United States v. Boss, No. 20-2061 (1st Cir. 2021)Annotate this Case
The First Circuit affirmed the judgment of the district court awarding to the Commonwealth a letter written by Alexander Hamilton to the Marquis de Lafayette on July 21, 1780 that was the subject of a civil forfeiture action, holding that there was no error.
The letter at issue was seized pursuant to a judicial warrant by the Federal Bureau of Investigations from a fine antiques auctions house in Virginia. The government filed a verified complaint for forfeiture in rem against the letter, alleging that the letter was subject to forfeiture as property traceable to a violation of statutes that criminalize interstate transport of and trade in stolen goods valued over $5,000. The Commonwealth and the Estate of Stewart Crane filed claims to the letter. The district court struck the Estate's claim and concluded that the Commonwealth was the only entity that could own the letter. The First Circuit affirmed, holding that the district court did not err in honoring the Commonwealth's claim of entitlement to the letter.
The court issued a subsequent related opinion or order on October 14, 2021.