With no explanation, chose the best option from "A", "B", "C" or "D". by the Court that was quickly rectified. After Helvering, the Supreme Court relied on Radford in a decision only once in the next 17 years, and that was for the proposition that lien rights constitute a property interest protected by the Fifth Amendment— not for the idea that liens ride through bankruptcy unaffected. Armstrong v. United States, 364 U.S. 40, 44, 80 S.Ct. 1563, 1566, 4 L.Ed.2d 1554 (1960). Twenty-two more years would pass before a majority of the Supreme Court again relied on Radford, also for the proposition that there are Fifth Amendment limitations on the extent to which the bankruptcy statutes can “be used to defeat traditional property interests,” like lien rights. United States v. Security Industrial Bank, 459 U.S. 70, 74, 103 S.Ct. 407, 410, 74 L.Ed.2d 235 (1982) (<HOLDING>). In Ahlers, supra, Justice White notes that

A: holding that subsequent acts cannot be applied retroactively to the bioc analysis
B: holding that the 2000 version of section 489128 may not be retroactively applied
C: holding that the debtor must have had an interest in the property before the lien attached to take advantage of  522f
D: holding that consumer lien avoidance powers of section 522f cannot be applied retroactively
D.