context: Although the United States Court of Appeals for the Fourth Circuit has not yet addressed ERISA's preemptive effects on state exemption statutes like Virginia's, several other circuits have. The majority of those circuits have held that ERISA's savings clause precluded preemption of state exemption statutes.
citation_a.signal: see also
citation_a.identifier: 275 F.3d 604, 605
citation_a.parenthetical: acknowledging that exemption statutes dealing with IRAs are outside ERISA's scope and therefore not preempted
citation_a.sentence: See also In re Weinhoeft, 275 F.3d 604, 605 (7th Cir.2001) (acknowledging that exemption statutes dealing with IRAs are outside ERISA’s scope and therefore not preempted).
citation_b.signal: but cf.
citation_b.parenthetical: finding that ERISA's savings clause did not save Arizona exemption statute from preemption
citation_b.sentence: But cf. Pitrat v. Garlikov, 947 F.2d 419 (9th Cir.1991), withdrawn, 992 F.2d 224 (9th Cir.1993) (finding that ERISA’s savings clause did not save Arizona exemption statute from preemption).