State v. Timbs
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The Supreme Court ruled that the forfeiture of Tyson Timbs's his white Land Rover was unconstitutional, holding that Timbs met his high burden to show that the harshness of his Land Rover's forfeiture was grossly disproportionate to the gravity of the underlying offense and his culpability for the vehicle's misuse.
The State filed a civil forfeiture complaint alleging that Timbs had used his Land Rover to illegally purchase, possess, and deal narcotics. The trial court entered judgment for Timbs. The case made its way up to the Supreme Court of the United States. On remand, the Supreme Court held that the Excessive Fines Clause of the Eighth Amendment includes both instrumentality and proportionality limitations for use-based in rem fines like the forfeiture of Timbs's vehicle and that such fines are constitutional if two requirements are met. The Supreme Court held that the forfeiture fell within the Excessive Fines Clauses's instrumentality limit but remanded for the trial court to determine whether the harshness of the forfeiture penalty was grossly disproportional to the gravity of the offense. The trial court determined that Timbs had shown gross disproportionality. The Supreme Court affirmed, holding that Timbs met his burden to show gross disproportionality and that the Land Rover's forfeiture was unconstitutional.
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