$8,074.68 in United States Currency 40 "8 Liner" MacHines 3 Walmart Gift Cards And Misc. Papers v. State, 05-13-01502-CV

Law enforcement (Sergeant Jeff Brownrigg) obtained a search warrant for Triple Crazy Game Room after an affidavit reporting observations and information from other officers; warrant issued June 13, 2013.
Executing the warrant, officers seized $8,074.68, forty “8-liner” gambling machines, three Walmart gift cards, and miscellaneous papers.
The State filed a civil forfeiture motion under Tex. Code Crim. Proc. art. 18.18 and gave notice it would not prosecute criminally for related offenses.
Jack Fairchild, an interested party, appeared and contested forfeiture at a show-cause hearing, objecting to admission of the warrant affidavit as hearsay and arguing it lacked personal-knowledge foundation.
The trial court admitted a certified copy of the warrant, affidavit, and return (State’s Exhibit 1); neither side introduced additional evidence; the court ordered forfeiture.
Fairchild appealed solely arguing the affidavit was inadmissible hearsay and thus the State failed to meet its burden at the show-cause hearing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the search-affidavit (State’s Exhibit 1) was inadmissible hearsay at the show-cause hearing	Fairchild: affidavit is hearsay, based on speculation/conjecture, not competent evidence for forfeiture	State: affidavit properly supported issuance of the warrant; magistrate already found probable cause; fellow-officer hearsay permissible for warrants	Court: affidavit admissible; hearsay in a warrant affidavit does not require exclusion; any defect was harmless because probable cause was already established when warrant issued
Who bears burden at show-cause hearing after warrant issuance	Fairchild: State must prove at hearing that property is subject to forfeiture	State: once warrant issued, burden shifts to interested party to prove property is not forfeitable	Court: follows Hardy — State met its burden by obtaining warrant; burden shifted to Fairchild, who introduced no evidence, so forfeiture proper

Hardy v. State, 102 S.W.3d 123 (Tex. 2003) (allocates burden in art. 18 forfeiture proceedings; issuance of warrant satisfies State’s initial burden)
State v. Ninety Thousand Two Hundred Thirty-Five Dollars and No Cents in U.S. Currency and 2000 Black Lincoln Navigator, 390 S.W.3d 289 (Tex. 2013) (probable cause in forfeiture context requires substantial connection between property and criminal activity)
Cassias v. State, 719 S.W.2d 585 (Tex. Crim. App. 1986) (officer may rely on observations/info from fellow officers in a warrant affidavit)
United States v. Ventresca, 380 U.S. 102 (1965) (magistrate may draw reasonable inferences; fellow-officer observations are reliable for warrants)
State v. One Super Cherry Master Video 8-Liner Machine, 102 S.W.3d 132 (Tex. 2003) (interested party bears burden to prove property not subject to forfeiture under art. 18.18)