In Jones v. Carpenter, 90 Fla. 407, 106 So. 127 (Fla. 1925), the Court allowed the trustee of a bankrupt bread company to have an equitable lien against the homestead of its former president where the former president embezzled corporate funds to make improvements on his homestead. The Court concluded that the trustee's claims fell within the exceptions to the exemption: "The funds involved in this litigation were all spent for labor and improvements on the house which appellee seeks to exempt and are clearly within the qualifications to his homestead as above enumerated." Jones, 106 So. at 130. The Court employed the doctrine of equitable subrogation to accommodate the trustee's claim within the exceptions to the exemption: "Appellant, who steps into the shoes of the bread company, cannot follow said funds or materials into Carpenter's home and recover them, they having been so converted, but he can subject the home to the repayment or restoration of said funds." Id.