United States v. Ancient Coin Collectors Guild, No. 17-1625 (4th Cir. 2018)Annotate this Case
The Guild appealed the district court's order of forfeiture to the United States of seven ancient Cypriot coins and eight ancient Chinese coins, which were imported into this country by the Guild. The Fourth Circuit affirmed and held that the district court properly determined that the government had satisfied its burden under 19 U.S.C. 2610 with respect to the coins at issue in these forfeiture proceedings. Therefore, the burden shifted to the Guild to prove that the coins were somehow not subject to being forfeited to the United States.
The court held that the district court did not abuse its discretion by requiring the Guild to present expert evidence that was particularized to the fifteen defendant ancient coins; the district court did not improperly discount expert testimony regarding the circulation patterns of ancient Cypriot and Chinese coins; and the district court did not improperly reject and discount another expert's particularized evidence about the ancient Cypriot coins. The court rejected the Guild's contention that the Customs regulation promulgated and codified at 19 C.F.R. 12.104 irreconcilably conflicted with 19 U.S.C. 2601(2), and the Guild's claims of discovery errors. Finally, the district court's conclusion in the Strike Opinion and Order did not violate the Guild's due process rights.