In re Eilbert , 162 F.3d 523, 526 (8th Cir. 1998) (citations omitted). See alsoIn re Helming , 567 B.R. 357, 361 (B.A.P. 8th Cir. 2017) ("[A] bankruptcy court must be careful to not substantially depart from the express language of the exemption or to extend the legislative grant as expressed by Congress.") (citations and internal quotation marks omitted).Mo. Rev. Stat. ยง 513.430.1(10)(e)
; see also Acreback v. Myer, 65 S.W. 1015, 1016 (Mo. 1901) (applying plain language of homestead exemption). Although "[e]xemption laws are to be liberally construed," bankruptcy courts "must be careful not to substantially depart from the express language of the exemption or to extend the legislative grant as expressed by Congress." In re Helming, 567 B.R. 357, 360-61 (B.A.P. 8th Cir. 2017) (cleaned up).