Melisa Ingram v. Wayne County, Mich., 81 F.4th 603

Wayne County, Michigan allegedly seized private vehicles (and contents) and detained them for months while pressuring owners to pay tiered "redemption" fees ($900, $1,800, $2,700) or await civil forfeiture proceedings. Owners faced towing/storage fees and repeated pretrial conferences with prosecutors (no judge) before a judicial hearing.
Plaintiffs (Wilson, Reeves, Ingram) each had cars seized under Michigan forfeiture statutes (Controlled Substances Act, Nuisance Abatement, Omnibus Forfeiture Act) and alleged they were denied timely process to contest retention of their vehicles.
District court denied Wayne County’s motions to dismiss Count IV (procedural-due-process claim) under Mathews v. Eldridge, certified that order for interlocutory appeal, and concluded plaintiffs pleaded a timely-hearing entitlement.
On interlocutory review the Sixth Circuit (majority) held that plaintiffs plausibly alleged a Fourteenth Amendment due-process violation from prolonged, pre-forfeiture vehicle retention without a prompt post-seizure hearing.
The Sixth Circuit applied the Mathews balancing test, concluded all factors favored the plaintiffs, and provided guidance that a post-seizure hearing should be held within two weeks for vehicles vital to transportation and livelihood; remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether due process requires a prompt post-seizure, pre-forfeiture hearing for retained vehicles	Vehicle owners need a prompt hearing; prolonged retention without neutral review deprives property and livelihood	County argued no interim hearing required; defense urged speedy-trial/Barker framework	Yes; Due Process requires a prompt post-seizure hearing for personal vehicles used for transportation/livelihood
Which legal standard governs need for interim hearing	Apply Mathews v. Eldridge balancing test	Apply Barker speedy-trial test (or treat final forfeiture hearing as sufficient)	Apply Mathews; Barker is a poor fit for interim property-retention review
What procedural remedy/timing is constitutionally adequate	Prompt opportunity to test probable validity of retention; plaintiffs sought timely hearing	County emphasized administrative burdens and final forfeiture process	Court: hearing required within two weeks of seizure for vehicles vital to transportation/livelihood; hearing must test probable validity and include Mathews/Golberg-type protections
Scope of interlocutory review of district court order	Plaintiffs sought resolution of Count IV only	County raised additional procedural defenses on appeal	Court limited review to Count IV issues certified; declined to resolve other procedural defenses on interlocutory appeal

Mathews v. Eldridge, 424 U.S. 319 (1976) (three-factor due-process balancing test applied to need for additional procedural safeguards)
Krimstock v. Kelly, 306 F.3d 40 (2d Cir. 2002) (post-seizure retention of vehicles for months without prompt neutral hearing violates due process; requires early probable-validity review)
County of Riverside v. McLaughlin, 500 U.S. 44 (1991) (Gerstein prompt-probable-cause rule: 48-hour benchmark for detention hearings informs timeliness analysis)
Gerstein v. Pugh, 420 U.S. 103 (1975) (Fourth Amendment requires prompt judicial determination of probable cause for detention)
United States v. Von Neumann, 474 U.S. 242 (1986) (addressed administrative delays in federal seizure context; distinguished from requirement for interim hearing)
Nichols v. Wayne County, [citation="822 F. App'x 445"] (6th Cir. 2020) (fractured panel; recognized need for notice and a timely post-seizure hearing though did not answer how prompt)
Goldberg v. Kelly, 397 U.S. 254 (1970) (due-process hearing elements: notice, opportunity to confront, present evidence, impartial decisionmaker)