Do I.R.A.'s Have Protection in Bankruptcy Proceeding?

The New York Times: "Colli C. McKiever, the lawyer representing Jill R. Jacoway, the trustee appointed to oversee the Rouseys' affairs and pay off their creditors, said that 'unfettered access' to an I.R.A. made it 'much more like a savings account' than a retirement plan. Savings accounts are not shielded from creditors in a bankruptcy."