OCTOBER TERM, 2001
certiorari to the united states court of appeals for the sixth circuit
No. 00-6567. Argued October 29, 2001—Decided January 8, 2002
While petitioner was in prison on federal drug charges, the Federal Bureau of Investigation (FBI) began an administrative process to forfeit cash that officers seized when they executed a search warrant for the residence where petitioner was arrested. The statute in effect at the time required the agency, inter alia, to send written notice of the seizure and applicable forfeiture procedures to each party who appeared to have an interest in the property. 19 U. S. C. § 1607(a). The FBI sent such notice by certified mail addressed to petitioner care of the federal correctional institution (FCI) where he was incarcerated; to the address of the residence where he was arrested; and to an address in the town where his mother lived. It received no response in the time allotted and turned over the cash to the United States Marshals Service. Subsequently, petitioner moved in the District Court under Federal Rule of Criminal Procedure 41(e) for return of all the property and funds seized in his criminal case. The court denied the motion. The Sixth Circuit vacated and remanded, holding that the motion should have been construed as a civil complaint seeking equitable relief for a due process challenge to the adequacy of the notice. On remand, the District Court presided over a telephone deposition of an FCI officer who stated that he signed the certified mail receipt for the FBI's notice to petitioner and testified about the FCI's procedures for accepting, logging, and delivering certified mail addressed to inmates. The court granted the Government summary judgment, ruling that its sending of notice by certified mail to petitioner's place of incarceration satisfied his due process rights. The Sixth Circuit affirmed.
Held: The FBI's notice of the cash forfeiture satisfied due process. The
Fifth Amendment's Due Process Clause entitles individuals whose property interests are at stake to "notice and an opportunity to be heard." United States v. James Daniel Good Real Property, 510 U. S. 43, 48. The straightforward reasonableness under the circumstances test of Mullane v. Central Hanover Bank & Trust Co., 339 U. S. 306, 313, not the balancing test approach of Mathews v. Eldridge, 424 U. S. 319, 335, supplies the appropriate analytical framework for the due process analysis. This Court has never viewed Mathews as announcing an all-embracing test for deciding due process claims, but has regularly turned
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