Background

• Garcia-Mendoza challenged civil forfeiture of his 2003 Chevy Tahoe and $611 after police inventory search revealed 225 grams of methamphetamine.
• He was the registered owner and in possession of the Tahoe and cash at the time of seizure.
• Minnesota civil forfeiture statute 609.531-.5319 provides in rem actions with presumptions that money and vehicles near drugs are subject to forfeiture.
• The district court granted summary judgment for the County; the court of appeals affirmed on different grounds, ruling that Fourth Amendment exclusionary rule did not apply to civil forfeiture.
• The issue presented: whether the Fourth Amendment exclusionary rule applies to civil forfeiture actions under Minn. Stat. 609.531-.5319; the Supreme Court reversed and remanded.
• The Court held that the exclusionary rule applies and that Garcia-Mendoza has standing to challenge the forfeiture.

Issues

Key Cases Cited

• Plymouth Sedan v. Pennsylvania, 380 U.S. 693 (1965) (exclusionary rule applies to civil forfeiture; forfeiture is quasi-criminal in nature)
• United States v. Good Real Prop., 510 U.S. 43 (1993) (cited for contextual support on forfeiture principles (non-control-specific))
• United States v. Bailey, 419 F.3d 1208 (11th Cir. 2005) (relation-back timing and ownership in forfeiture)
• United States v. 92 Buena Vista Ave., 507 U.S. 111 (1993) (discussion of relation-back concept in forfeiture)
• State v. Brist, 812 N.W.2d 51 (Minn. 2012) (Supreme Court decisions govern federal constitutional issues)
• State v. Askerooth, 681 N.W.2d 353 (Minn. 2004) (Minnesota constitutional analogue on exclusionary rule)