United States v. Samaniego, No. 14-16070 (9th Cir. 2016)Annotate this Case
Claimants 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.