Church plans and bankruptcy actions

[Guest brugamam]

I have been researching the issue of what is included in a debtor's bankruptcy estate as far as non-ERISA plans are concerned. I have been unable to find any authority dealing with church plan assets, however. I was wondering if anyone has any insight into how courts (specifically Michigan/6th Circuit Courts) will handle inclusion of a debtor's retirement plan assets.

My understanding is that, under Patterson v. Shumate, whether a debtor's retirement plan assets will be excluded from the bankruptcy estate under 11 U.S.C. 541©(2) is based on state OR federal law that clearly provides an anti-alienation provision, which Michigan apparently does not have in regard to church plans. My final determination, based on many factors, is that church plans must be included in the debtor's estate. I would really appreciate any information or authority to the contrary.

Thanks!