United States v. Samaniego, No. 14-16070 (9th Cir. 2016)
Annotate this CaseClaimants challenge the government’s seizure of two J.P. Morgan Chase bank accounts in a civil asset-forfeiture action. In a verified complaint seeking forfeiture, the government contends that Claimants unlawfully used the accounts to launder money connected with illicit drug proceeds. Claimants answered and filed verified claims in response to the complaint, alleging that they held ownership and possessory interests in the seized funds sufficient to confer standing. The district court entered judgment in favor of the government. The court concluded that the district court did not err by holding that Claimants failed to provide indicia of their own ownership of the funds sufficient to defeat summary judgment. However, viewing the evidence in the light most favorable to Claimants, the court held that Claimants’ explanation of their respective possessory interests in the seized funds, coupled with supporting evidence in the form of declarations, deposition testimony, bank records, and other evidence, raises a material dispute of fact for trial. Therefore, the court concluded that Claimants have standing to challenge the forfeiture. The court also concluded that there is sufficient evidence of a possessory interest to confer prudential standing. Accordingly, the court reversed and remanded for further proceedings.
Court Description: Civil Forfeiture. The panel reversed the district court’s summary judgment in favor of the government in claimants’ challenge to the government’s seizure of two J.P. Morgan Chase bank accounts in a civil asset-forfeiture action, and remanded for further proceedings. Claimants Ladislao Samaniego and Manuel Castro opened the two bank accounts which the government seized, based on the government’s belief that the accounts were used in money laundering connected to the illegal drug trade. The district court held that claimants had not demonstrated a property interest in the seized funds sufficient to confer standing. The panel held that claimants had standing to proceed past summary judgment and challenge the government’s forfeiture action, but did not address the merits of their claims or preclude the district court from re-examining Article III standing at a later date, in light of additional evidence. UNITED STATES V. SAMANIEGO 3 The panel held that claimants set forth sufficient evidence for a reasonable factfinder to conclude that they had Article III standing to challenge the forfeiture. The panel held that in light of claimants’ self-contradictory claims and shifting legal theories, the district court did not err by holding that claimants failed to provide indicia of their own ownership of the funds sufficient to defeat summary judgment, but claimants demonstrated a possessory interest in the funds sufficient to defeat summary judgment. Specifically, the panel held that, viewing the evidence in the light most favorable to claimants, claimants’ explanation of their respective possessory interests in the seized funds, coupled with supporting evidence in the form of declarations, deposition testimony, bank records, and other evidence, raised a material dispute of fact for trial. The panel also held that claimants provided sufficient evidence of possessory interests to confer prudential standing.
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