OPINION

MINGE, Judge.

Appellant challenges the district court's denial of his claim that funds he received in settlement of a personal-injury claim are exempt from garnishment. We affirm.

FACTS

In 2006, respondent Midland Credit Management (Midland) obtained a money judgment against appellant Eldridge Chatman. In 2008, Chatman suffered personal injuries and commenced a lawsuit. In 2009, Chatman settled the lawsuit and deposited the settlement proceeds into his bank account. In 2010, Midland garnished Chatman's bank account. In response to the garnishment, Chatman filed a notice of exemption, asserting that because the money in the account constituted proceeds of the personal injury settlement, it represented "[r]ights of action for injuries to the person of the debtor" and was exempt from creditors' claims under Minn.Stat. § 550.37, subd. 22. Midland objected to the exemption claim. The district court determined that personal-injury-settlement proceeds are not exempt. This appeal follows.

ISSUE

Does Minn.Stat. § 550.37, subd. 22 exempt proceeds from the settlement of a personal-injury action from creditor claims?

ANALYSIS

This court reviews de novo questions of statutory interpretation. Molde v. CitiMortgage, Inc., 781 N.W.2d 36, 39 (Minn.App.2010). Words and phrases are interpreted according to their common meaning. Minn.Stat. § 645.08 (2010); ILHC of Eagan, LLC v. County of Dakota, 693 N.W.2d 412, 419 (Minn.2005). "Where the legislature's intent is clearly discernable from plain and unambiguous language, statutory construction is neither necessary nor permitted and we apply the statute's plain meaning." Hans Hagen Homes, Inc. v. City of Minnetrista, 728 N.W.2d 536, 539 (Minn.2007); see also Minn.Stat. § 645.16 (2010) (directing that, when the language of a statute is "clear and free from all ambiguity, the letter of the law shall not be disregarded under the pretext of pursuing the spirit").

The Minnesota statutes identify certain property that is "not liable to attachment, garnishment, or sale on any final process, issued from any court." Minn.Stat. § 550.37, subd. 1 (2010). Included among exempt property are

Minn.Stat. § 550.37, subd. 22. The issue in this appeal is whether this statutory language exempts identifiable proceeds of the settlement of a personal-injury claim. The term "right of action" generally is understood to mean "[t]he right to bring a specific case to court" or "[a] right that can be enforced by legal action; a chose in action." Black's Law Dictionary 1438 (9th ed.2009).1

Certain subdivisions of the exemption section include proceeds and payments that are traceable to exempt sources. See, e.g., Minn.Stat. § 550.37, subd. 9 (2010) (exempting "[a]ll money arising from any claim on account of the destruction of, or damage to, exempt property") (emphasis added); subd. 24 (2010) (exempting "right to receive present or future payments, or payments received by the debtor," under specified retirement plans) (emphasis added); subd. 25 (2010) (exempting "[p]roceeds of payments received by a person for labor, skill, material, or machinery contributing to an improvement to real estate") (emphasis added). And another subdivision expressly protects proceeds covered by certain exemptions following their deposit into an account at a bank or other financial institution "if the funds are traceable to their exempt source." Id., subd. 20 (2010). Monies recovered for personal injuries are not covered by any of these Minnesota exemptions. These and other highly specific provisions of the law indicate that, had the legislature intended to exempt not just rights of action for personal injuries, but the subsequent recovery and retention of money received for those personal injuries, it could have easily stated that. Christians v. Dulas, 95 F.3d 703, 705 (8th Cir.1996).2

Although not binding on this court, federal court analysis informs our consideration of the issue.3 We note that the federal bankruptcy court in Minnesota "has consistently construed [Minnesota's statutory exemption for] `rights of action' as referring only to pending or future claims." In re Procter, 186 B.R. 466, 468 (Bankr.D.Minn.1995); cf. Christians, 95 F.3d at 704 (holding that payments from annuity created pursuant to settlement agreement are not exempt, explaining that "[t]he statute exempts rights of action, not rights of payment"). In one of its decisions, the bankruptcy court explained the difference between a right of action and the proceeds from the settlement of an action:

In re Gagne, 163 B.R. 819, 823 (Bankr. D.Minn.1994).

Chatman asserts that the bankruptcy-court decisions are inapposite because of the setting in which they were decided. In federal bankruptcy proceedings, exemption issues arise when a debtor elects to claim state (as opposed to federal) exemptions for the purpose of determining what will be included as property of the bankruptcy estate. See 11 U.S.C. § 522(b)(2) (allowing choice of exemptions); see also In re Carlson, 40 B.R. 746, 749 (Bankr. D.Minn. 1984) (summarizing 1979 amendment of federal bankruptcy code to allow debtors to elect state or federal exemptions). Chatman asserts that, in this unique bankruptcy context, bankruptcy court decisions are distinguishable because the exemption determinations are made at the beginning of the proceeding, rather than after judgment, as in collection proceedings. We disagree; nothing in the bankruptcy court's analysis of the plain language of the exemption relies on the procedural posture in which the analysis is being made.

Chatman also argues that exempting his personal-injury-settlement proceeds would comport with the general purpose of statutory exemptions-"to protect a debtor and his family against absolute want by allowing them out of his property some reasonable means of support and education and the maintenance of the decencies and proprieties of life." Medill, 477 N.W.2d at 708 (quotation omitted). We agree that in Medill, the supreme court did laud the "[e]xemption provisions['] protect[ion of] fundamental needs by limiting the assets available for distribution to creditors," and noted that in that proceeding the application of these policies had the effect of exempting a personal injury right of action. Medill, 477 N.W.2d at 708. The Medill court did not, however, hold that personal-injury proceeds are exempt.

DECISION

Because Minn.Stat. § 550.37, subd. 22, does not exempt from creditor claims, including garnishment, proceeds from a personal-injury settlement, we affirm the district court's order denying Chatman's exemption claim.

Affirmed.