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Federal Charges · Federal Forfeiture

Federal forfeiture defense

Federal forfeiture matters in Texas carry consequences that turn on the specific facts, the county, and the record that follows you afterward. The collateral consequences — employment, professional licensing, housing — often outlast the sentence itself. L and L Law Group defends these cases across Collin, Denton, Dallas, and Tarrant Counties.

Federal asset forfeiture in the Northern and Eastern Districts of Texas runs on three parallel tracks — criminal forfeiture under 18 U.S.C. § 982 and 21 U.S.C. § 853 as part of the criminal judgment, civil forfeiture under 18 U.S.C. § 981 as an in rem proceeding against the property itself, and administrative forfeiture under 19 U.S.C. §§ 1607-1610 for uncontested seizures under threshold values. After Honeycutt, Luis, Kaley, Timbs, and Good, the forfeiture statutes have been substantially narrowed; defense work happens at the intersection of nexus, ownership, due-process notice, and constitutional-proportionality attacks.

Federal forfeiture: Texas punishment ranges at a glance
Offense levelConfinementMax finePenal Code
Class A misdemeanorUp to 1 year, county jail$4,000§12.21
Third-degree felony2 – 10 years, TDCJ$10,000§12.34
Second-degree felony2 – 20 years, TDCJ$10,000§12.33

Ranges per Tex. Penal Code ch. 12. Enhancements, deadly-weapon findings, and prior convictions can raise the applicable range; some offenses carry their own special ranges.

15 min read 3,500 words Reviewed May 17, 2026 By Reggie London
Direct Answer

Federal asset forfeiture runs on three tracks: criminal forfeiture under 18 U.S.C. § 982 and 21 U.S.C. § 853 as part of a criminal judgment, civil forfeiture under 18 U.S.C. § 981 as an in rem proceeding against the property, and administrative forfeiture under 19 U.S.C. §§ 1607-1610 as a non-judicial agency procedure for uncontested seizures up to $500,000. Civil forfeiture is governed by the Civil Asset Forfeiture Reform Act of 2000 (CAFRA), codified at 18 U.S.C. § 983 — raising the government's burden to preponderance, codifying the innocent-owner defense at § 983(d), and establishing a constitutional proportionality limit at § 983(g) under the Eighth Amendment Excessive Fines Clause. Modern forfeiture defense centers on Honeycutt v. United States, 581 U.S. 443 (2017) (no co-conspirator joint-and-several liability), Luis v. United States, 578 U.S. 5 (2016) (no pretrial restraint of untainted counsel-fee assets), Kaley v. United States, 571 U.S. 320 (2014) (pretrial probable-cause hearing scope), Timbs v. Indiana, 586 U.S. 146 (2019) (Excessive Fines incorporation), and United States v. James Daniel Good Real Property, 510 U.S. 43 (1993) (due-process notice requirements). The 35-day verified-claim deadline under § 983(a)(2)(B) is the most time-sensitive defense action — missing it converts the property to default administrative forfeiture with only narrow post-default review available.

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Key Takeaways
  • Three tracks — criminal forfeiture under § 982 + Rule 32.2 (part of the criminal judgment), civil forfeiture under § 981 + CAFRA § 983 (in rem against the property), administrative forfeiture under 19 U.S.C. § 1607 (non-judicial agency forfeiture, $500,000 limit).
  • Honeycutt (2017) — criminal forfeiture limited to property the individual defendant actually acquired; joint-and-several co-conspirator forfeiture is no longer permitted.
  • Luis (2016) — Sixth Amendment bars pretrial restraint of untainted assets the defendant needs to retain counsel of choice.
  • CAFRA (2000) — government burden raised to preponderance; innocent-owner defense codified at § 983(d); proportionality defense codified at § 983(g); 90-day government complaint deadline; counsel for indigent claimants in residence cases.
  • 35-day claim deadline — administrative-forfeiture verified claim must be filed within 35 days of personal notice or 30 days of final publication or the property is forfeit by default.
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Texas Legal Context

What the statute actually requires

Analytical framework Federal asset forfeiture is a specialty within federal criminal practice — three parallel tracks (criminal under § 982 / § 853, civil under § 981 / CAFRA § 983, administrative under 19 U.S.C. § 1607) governed by overlapping statutes, the Sixth Amendment counsel-of-choice doctrine (Luis), the Eighth Amendment Excessive Fines Clause (Timbs), and CAFRA's 2000 procedural reforms. The defense work happens at the intersection of nexus tracing, innocent-owner status, due-process notice, and constitutional-proportionality challenges. The most consequential modern decision is Honeycutt v. United States, 581 U.S. 443 (2017), which ended joint-and-several co-conspirator criminal forfeiture and reshaped conspiracy-forfeiture practice across all federal districts.
5 Texas-specific insights
  1. Honeycutt ended joint-and-several co-conspirator forfeiture. Before Honeycutt v. United States, 581 U.S. 443 (2017), federal prosecutors routinely sought joint-and-several criminal forfeiture against all co-conspirators for the full proceeds of a conspiracy. The Supreme Court unanimously rejected the practice: 21 U.S.C. § 853(a)(1) limits forfeiture to property the individual defendant actually acquired. Low-level participants, salaried employees, family members, and minor co-conspirators no longer face forfeiture orders for proceeds they never received. The decision applies retroactively to non-final cases and has reshaped sentencing-phase forfeiture practice across every federal district.
  2. Luis protects untainted assets needed for counsel of choice. Luis v. United States, 578 U.S. 5 (2016), drew the Sixth Amendment line at untainted assets — property unconnected to the alleged offense cannot be pretrial-restrained when the defendant needs it to retain counsel of choice. The decision distinguished Caplin & Drysdale (tainted-asset restraint permitted) and Kaley (no relitigation of grand-jury probable cause). Defense practice traces each restrained asset back to its source; assets with non-criminal origins must be released to support the Sixth Amendment right to counsel. Forensic accountants typically develop the tracing record in commingled-account cases.
  3. CAFRA shifted the burden and codified defenses. The Civil Asset Forfeiture Reform Act of 2000 (CAFRA), codified at 18 U.S.C. § 983, was the most significant federal forfeiture reform in modern practice. CAFRA raised the government's civil-forfeiture burden from probable cause to preponderance of the evidence (§ 983(c)); codified the innocent-owner defense (§ 983(d)); created the 90-day government-complaint deadline after a verified claim (§ 983(a)(3)); authorized appointment of counsel for indigent claimants whose primary residence is at stake (§ 983(b)); permitted hardship-release of seized property pending forfeiture (§ 983(f)); and codified an Eighth-Amendment proportionality defense (§ 983(g)). CAFRA does not apply to customs forfeiture under Title 19 or to administrative forfeiture under § 1607.
  4. The 35-day administrative-claim deadline is the single most-missed defense action. Under 18 U.S.C. § 983(a)(2)(B), a claimant in administrative forfeiture has 35 days from personal notice (or 30 days from final publication) to file a verified claim with the seizing agency. Missing the deadline results in default forfeiture with only narrow post-default review under § 983(e). The deadline is statutory and largely unforgiving — claimants who assume informal negotiation will resolve the matter, or who underestimate the strict verification requirements, regularly lose the property by default. Retain federal forfeiture counsel within days of notice receipt, not weeks.
  5. Timbs and Bajakajian created constitutional proportionality limits. Timbs v. Indiana, 586 U.S. 146 (2019), incorporated the Eighth Amendment Excessive Fines Clause against the states through the Fourteenth Amendment. United States v. Bajakajian, 524 U.S. 321 (1998), established that forfeitures are subject to constitutional proportionality review under the Excessive Fines Clause. CAFRA § 983(g) codifies the proportionality defense for civil forfeiture — claimants may petition the court to find that the forfeiture is grossly disproportional to the gravity of the offense, with mandatory reduction or elimination if proportionality is found lacking. The defense is most powerful in structured-cash, low-level money-laundering, and reporting-statute cases under 31 U.S.C. § 5324.
  6. Good v. James Daniel Good Real Property imposed pre-seizure due-process notice. United States v. James Daniel Good Real Property, 510 U.S. 43 (1993), held that the Fifth Amendment Due Process Clause requires pre-seizure notice and an opportunity to be heard before the government seizes real property in civil forfeiture — except in exigent circumstances. The decision distinguished real property from movable property (cash, vehicles), where pre-seizure notice could enable concealment or transfer. The defense applies in any federal civil forfeiture targeting real estate, and post-seizure due-process challenges remain available where the seizing agency failed to provide adequate notice. Krimstock v. Kelly, 306 F.3d 40 (2d Cir. 2002), extended due-process scrutiny to vehicle seizures in a parallel state-law context.

The federal forfeiture framework — criminal, civil, and administrative tracks

Federal asset forfeiture is not one proceeding — it is three distinct tracks that the government chooses among or runs in parallel. Criminal forfeiture under § 982 is part of the criminal judgment; civil forfeiture under § 981 runs against the property itself; administrative forfeiture under § 1607 forfeits uncontested seizures with no court filing at all.

Criminal Forfeiture (18 U.S.C. § 982 / 21 U.S.C. § 853)
An in personam forfeiture imposed as part of a criminal judgment. Requires a conviction (verdict or plea) on the underlying offense. Reaches property constituting or derived from proceeds, property involved in the offense, and substitute assets under § 853(p). Procedural mechanics governed by Federal Rule of Criminal Procedure 32.2. After Honeycutt v. United States, 581 U.S. 443 (2017), the forfeiture reaches only property the individual defendant actually acquired — joint-and-several co-conspirator liability is no longer permitted. Third-party claims are litigated in an ancillary proceeding under § 853(n) after entry of the preliminary order of forfeiture.
Civil Forfeiture (18 U.S.C. § 981 + CAFRA § 983)
An in rem proceeding brought directly against the property. Requires no criminal conviction. The government must prove by a preponderance of the evidence (raised from probable cause by CAFRA in 2000) that the property is connected to specified unlawful activity. Procedure governed by the Supplemental Rules for Admiralty and Maritime Claims and Asset Forfeiture Actions (Rules G). Innocent-owner defenses under § 983(d) are available; counsel may be appointed for indigent claimants under § 983(b) where the primary residence is at stake; hardship release is available under § 983(f); proportionality defense under § 983(g) implements the Timbs Eighth-Amendment limit.
Administrative Forfeiture (19 U.S.C. §§ 1607-1610)
A non-judicial forfeiture by the seizing agency itself — DEA, FBI, ICE, ATF, U.S. Customs and Border Protection. Available for monetary instruments of any value, conveyances used in customs offenses, and other property appraised at $500,000 or less. The agency publishes notice and provides personal written notice; if no person files a timely verified claim under 18 U.S.C. § 983(a)(2) (35 days from personal notice or 30 from final publication), the property is administratively forfeited by default without any court involvement at all. A timely verified claim moves the case into a CAFRA civil forfeiture proceeding.
Equitable Sharing / Adoptive Forfeiture
The federal forfeiture regime interacts with state and local law enforcement through equitable sharing under 21 U.S.C. § 881(e). State agencies seize property under state authority and refer it to federal adoption; the federal agency adopts the seizure and forfeits the property under federal law, returning up to 80% of the net proceeds to the originating state or local agency. The 2015 and 2017 DOJ policy changes restricted adoptive forfeiture, but the practice continues in narcotics, money-laundering, and customs cases. For claimants, federal adoption converts a state forfeiture into a CAFRA proceeding with the federal burden of proof and the innocent-owner defense.

The choice among these tracks is a prosecutorial decision that turns on three variables — whether there is a charged defendant, whether the government intends to pursue a criminal conviction, and the value and type of the property at issue. Criminal forfeiture requires a defendant and a conviction; civil forfeiture requires neither but exposes the government to claimant litigation; administrative forfeiture is the cheapest and fastest track but limited by statute to property under $500,000 (with the customs and monetary-instrument exceptions). Federal prosecutors frequently run all three tracks against the same defendant in parallel — criminal forfeiture in the indictment, civil forfeiture against related property held by third parties, and administrative forfeiture against seized cash that the claimant chooses not to contest.

Defense strategy depends fundamentally on identifying which track applies and where the leverage points sit. In criminal forfeiture, the leverage is at sentencing — third-party ancillary proceedings under § 853(n), Honeycutt-based limits on co-conspirator liability, and substitute-asset disputes under § 853(p). In civil forfeiture, the leverage is at the claim-filing stage — innocent-owner defenses under § 983(d), the government's preponderance burden, hardship-release motions under § 983(f), and the 90-day statutory deadline for the government to file its forfeiture complaint after a verified claim under § 983(a)(3). In administrative forfeiture, the leverage is the claim deadline itself — file a verified claim within the statutory window and the case moves into CAFRA civil forfeiture; miss the deadline and the property is forfeit with no further recourse beyond a narrow due-process petition under § 983(e).

Criminal forfeiture under § 982 and Rule 32.2

Criminal forfeiture under 18 U.S.C. § 982 is an in personam sentencing component governed by Federal Rule of Criminal Procedure 32.2. The forfeiture order requires a conviction, reaches the individual defendant's tainted proceeds (Honeycutt), and exposes substitute assets when traceable proceeds are unavailable.

Criminal forfeiture under 18 U.S.C. § 982 operates as part of the criminal judgment in any federal prosecution where the underlying statute authorizes forfeiture. The most heavily-used predicates are § 982(a)(1) for money-laundering offenses (1956, 1957, 1960); § 982(a)(2) for offenses affecting financial institutions (1341, 1343, 1344); § 982(a)(7) for federal healthcare offenses (1347, 1349); and § 982(b)(1), which incorporates by reference the procedural framework of 21 U.S.C. § 853 — the drug-forfeiture statute that supplies the operative procedural rules for almost all federal criminal forfeiture.

The procedural choreography runs through Federal Rule of Criminal Procedure 32.2. The indictment or information must include a forfeiture allegation (Rule 32.2(a)) — failure to do so is generally fatal under Libretti v. United States, 516 U.S. 29 (1995), although some courts permit late amendment. After a conviction (verdict or plea), the court determines forfeiture by special verdict (Rule 32.2(b)(5)) — the jury decides whether the government has shown the required nexus between the property and the offense. The defendant's standing to contest is generally limited to property in which he claims an ownership interest. Third parties are excluded from the criminal proceeding; their interests are litigated in an ancillary proceeding under § 853(n) after entry of the preliminary forfeiture order.

Three categories of property are reachable. First, proceeds — property constituting or derived from any proceeds the defendant obtained directly or indirectly as a result of the offense. The "proceeds" definition under § 981(a)(2) is the gross-receipts rule for most general offenses, the net-profits rule for unlawful activities (a controlled-substance offense, for example), and a hybrid for certain categories. Second, facilitating property — property used to commit or facilitate the offense (most relevant in drug, money-laundering, and child-exploitation cases). Third, substitute assets under § 853(p) — when the proceeds have been transferred, dissipated, commingled, hidden, or otherwise placed beyond the reach of the court, the government may forfeit untainted property of equivalent value as substitute. The substitute-asset provision converts criminal forfeiture into a money-judgment-style remedy where the original tainted property cannot be located.

After Honeycutt v. United States, 581 U.S. 443 (2017), the reach of criminal forfeiture is meaningfully narrower than it was for the preceding three decades. Honeycutt involved two brothers convicted of conspiracy to sell iodine — a methamphetamine precursor — out of their hardware store. The government sought joint-and-several criminal forfeiture against both for the full $269,000 in proceeds the conspiracy generated, even though the convicted brother (Terry Honeycutt) was a salaried employee who received no proceeds beyond his wages. The Supreme Court unanimously rejected the joint-and-several theory: § 853(a)(1) limits forfeiture to property the individual defendant "obtained, directly or indirectly, as the result of" the violation. A defendant who did not himself acquire tainted proceeds cannot be ordered to forfeit them. Honeycutt transformed forfeiture defense in conspiracy cases — particularly for low-level participants, salaried employees, and family members who shared none of the conspiracy's economic benefit.

Civil forfeiture under § 981 and CAFRA procedure

Civil forfeiture under 18 U.S.C. § 981 is an in rem proceeding against the property itself, governed by CAFRA at 18 U.S.C. § 983. The government must prove a connection to specified unlawful activity by a preponderance of the evidence; innocent-owner defenses, hardship release, and Eighth-Amendment proportionality challenges are all codified.

Civil forfeiture under 18 U.S.C. § 981 reaches property connected to "specified unlawful activity" as defined in § 1956(c)(7) — a long list of federal predicates that includes virtually every federal fraud, narcotics, money-laundering, public-corruption, and tax offense. The proceeding is in rem against the property itself, captioned United States v. [Property Description] — for example, United States v. $58,920 in U.S. Currency. The proceeding requires no criminal conviction; the government can pursue civil forfeiture against property even when the criminal case is dismissed, the defendant is acquitted, or no person is ever charged at all.

Procedure is governed by the Civil Asset Forfeiture Reform Act of 2000, codified principally at 18 U.S.C. § 983, and by the Supplemental Rules for Admiralty or Maritime Claims and Asset Forfeiture Actions (Rules G). CAFRA was the most significant federal forfeiture reform of the modern era. It raised the government's burden of proof from probable cause to preponderance of the evidence (§ 983(c)); codified the innocent-owner defense (§ 983(d)); created the 90-day statutory deadline for the government to file its forfeiture complaint after a verified claim is filed (§ 983(a)(3)); authorized appointment of counsel for indigent claimants whose primary residence is at stake (§ 983(b)); permitted hardship-release of seized property pending forfeiture (§ 983(f)); and codified an Eighth-Amendment proportionality defense (§ 983(g)).

The procedural sequence is rigid and unforgiving. After seizure, the seizing agency provides notice to known interest-holders and publishes notice for unknown claimants. A potential claimant must file a verified claim within the statutory deadline — 35 days from personal notice or 30 days from final publication under § 983(a)(2)(B). Failure to file a timely verified claim results in default and administrative forfeiture under § 1607 (for property within the administrative threshold). Once a verified claim is filed, the government has 90 days under § 983(a)(3)(A) to file a civil forfeiture complaint or release the property. After the complaint is filed, the claimant must file an answer within 20 days (Rule G(5)(b)). The case then proceeds through discovery, motion practice (especially motions to dismiss for failure to allege a sufficient nexus or for due-process notice defects), summary judgment, and trial.

The innocent-owner defense under § 983(d) is the principal substantive defense in civil forfeiture against pre-existing owners who can prove they were unaware of the connection to unlawful activity or, on becoming aware, took reasonable steps to terminate the use. The defense applies differently to interests acquired before the unlawful conduct (the "knowledge" prong under § 983(d)(2)) versus interests acquired after (the "bona fide purchaser for value" prong under § 983(d)(3)). The burden of proving innocent-owner status rests on the claimant by a preponderance of the evidence under § 983(d)(1). The defense applies to all civil forfeitures under any federal statute under § 983(d)(6), with limited exceptions for narcotics and contraband.

Administrative forfeiture under § 1607 — the no-court-filing track

Administrative forfeiture under 19 U.S.C. §§ 1607-1610 is a non-judicial procedure by which the seizing agency forfeits property without any court involvement — provided no person files a timely verified claim. It is limited to monetary instruments, customs conveyances, and other property valued at $500,000 or less.

Administrative forfeiture is the most-used federal forfeiture track by volume, accounting for the majority of all federal forfeiture proceedings. Under 19 U.S.C. §§ 1607-1610 (incorporated into the modern forfeiture regime by 19 U.S.C. § 1602 and the various agency-specific forfeiture statutes), the seizing agency itself — DEA, FBI, ICE/Homeland Security Investigations, ATF, U.S. Postal Inspection Service, or U.S. Customs and Border Protection — declares property forfeit by administrative declaration. No civil complaint is filed; no federal judge is involved; the proceeding takes place entirely within the seizing agency.

Administrative forfeiture is available only for property within statutory limits: monetary instruments of any value (cash, traveler's checks, money orders, certain financial instruments under 31 U.S.C. § 5312); conveyances used to import, export, transport, or store any merchandise the importation of which is prohibited (the customs-specific exception); and other property with an appraised value not exceeding $500,000 (raised from earlier lower thresholds). Real property is never subject to administrative forfeiture — real estate must always go through judicial civil forfeiture under § 981. Property of a value above the statutory threshold must also be referred for judicial proceedings.

The procedural sequence begins with the seizure. The seizing agency must publish notice of the seizure for at least 30 consecutive days (or post on an official forfeiture website for the modern equivalent under the Internet-Notice provisions) and provide personal written notice to any person known to have an interest in the property. After receipt of personal notice, the claimant has 35 days under 18 U.S.C. § 983(a)(2)(B) to file a verified claim with the seizing agency asserting an interest in the property. Where notice is published rather than personally served, the deadline is 30 days from the date of final publication.

The verified claim must satisfy specific statutory requirements: it must (1) identify the specific property being claimed, (2) state the claimant's interest in the property, and (3) be made under oath subject to penalty of perjury. A claim that does not meet the verification requirements may be rejected as procedurally defective and forfeiture proceeds by default. If a timely verified claim is filed, the case is removed from the administrative track and the government must either file a judicial civil forfeiture complaint within 90 days under § 983(a)(3)(A) or release the property. If no timely verified claim is filed, the agency issues a declaration of forfeiture and the property is forfeit to the United States. Post-default review is available only on narrow grounds under § 983(e) — typically defective notice or lack of actual notice — and the motion to set aside must be filed within five years of the date of the final notice of forfeiture.

Defense strategy under Honeycutt, Luis, and CAFRA

Modern federal forfeiture defense is organized around a suite of Supreme Court and statutory limits: Honeycutt (co-conspirator forfeiture), Luis (untainted pretrial restraint), Kaley (probable-cause hearing), Timbs (excessive fines), Good (due-process notice), and the CAFRA innocent-owner / proportionality defenses under § 983(d) and § 983(g).

The Honeycutt defense is the most consequential modern limit on criminal forfeiture. In any conspiracy case under § 982 or § 853, the defense scrutinizes the government's forfeiture allegation to determine whether it seeks recovery against the individual defendant for proceeds the defendant himself acquired or for proceeds acquired by co-conspirators. Where the indictment seeks joint-and-several recovery — or where the government's evidence shows the defendant was a salaried participant who received no proceeds beyond ordinary wages — the defense moves to limit the forfeiture to the defendant's individual share under Honeycutt. The motion is routinely successful for low-level participants, family members, and salaried employees who shared none of the conspiracy's economic benefit.

The Luis defense applies at the pretrial stage when the government has restrained assets the defendant needs to retain counsel. The Supreme Court in Luis v. United States, 578 U.S. 5 (2016), distinguished tainted from untainted assets: tainted assets (traceable to the offense) can be pretrial-restrained under Caplin & Drysdale v. United States, 491 U.S. 617 (1989), and United States v. Monsanto, 491 U.S. 600 (1989), but untainted assets cannot. The defense traces the restrained assets back to their source. Where the government cannot establish tainted-origin tracing for some portion of the restrained assets, the defense moves to release that portion for use in retaining counsel. The motion requires careful tracing work, often involving forensic accountants, and is most powerful in long-running fraud cases where the defendant had substantial legitimate income before or alongside the alleged offense.

The Kaley hearing is the pretrial probable-cause challenge to restraint. Under Kaley v. United States, 571 U.S. 320 (2014), a defendant may not relitigate the grand jury's probable-cause determination on the underlying offense, but may litigate the traceability of the restrained property to the alleged offense. The hearing is governed by 21 U.S.C. § 853(e) and § 853(f) for restraining orders and warrants of seizure. In the Fifth Circuit, the practical scope of Kaley hearings varies considerably by district and by judge — N.D. Texas and E.D. Texas magistrates generally entertain traceability challenges but rarely the broader probable-cause inquiries that the Sixth Amendment in Luis arguably contemplates.

The CAFRA innocent-owner defense under § 983(d) protects pre-existing and post-acquisition owners who lacked knowledge of the property's connection to unlawful activity. The defense applies to all civil forfeitures with limited statutory exceptions; it does not apply to criminal forfeiture (where third-party rights are litigated in the § 853(n) ancillary proceeding under different standards). The burden of proof rests on the claimant by a preponderance of the evidence. The defense is fact-intensive and often dispositive in real-estate forfeitures involving family members, in cash forfeitures involving spouses or business partners, and in vehicle forfeitures involving lenders or lessors. Documentary evidence — bank records, property records, communication records, business records — supports the knowledge-or-no-knowledge analysis.

The Timbs proportionality defense under § 983(g) implements the Eighth Amendment's Excessive Fines Clause. Timbs v. Indiana, 586 U.S. 146 (2019), held that the Excessive Fines Clause is incorporated against the states through the Fourteenth Amendment, and the Supreme Court in United States v. Bajakajian, 524 U.S. 321 (1998), established that forfeitures are subject to constitutional proportionality review. CAFRA § 983(g) codifies the defense for civil forfeiture: a claimant may petition the court to find that the forfeiture is grossly disproportional to the gravity of the offense; if the court so finds, it must reduce or eliminate the forfeiture. The factors are essentially the Bajakajian factors — the relationship of the property to the offense, the gravity of the offense, the harm caused, and the available statutory penalties. The defense applies most powerfully in cases involving structured-cash seizures, low-level money-laundering charges, and reporting-statute violations under 31 U.S.C. § 5324.

Pretrial restraint and the Luis / Kaley framework

Pretrial restraint of assets under § 853(e) freezes property the government alleges is forfeitable before any criminal trial. The Sixth Amendment line from Luis protects untainted assets needed for counsel of choice; Kaley governs probable-cause hearings for tainted assets; Caplin & Drysdale permits the underlying restraint regime.

Pretrial asset restraint is one of the most aggressive tools in the federal forfeiture arsenal. Under 21 U.S.C. § 853(e) (incorporated into § 982 by § 982(b)(1)), the government may obtain a pretrial restraining order or seizure warrant freezing property the government alleges is subject to criminal forfeiture. The restraint can issue before indictment under § 853(e)(1)(B) on a showing of probable cause and the substantial likelihood the government will prevail. After indictment, the restraint issues under § 853(e)(1)(A) based on the grand jury's probable-cause determination on the underlying offense.

The Supreme Court's pretrial-restraint jurisprudence developed in three stages. Caplin & Drysdale v. United States, 491 U.S. 617 (1989), upheld the constitutionality of the pretrial-restraint regime against Sixth Amendment counsel-of-choice challenges, holding that no Sixth Amendment right attaches to tainted funds. United States v. Monsanto, 491 U.S. 600 (1989), decided the same day, established the same rule with respect to specific restrained assets. Kaley v. United States, 571 U.S. 320 (2014), refused to extend the pretrial hearing to permit relitigation of the grand jury's probable-cause finding on the underlying offense — meaning the defendant could challenge traceability but not the underlying charge. Luis v. United States, 578 U.S. 5 (2016), finally drew the constitutional line at untainted assets: the Sixth Amendment forbids pretrial restraint of property unconnected to the alleged offense when the defendant needs that property to retain counsel of choice.

The practical defense framework that emerges from these decisions is asset-by-asset. The defense traces each restrained asset back to its source — bank records, real-estate records, business records, ownership documents. Assets that the government can show were acquired with proceeds of the alleged offense (or used to facilitate the offense) remain restrained under Caplin & Drysdale and Monsanto. Assets that the government cannot trace to the offense — pre-existing savings, pre-existing real estate, gifts, inheritances, lawful business income from sources unrelated to the offense — are subject to release under Luis if the defendant needs them to retain counsel.

The Kaley hearing itself is not a guaranteed proceeding — the Court left open the precise contours in dicta, and the Fifth Circuit has not definitively resolved whether the hearing must be granted on demand or only on a substantial threshold showing. Some district judges in N.D. Texas and E.D. Texas grant traceability hearings routinely on motion; others require a substantial preliminary showing of untainted source before scheduling the hearing. Defense counsel approaches the issue practically — file a motion to release that specifies the assets, attaches tracing documentation, and requests an evidentiary hearing only if the documentary record cannot resolve the question on the papers. Forensic accountants are routinely retained to develop the tracing evidence, particularly in cases involving commingled accounts and long-running transaction histories.

Local DFW forfeiture practice — N.D. Texas and E.D. Texas

Federal forfeiture practice in the Northern and Eastern Districts of Texas concentrates around DEA narcotics seizures, FBI fraud-proceeds restraints, IRS-CI tax-and-money-laundering forfeitures, and HSI customs-and-trade seizures. Each district has distinct AUSA practices, magistrate procedures, and adoption patterns.

The Northern District of Texas (N.D. Tex.) covers Collin, Dallas, Denton, Tarrant, and 96 other Texas counties; the Eastern District of Texas (E.D. Tex.) covers 43 counties including the eastern DFW suburbs and parts of East Texas. Both districts handle substantial federal-forfeiture caseloads — N.D. Tex. through the Dallas, Fort Worth, Amarillo, and Wichita Falls divisions; E.D. Tex. through the Sherman, Tyler, Plano, Beaumont, and Lufkin divisions. Forfeiture practice differs meaningfully between the two districts in pace, motion-handling, and the AUSA office's typical posture on innocent-owner and proportionality challenges.

DEA narcotics seizures are the most-common forfeiture predicate in both districts. The DFW metropolitan area is a major narcotics-trafficking corridor, and federal seizures of cash, vehicles, and real property connected to narcotics offenses generate high administrative-forfeiture volume. The 2017 DOJ adoptive-forfeiture policy changes restricted but did not eliminate state-to-federal referrals; police-and-prosecutor relationships with DEA and HSI continue to drive a substantial share of federal forfeiture caseload. Defense practice on DEA seizures hinges on the 35-day administrative-claim deadline — claimants who miss the window face an uphill battle to recover the property under § 983(e), and the burden shifts to demonstrating defective notice or actual lack of notice.

FBI and IRS-Criminal Investigation fraud forfeitures are the next-most-common category in both districts. The N.D. Tex. U.S. Attorney's Office Asset Forfeiture and Money Laundering Unit (AFMLU) coordinates with the FBI Dallas Field Office and IRS-CI Dallas Field Office on healthcare-fraud, public-corruption, money-laundering, and securities-fraud forfeitures. The E.D. Tex. office runs parallel processes through Plano, Sherman, and Tyler. Both offices regularly seek pretrial restraint of accounts and real property in fraud cases, and the post-Honeycutt environment has reduced the aggressive joint-and-several positions that AUSAs took on co-conspirator forfeiture in the pre-2017 era. Where the indictment seeks individual forfeiture only against the proceeds the named defendant actually received, defense practice focuses on the substitute-asset analysis and the tracing of allegedly-tainted assets.

IRS-CI tax-and-money-laundering forfeitures often involve structured-cash deposits under 31 U.S.C. § 5324 and the parallel money-laundering counts under § 1956 and § 1957. After the Internal Revenue Service's 2014 policy change limiting structuring forfeitures to cases involving evidence of an underlying offense, the volume of small-cash structuring forfeitures dropped sharply — but the policy change did not eliminate the practice, and IRS-CI continues to pursue cash forfeiture in cases involving genuinely tainted funds. Defense practice on structuring forfeitures focuses heavily on the Timbs / § 983(g) proportionality defense, particularly where the structured amounts are small relative to total business cash flow and there is no evidence of underlying tax evasion or other criminal conduct.

HSI customs-and-trade seizures account for a significant volume of administrative forfeiture in DFW because of DFW International Airport's status as a federal port of entry. Currency seizures from international travelers, counterfeit-goods seizures, and merchandise-import-violation seizures all run through HSI in the DFW area, with referral to the U.S. Attorney's Office only when judicial proceedings are required. The customs-forfeiture regime under 19 U.S.C. § 1602 et seq. operates somewhat differently from the general 18 U.S.C. § 981 framework — fewer CAFRA protections apply, and the time deadlines are different. Defense counsel handling DFW Airport seizures must be familiar with both the customs-specific rules and the general CAFRA framework.

When to retain federal forfeiture counsel

Federal forfeiture timing is unforgiving. The 35-day administrative-claim window starts running on the date of personal notice; the 30-day window starts on final publication. Missing either deadline forfeits the property by default. Retain federal forfeiture counsel immediately on notice — not after the deadline runs.

The most common forfeiture-defense failure is missing the verified-claim deadline. Under 18 U.S.C. § 983(a)(2)(B), a claimant has 35 days from personal notice (or 30 days from final publication) to file a verified claim with the seizing agency asserting an interest in the property. The deadline is statutory and largely unforgiving — post-default review under § 983(e) is available only on narrow grounds (defective notice, lack of actual notice) and must be filed within five years of the final notice of forfeiture. Claimants who receive notice and assume the agency will return the property without action, or who attempt to negotiate informally with the agency without filing a verified claim, regularly lose the property by default.

The second most common failure is filing a defective verified claim. The claim must satisfy the statutory verification requirements — it must (1) identify the specific property, (2) state the claimant's interest, and (3) be made under oath subject to penalty of perjury. A claim signed by counsel rather than the claimant, a claim that fails to identify the specific property, or a claim that asserts a generalized rather than specific interest can all be rejected as procedurally defective. The agency's rejection effectively converts the case to default forfeiture, with the same narrow post-default review available. Retained counsel familiar with the verification requirements is the practical safeguard against these traps.

In criminal forfeiture cases, the timing pressure shifts. The forfeiture allegation appears in the indictment or information; the procedural mechanics run through Federal Rule of Criminal Procedure 32.2. Third parties asserting interests in property identified in the indictment have until the ancillary proceeding under § 853(n) — typically 30 days after publication of the preliminary forfeiture order — to file their petitions. The third-party ancillary proceeding is functionally a civil mini-trial within the criminal case, governed by the same standards as quiet-title actions; the third party must prove either a legal interest in the property that was vested before the offense or that the third party is a bona fide purchaser for value without knowledge of the underlying offense.

Federal forfeiture defense is a specialized practice within federal criminal defense. The intersection of substantive forfeiture law (§§ 981-983, § 853, the customs statutes), procedural rules (Rule 32.2, Supplemental Rule G, the administrative-claim mechanics), Sixth Amendment Luis/Kaley doctrine, Eighth Amendment Timbs/Bajakajian doctrine, and forensic-accounting tracing work demands experience that not every federal criminal defense lawyer has developed. Where the seized property is significant — real estate, business assets, retirement accounts, substantial cash deposits — the forfeiture defense often determines whether the client emerges from the criminal proceeding with the resources to rebuild a life or with nothing. Retain federal forfeiture counsel at the earliest possible signal: seizure receipt, notice of seizure, pre-indictment restraining order application, target letter mentioning forfeiture allegations, or grand-jury subpoena attaching property descriptions.

Defense Strategy

What we evaluate first

Five defense levers do most of the work in Texas evading cases. We evaluate every one before charting a path — suppression first, then knowledge, intent, necessity, and charge-reduction posture together set the strategy.

  1. Honeycutt co-conspirator limit — individual defendant's share only
    Under Honeycutt v. United States, 581 U.S. 443 (2017), criminal forfeiture under 21 U.S.C. § 853(a)(1) reaches only property the individual defendant actually acquired — not property acquired by co-conspirators. The defense scrutinizes the forfeiture allegation in any conspiracy indictment and moves to limit forfeiture to the defendant's individual share. The motion is routinely successful for low-level participants, salaried employees, and family members who received minimal proceeds from larger conspiracies. Post-Honeycutt, joint-and-several co-conspirator forfeiture is no longer the default — the burden rests on the government to prove the defendant's individual proceeds, asset by asset.
  2. Luis untainted-asset release for counsel of choice
    Under Luis v. United States, 578 U.S. 5 (2016), the Sixth Amendment bars pretrial restraint of untainted assets the defendant needs to retain counsel. The defense traces each restrained asset back to its source — bank records, real-estate records, business records — and identifies assets with non-criminal origins. Forensic accountants typically develop the tracing record in cases involving commingled accounts or long-running transaction histories. Where the government cannot establish tainted-origin tracing for some portion of the restrained assets, the defense moves to release that portion for use in retaining counsel under Luis and Caplin & Drysdale's tainted/untainted distinction.
  3. CAFRA innocent-owner defense under § 983(d)
    In civil forfeiture, a claimant who can prove either lack of knowledge of the property's connection to unlawful activity (pre-existing interest under § 983(d)(2)) or bona fide purchaser status (post-acquisition interest under § 983(d)(3)) defeats the forfeiture entirely. The burden rests on the claimant by a preponderance of the evidence. The defense is fact-intensive — bank records, communication records, business records, property records all support the knowledge analysis. Common applications include family members holding title to seized real estate, business partners in seized accounts, lenders or lessors of seized vehicles, and spouses of charged defendants in seized cash.
  4. Timbs / Bajakajian Excessive Fines proportionality challenge
    Under Timbs v. Indiana, 586 U.S. 146 (2019), and United States v. Bajakajian, 524 U.S. 321 (1998), forfeitures are subject to Eighth Amendment Excessive Fines proportionality review. CAFRA codifies the defense at 18 U.S.C. § 983(g) — a claimant may petition the court to find the forfeiture grossly disproportional to the gravity of the offense, with mandatory reduction or elimination on a finding of disproportionality. The Bajakajian factors include the relationship of the property to the offense, the gravity of the offense, the harm caused, and the available statutory penalties. The defense is most powerful in structured-cash, low-level money-laundering, and reporting-statute cases under 31 U.S.C. § 5324, where small offenses can trigger disproportionate cash forfeitures.
  5. Good due-process notice challenge
    Under United States v. James Daniel Good Real Property, 510 U.S. 43 (1993), the Fifth Amendment Due Process Clause requires pre-seizure notice and an opportunity to be heard before the government seizes real property in civil forfeiture, except in exigent circumstances. The defense reviews the procedural sequence of any real-property seizure for compliance with Good and analogous notice requirements. Post-seizure due-process challenges remain available where the seizing agency failed to provide adequate notice, where personal service was defective, or where published notice did not meet statutory requirements. Mullane v. Central Hanover Bank & Trust Co., 339 U.S. 306 (1950), supplies the foundational notice doctrine that Good applied in the forfeiture context.
  6. Nexus challenge — break the connection to the offense
    Both civil and criminal forfeiture require the government to prove a nexus between the property and the underlying offense. In civil forfeiture under § 981, the nexus must be to "specified unlawful activity" as defined in § 1956(c)(7); in criminal forfeiture under § 853, the nexus is to proceeds, facilitating property, or substitute assets. The defense challenges each link in the nexus chain — sourcing of funds, traceability through commingled accounts, the "involved in" requirement for facilitating property, and the "directly or indirectly" tracing requirement for proceeds. Forensic accountants develop the tracing record in complex financial cases; documentary evidence supports the source-of-funds challenge.
  7. Kaley pretrial restraint traceability hearing
    Under Kaley v. United States, 571 U.S. 320 (2014), a defendant may not relitigate the grand jury's probable-cause determination on the underlying offense at a pretrial restraint hearing — but may challenge the traceability of the restrained property to the alleged offense. The hearing is governed by 21 U.S.C. § 853(e) for restraining orders and § 853(f) for warrants of seizure. Defense practice involves filing a motion to release that specifies the assets at issue, attaches tracing documentation, and requests an evidentiary hearing where the documentary record cannot resolve the question. Outcomes vary considerably by judge and district — N.D. Texas and E.D. Texas magistrates generally entertain traceability challenges but the scope and depth of the hearing depend heavily on the individual judge.
Defense Timeline

How we build the case

Texas evading defense follows a predictable four-phase arc — stabilize and discover (0-15 days), build the suppression record (15-90 days), motion practice and posture (3-6 months), then trial readiness or resolution (6 months+).

  1. Day 0-7
    Seizure and notice of seizure
    Federal agency seizes property — DEA narcotics seizure, FBI fraud-proceeds restraint, HSI customs seizure, IRS-CI structuring forfeiture. Within days the seizing agency provides personal written notice to known interest-holders identifying the property and the statutory basis for seizure. Notice triggers the 35-day verified-claim deadline under 18 U.S.C. § 983(a)(2)(B). Retain federal forfeiture counsel immediately — the deadline runs from the date of personal notice, not from the date of retention or the date of consultation.
  2. Day 7-35
    Verified claim filing in administrative forfeiture
    Counsel reviews the notice, confirms the property identification, traces the source of funds or chain of title, and prepares the verified claim. The claim must (1) identify the specific property, (2) state the claimant's interest, and (3) be sworn under penalty of perjury. The claim is filed with the seizing agency within 35 days of personal notice (or 30 days of final publication). Filing the verified claim removes the case from the administrative track and triggers the government's 90-day deadline to file a judicial civil forfeiture complaint or release the property under § 983(a)(3).
  3. Day 35-180
    Civil forfeiture complaint and answer
    After verified claim, the government has 90 days under § 983(a)(3)(A) to file a judicial civil forfeiture complaint — captioned United States v. [Property Description] — or release the property. Once the complaint is filed, the claimant must answer within 20 days under Supplemental Rule G(5)(b). The case then proceeds to discovery, motion practice (motions to dismiss for failure to allege a sufficient nexus, due-process notice defects, statute of limitations under § 981(b)), and summary judgment. Innocent-owner defenses under § 983(d) and proportionality defenses under § 983(g) are developed throughout this phase.
  4. Month 6-24
    Trial or ancillary criminal-forfeiture proceeding
    Civil forfeiture cases proceed to trial — typically a bench trial on documentary records — within 12-24 months of complaint filing. Criminal forfeiture proceeds in parallel with the underlying criminal case: forfeiture allegation in the indictment, special verdict at trial under Rule 32.2(b)(5), preliminary order of forfeiture, third-party ancillary proceedings under § 853(n), and final order of forfeiture as part of the criminal judgment. Substitute-asset proceedings under § 853(p) follow if traceable proceeds are unavailable. Appellate review of forfeiture orders proceeds through the Fifth Circuit on the same timeline as the underlying criminal appeal in criminal-forfeiture cases, or as a separate civil appeal in civil-forfeiture cases.

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Frequently asked questions

Twelve questions we answer most often about Texas evading-arrest cases — penalties, defenses, expunction, court timeline, license impact, and federal-case interaction.

What is the difference between criminal and civil federal forfeiture?

Criminal forfeiture under 18 U.S.C. § 982 and 21 U.S.C. § 853 is an in personam forfeiture imposed as part of a criminal sentence — it requires a guilty verdict or plea on the underlying offense and is part of the criminal judgment under Federal Rule of Criminal Procedure 32.2. Civil forfeiture under 18 U.S.C. § 981 is an in rem proceeding brought directly against the property itself, requiring no criminal conviction; the government must prove by a preponderance of the evidence that the property is connected to specified unlawful activity. The two proceedings can run in parallel — many federal prosecutions include both a criminal-forfeiture allegation in the indictment and a parallel civil-forfeiture complaint against related property held by third parties. Procedure governs differently: Rule 32.2 for criminal, the Supplemental Rules for Admiralty (Rule G) for civil. Innocent-owner defenses under § 983(d) are available in civil but not criminal forfeiture (third-party rights in criminal forfeiture are litigated under § 853(n) in an ancillary proceeding).

What is administrative forfeiture, and when does it apply?

Administrative forfeiture under 19 U.S.C. §§ 1607-1610 is a non-judicial procedure by which the seizing federal agency itself — DEA, FBI, ICE/HSI, ATF, IRS-CI, or U.S. Customs and Border Protection — declares property forfeit without any court involvement. It applies to monetary instruments of any value, conveyances used in customs offenses, and other property appraised at $500,000 or less. Real property is never subject to administrative forfeiture — it must always go through judicial civil forfeiture under § 981. The procedure requires the agency to publish notice and provide personal written notice to known interest-holders. If no person files a timely verified claim within 35 days of personal notice (or 30 days of final publication) under 18 U.S.C. § 983(a)(2)(B), the property is administratively forfeit by default. Filing a timely verified claim moves the case into a CAFRA civil forfeiture proceeding with full court involvement.

What is the Honeycutt rule, and how does it affect co-conspirator forfeiture?

Honeycutt v. United States, 581 U.S. 443 (2017), held unanimously that 21 U.S.C. § 853(a)(1) limits federal criminal forfeiture to property the individual defendant actually acquired — not property acquired by co-conspirators. Before Honeycutt, federal prosecutors routinely sought joint-and-several criminal forfeiture against all co-conspirators for the full proceeds of a conspiracy, meaning even a low-level salaried employee could face a forfeiture order equal to the entire conspiracy's gross proceeds. The Supreme Court rejected this practice as inconsistent with the statutory text. Post-Honeycutt, the government must prove the defendant's individual share of proceeds — asset by asset — and cannot recover from a defendant who never received the funds in the first place. The decision has been particularly transformative for low-level participants, salaried employees, family members, and minor co-conspirators in drug, fraud, and other conspiracy cases. Honeycutt applies retroactively to non-final cases on direct appeal.

What is the Luis rule on pretrial restraint of assets?

Luis v. United States, 578 U.S. 5 (2016), held that the Sixth Amendment forbids federal pretrial restraint of a defendant's untainted assets — assets unconnected to the alleged criminal conduct — when the defendant needs those assets to retain counsel of choice. The decision distinguished Caplin & Drysdale v. United States, 491 U.S. 617 (1989), which permitted pretrial restraint of tainted assets, by drawing a constitutional line at the tainted/untainted distinction. Luis applies only to traceably untainted assets and only at the pretrial stage; the rule does not survive conviction, when even untainted assets become forfeitable as substitute property under § 853(p). Defense practice traces each restrained asset back to its source through bank records, real-estate records, and business records — assets with non-criminal origins (pre-existing savings, lawful business income from sources unrelated to the offense, gifts, inheritances) are subject to release under Luis. Forensic accountants typically develop the tracing record in commingled-account cases.

What is the innocent-owner defense under CAFRA?

The CAFRA innocent-owner defense at 18 U.S.C. § 983(d) protects civil-forfeiture claimants who can prove either (1) lack of knowledge of the property's connection to unlawful activity (for pre-existing interests under § 983(d)(2)) or (2) bona fide purchaser status (for post-acquisition interests under § 983(d)(3)). The burden rests on the claimant by a preponderance of the evidence. For pre-existing interests, the claimant must show the interest was acquired before the unlawful conduct giving rise to forfeiture or that the claimant did not know of the conduct and, on becoming aware, did all that reasonably could be expected under the circumstances to terminate the use. For post-acquisition interests, the claimant must show the interest was acquired as a bona fide purchaser for value and the claimant did not know and was reasonably without cause to believe the property was subject to forfeiture. The defense applies to all civil forfeitures with limited statutory exceptions and does NOT apply to criminal forfeiture (where third-party rights are litigated in the § 853(n) ancillary proceeding under different standards).

What does it cost to defend a federal forfeiture case?

Federal forfeiture defense fees vary substantially by case complexity, the value of the property at stake, and whether the matter is administrative, civil, or criminal forfeiture. Administrative-forfeiture defense — filing a verified claim and managing the conversion to civil forfeiture — typically runs $5,000-$15,000. Civil forfeiture through complaint, answer, discovery, motion practice, and trial typically runs $25,000-$75,000 in straightforward cases. Complex civil forfeitures involving multiple parcels of real estate, commingled accounts, multiple claimants, or parallel criminal proceedings can run $100,000-$250,000 or more. Forensic accountant retention adds $10,000-$50,000+ in tracing-intensive cases. Criminal-forfeiture defense is typically scoped within the underlying criminal-defense fee but can be separately scoped where the forfeiture exposure is the dominant issue. We quote in writing after a free consultation and walk through the cost/benefit analysis specific to the property at stake and the procedural track at issue.

How long do federal forfeiture cases take to resolve?

Administrative forfeiture is the fastest track — uncontested administrative forfeitures complete within 60-90 days of notice publication. Where a verified claim is filed within the 35-day deadline, the case converts to civil forfeiture, which typically runs 12-24 months from complaint filing to trial or settlement. Complex civil forfeitures involving multiple parties, real estate, commingled accounts, or parallel criminal proceedings can run 2-4 years. Criminal forfeiture runs on the timeline of the underlying criminal case — typically 12-36 months from indictment to sentencing, with the forfeiture component finalized at the sentencing hearing. Third-party ancillary proceedings under § 853(n) follow the preliminary forfeiture order and typically resolve within 6-18 months. Appellate review of forfeiture orders adds 12-18 months to the timeline. The 35-day administrative-claim deadline is the single most time-sensitive action in any federal forfeiture matter and runs from the date of personal notice — not from the date of retention or consultation.

What is the proportionality defense under Timbs and Bajakajian?

Under Timbs v. Indiana, 586 U.S. 146 (2019), the Eighth Amendment Excessive Fines Clause applies to civil forfeiture. United States v. Bajakajian, 524 U.S. 321 (1998), held that forfeitures violating the Excessive Fines Clause must be reduced or eliminated; the test is whether the forfeiture is "grossly disproportional" to the gravity of the offense. CAFRA codifies the defense at 18 U.S.C. § 983(g) for civil forfeiture — a claimant may petition the court to find the forfeiture grossly disproportional, and the court must reduce or eliminate the forfeiture on such a finding. The Bajakajian factors include: (1) the relationship of the property to the offense; (2) the gravity of the offense; (3) the harm caused; and (4) the available statutory penalties. The defense is most powerful in structured-cash forfeitures under 31 U.S.C. § 5324, low-level money-laundering forfeitures, reporting-statute forfeitures, and cases where small offenses trigger disproportionate cash or asset seizures. Bajakajian itself involved a $357,144 cash forfeiture for a failure to report currency export — the Supreme Court held the forfeiture grossly disproportional to the offense.

Can I get my property back if I miss the 35-day claim deadline?

Post-default review of administrative forfeiture is available only on narrow grounds under 18 U.S.C. § 983(e) — typically (1) the agency failed to take reasonable steps to provide notice or (2) the claimant did not know or have reason to know of the seizure. The motion to set aside the forfeiture must be filed within five years of the final notice of forfeiture. Successful post-default motions are uncommon — courts generally enforce the 35-day deadline strictly, and informal assumptions that the agency would return the property without a verified claim are not a basis for relief. Even where the agency's notice was technically deficient, the claimant must show actual lack of notice and that the agency did not take reasonable steps to provide notice. The practical lesson is to retain federal forfeiture counsel immediately on receipt of notice — within days, not weeks — and file the verified claim within the statutory window regardless of any informal communications with the agency.

What is a Kaley hearing, and when do I get one?

A Kaley hearing is a pretrial proceeding under Kaley v. United States, 571 U.S. 320 (2014), at which the defendant challenges the federal government's pretrial restraint of property under 21 U.S.C. § 853(e). The Supreme Court in Kaley held that the defendant cannot use the hearing to relitigate the grand jury's probable-cause determination on the underlying offense — that determination is final once the grand jury indicts. The defendant CAN challenge the traceability of the restrained property to the alleged offense — that is, whether the government has shown a sufficient nexus between the property and the criminal conduct to justify pretrial restraint. The scope and procedural posture of Kaley hearings vary considerably by district and by judge. In N.D. Texas and E.D. Texas, magistrate judges generally entertain traceability challenges on motion, but the depth of the evidentiary inquiry depends on the individual judge. Defense practice typically involves filing a motion to release that specifies the assets, attaches tracing documentation, and requests an evidentiary hearing only where the documentary record cannot resolve the question.

What are substitute assets under 21 U.S.C. § 853(p)?

Substitute assets under 21 U.S.C. § 853(p) are untainted property the government may forfeit when the original tainted proceeds of the offense are unavailable. The substitute-asset provision applies when, as a result of any act or omission of the defendant, the originally forfeitable property: (1) cannot be located upon the exercise of due diligence; (2) has been transferred, sold to, or deposited with a third party; (3) has been placed beyond the jurisdiction of the court; (4) has been substantially diminished in value; or (5) has been commingled with other property that cannot be divided without difficulty. The government may then forfeit any other property of the defendant up to the value of the unavailable tainted property. The substitute-asset provision effectively converts criminal forfeiture into a money-judgment-style remedy. Substitute-asset forfeiture is generally not available pretrial under United States v. Razmilovic, 419 F.3d 134 (2d Cir. 2005) — and Luis v. United States, 578 U.S. 5 (2016), reinforced this limit by holding that untainted assets cannot be pretrial-restrained at all when needed for counsel of choice. After conviction, however, substitute-asset forfeiture is broadly available and is the default tool when tainted proceeds have been dissipated or hidden.

Can I file an innocent-owner claim in a criminal forfeiture case?

No — innocent-owner defenses under 18 U.S.C. § 983(d) apply only to civil forfeiture. In criminal forfeiture under 21 U.S.C. § 853, third-party rights are litigated in an ancillary proceeding under § 853(n), which uses different substantive standards. A third-party petitioner in a § 853(n) ancillary proceeding must establish either (1) a legal right, title, or interest in the property that was vested in the petitioner rather than the defendant or was superior to the defendant's right at the time of the offense (the "relation-back" doctrine), or (2) bona fide purchaser for value status. The § 853(n) standards are functionally similar to the CAFRA innocent-owner standards but operate under different procedural and substantive rules. The ancillary proceeding is filed within 30 days of publication of the preliminary order of forfeiture, is functionally a civil mini-trial within the criminal case, and is governed by quiet-title-style standards. Third parties asserting interests in property identified in a criminal indictment should retain forfeiture counsel immediately on becoming aware of the indictment — the ancillary proceeding deadlines are strict and post-default relief is limited.

References

All citations link to statutes.capitol.texas.gov for primary text. Footnote numbers in the body link here; the arrow returns to the citing paragraph.

  1. Tex. Penal Code § 38.04 — Evading arrest or detention.
  2. Tex. Penal Code § 12.21 — Class A misdemeanor punishment range.
  3. Tex. Penal Code § 12.34 — Third-degree felony punishment range.
  4. Tex. Penal Code § 12.33 — Second-degree felony punishment range.
  5. Tex. Penal Code § 9.22 — Necessity affirmative defense.
  6. Tex. Code Crim. Proc. art. 38.23 — Suppression of evidence from unlawful search/detention.
  7. Tex. Code Crim. Proc. art. 39.14 — Michael Morton Act discovery.
  8. Tex. Code Crim. Proc. art. 42A.054 — 3g offenses (not including evading).
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About the authors

The attorneys behind this page

Reggie London

Reggie London

Co-Founding Partner · Criminal Defense Attorney

Admitted in Texas, TXND, TXED, and the U.S. Court of Appeals for the Fifth Circuit. Practice spans DWI, drug, weapons, theft, and process crimes — plus federal practice.

Njeri London

Njeri London

Co-Founding Partner · Criminal Defense Attorney

Texas-licensed criminal defense attorney with deep Fourth Amendment motion practice. Focus: suppression hearings, drug-crime defense, federal-practice support.

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