In Frederick v. Lines, subsequently affirmed in a memorandum decision by the Supreme Court, the Ninth Circuit determined that title to a bankrupts accrued vacation pay significantly affects the bankrupt's ability to make an unencumbered fresh start, and therefore should not vest in the trustee.
Lee A. Chilcote,
Title to Accrued Vacation Pay: The Bankrupt's or the Trustee's in Bankruptcy,
22 Hastings L.J. 846
Available at: https://repository.uchastings.edu/hastings_law_journal/vol22/iss4/2