state law in 541(c)(2), since consis-
tency of usage within the same statute is to be
presumed.  Ante, at 4-5, and n. 2.  This application
of a normal and obvious principle of statutory
construction would not merit comment, except that
we explicitly rejected it, in favor of a one-sub-
section-at-a-time approach, when interpreting
another provision of this very statute earlier
this Term.  See Dewsnup v. Timm, ___ U. S. ___, ___
(slip op., at 6-7); id., at ___ (slip op., at 1-4)
(Scalia, J. dissenting).   [W]e express no opinion,
our decision said,  as to whether the words [at
issue] have different meaning in other provisions
of the Bankruptcy Code.  Id., at 7, n. 3.  I trust
that in our search for a neutral and rational
interpretive methodology we have now come to
rest, so that the symbol of our profession may
remain the scales, not the see-saw.
