Maldonado v. State, 172, 2016

Maldonado was arrested in Nov. 2013 on drug-dealing–related charges; police seized $4,000 cash and $39,000 in a Citibank account. Civil forfeiture proceedings were stayed during the criminal case.
In Apr. 2014 Maldonado pled guilty to aggravated possession of marijuana, agreed to forfeit the $4,000 cash and a vehicle (unless he proved ownership), but the criminal court declined to order forfeiture of the Citibank funds.
Civil forfeiture hearings (Sept. & Nov. 2015) produced evidence of repeated large cash deposits into the Citibank account coinciding with months Maldonado admitted selling substantial amounts of marijuana; deposits paused when he stayed in Virginia.
The State introduced testimony from a financial-crimes expert and evidence of prior admissions that drug proceeds had been deposited; Maldonado offered explanations (odd jobs, rental income, funds from his wife) that the court found not credible.
A Superior Court Commissioner found probable cause the Citibank funds were drug-sale profits and denied return of property; a de novo review by a Superior Court judge affirmed. Maldonado appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether collateral estoppel bars civil forfeiture because criminal sentencing declined to forfeit the bank funds	Maldonado: sentencing judge’s statement limits forfeiture to car and cash; State is estopped from civil forfeiture of account	State: bank-account forfeiture was not litigated or resolved in the criminal plea/sentencing; later sentencing letter disclaimed interference	Court: No estoppel; issue not fully litigated in criminal case, civil forfeiture may proceed
Whether notice of seizure under Super. Ct. Civ. R. 71.3(a) was defective	Maldonado: did not receive proper notice of seizure	State: procedural default / notice issue waived because raised late; Maldonado filed petition within 45 days so no prejudice	Court: Issue waived; no reversible prejudice shown
Whether State proved probable cause that account funds were drug-sale profits	Maldonado: funds came from lawful sources (odd jobs, rental income, wife’s money); he denied depositing drug proceeds into the account	State: timing/pattern of large cash deposits matches admitted drug sales; expert and admission evidence link deposits to drug profits	Court: Held State met probable cause; court found plaintiff’s explanations not credible and denied return of property

Brown v. State, 721 A.2d 1263 (Del. 1998) (explains burdens of proof and standard of review in forfeiture proceedings)
In re 1982 Honda, 681 A.2d 1035 (Del. 1996) (civil forfeiture may proceed separate from criminal prosecution)
In re One 1985 Mercedes Benz Auto., 644 A.2d 423 (Del. Super. 1992) (probable-cause standard for forfeiture requires a reasonable ground to believe property is drug-proceeds)