Honeycutt v. United States, 137 S. Ct. 1626

Terry Honeycutt was a salaried manager at his brother Tony’s hardware store; the store sold large quantities of an iodine product used to make methamphetamine.
DEA and other authorities investigated; the brothers were indicted for drug-related offenses and the Government sought forfeiture of the store’s profits under 21 U.S.C. §853(a)(1).
Tony pleaded guilty and forfeited $200,000; Terry was convicted at trial of several offenses including conspiracy and sentenced to prison.
The Government sought a money judgment against Terry for the remaining conspiracy profits ($69,751.98), arguing co-conspirators are jointly and severally liable for conspiracy proceeds.
The district court refused to order forfeiture against Terry because he had no ownership interest and received no profits; the Sixth Circuit reversed, applying joint-and-several liability.
The Supreme Court granted certiorari to decide whether §853 permits forfeiture from a defendant for proceeds that he did not personally obtain.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether §853(a)(1) permits joint-and-several forfeiture of conspiracy proceeds that a defendant did not personally obtain	§853 should be read against the background of conspiracy law (Pinkerton), making conspirators liable for proceeds foreseeably obtained by the conspiracy	§853 forfeiture is limited to property the defendant himself obtained or used; joint-and-several liability would reach untainted property	No—§853(a)(1) reaches only property the defendant personally obtained (directly or indirectly) as a result of the offense; it does not authorize joint-and-several forfeiture

Pinkerton v. United States, 328 U.S. 640 (establishes conspirator liability for foreseeable acts in furtherance of a conspiracy)
McDermott, Inc. v. AmClyde, 511 U.S. 202 (explains joint-and-several liability as a tort-law concept)
Caplin & Drysdale, Chartered v. United States, 491 U.S. 617 (describes governmental interests served by criminal forfeiture)
The Palmyra, 12 Wheat. 1 (discusses traditional in rem nature of forfeiture)