JOHNSON, Circuit Judge:
In 1987, the Texas legislature enacted a statute — now codified in section 42.0021(a) of the Texas Property Code — which exempts retirement benefits from the claims of creditors. In these consolidated cases, this Court must determine whether the Employee Retirement Income Security Act of 1974 ("ERISA"), which one court has described as a "quicksand [that] is fast swallowing up everything that steps in it or near it,"
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