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Culley v. Marshall (2024)

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Culley v. Marshall (2024)

Citation: 601 U.S. 377 (No. 22-585) · Court: Supreme Court of the United States · Decided: May 9, 2024 (argued October 30, 2023) · Opinion: Kavanaugh, J., for the Court (joined by Roberts, C.J., and Thomas, Alito, Gorsuch and Barrett, JJ.); Gorsuch, J. (joined by Thomas, J.), concurring; Sotomayor, J. (joined by Kagan and Jackson, JJ.), dissenting.

Facts

Halima Culley lent her car to her son, who was arrested for possessing marijuana; Lena Sutton lent hers to a friend arrested for trafficking methamphetamine. Alabama seized both cars under a civil-forfeiture law permitting seizure “incident to an arrest” if the State “promptly” filed a forfeiture case (Ala. Code § 20-2-93(b)(1), (c)), and filed forfeiture complaints 10 and 13 days after the seizures. The owners sued under 42 U.S.C. § 1983, arguing that due process required a separate preliminary hearing on whether the State could retain the cars pending the forfeiture case. The Eleventh Circuit affirmed dismissal.

Holding

“In civil forfeiture cases involving personal property, the Due Process Clause requires a timely forfeiture hearing but does not require a separate preliminary hearing.” (Syllabus.)

Reasoning

  • States may seize personal property subject to civil forfeiture immediately (unlike real property, which ordinarily requires notice and a hearing first), and the Court’s precedents — including United States v. [USD] 8,850 (caption uses a dollar figure) and United States v. Von Neumann — require a timely post-seizure forfeiture hearing, not an additional retention hearing. (Syllabus (a)-(b).)
  • Historical practice “is weighty evidence that due process does not require such hearings.” (Syllabus.)

Practical impact

  • For vehicle owners and lienholders, the constitutional floor is a timely forfeiture hearing; interim retention of the car without a separate hearing is permissible. Statutory claim procedures (in federal cases, 18 U.S.C. § 983(a)) govern the timing.
  • For buyers of forfeited vehicles, the decision confirms that a forfeiture judgment entered after a timely hearing is not vulnerable merely because no preliminary retention hearing was held.
  • The concurrence collects open questions about civil forfeiture, including innocent-owner limits discussed in bennis-v-michigan-1996.

Good-law status

Still good law (decided 2024).

Applies in →

All jurisdictions (federal constitutional rule). See forfeiture-and-government-seizure-sales, motor-vehicles, due-process-notice.

Sources

Disclaimer. This page is legal information, not legal advice. It summarizes a court decision that may have been limited or distinguished by later authority. Nothing here creates an attorney-client relationship. Read the full opinion and consult a licensed attorney before acting.

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