United States v. Maritime Life Caribbean Limited, No. 17-10889 (11th Cir. 2019)Annotate this Case
In an ancillary third-party forfeiture proceeding where Maritime Life asserted that it was given a security interest in the forfeited property, the Eleventh Circuit held that the district court committed harmless error in requiring Maritime Life to prove the authenticity of the collateral assignment that allegedly granted it a security interest in the forfeited property by a preponderance of the evidence. In this case, ample evidence supported the district court's finding on the ultimate question of authenticity and that finding controlled whether Maritime Life had an interest in the property.
The court also held that, although the district court erred in permitting the Republic of Trinidad and Tobago to intervene in the forfeiture proceeding even though it had no legal interest in the property, the intervention did not affect Maritime Life's substantial rights and did not require reversal. Accordingly, the court affirmed the judgment.