Saccoccia v. United States, No. 19-1361 (1st Cir. 2020)
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The First Circuit affirmed the judgment of the district court dismissing Plaintiff's 2018 complaint seeking vacated of a forfeiture order and return of his forfeited property, holding that Honeycutt v. United States, 137 S. Ct. 1626 (2017), did not apply in this case.
Plaintiff was convicted of conspiracy under the Racketeer Influenced and Corrupt Organization (RICO) Act, engaging in monetary transactions with criminal deprived property and money laundering arising out of his control of a money-laundering ring.
The district court ordered Plaintiff to forfeit the sum of $136,344,231. The district court did not challenge the district court's finding that all of the money at issue passed through a bank account he controlled. Plaintiff later filed a complaint arguing that the Supreme Court's decision in Honeycutt should be applied retroactively to invalidate the forfeiture judgment against him. The district court dismissed the complaint, concluding that Plaintiff failed to state a claim as to each asserted avenue of relief. The First Circuit affirmed, holding (1) Honeycutt did not apply as a matter of fact to Plaintiff's case given his control over the funds at issue; and (2) Honeycutt did not preclude liability in Plaintiff's case.
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