Six Thousand Dollars v. State Ex Rel. Mississippi Bureau of Narcotics, 179 So. 3d 1

John Cole fled a checkpoint, crashed, and was apprehended; officers found a roll of $6,000 near him along with cocaine and marijuana. MBN seized the currency and sought forfeiture under the Uniform Controlled Substances Law.
Anthony Brown filed a petition claiming he owned the $6,000 and that it came from a workers’‑compensation settlement; he testified he had given Cole the cash to purchase a car and later told Cole to return it.
MBN produced crime‑lab results confirming the seized substances were cocaine and marijuana; Agent Heather Sullivan and forensic scientist Keith McMahan were identified as witnesses and later designated as experts shortly before trial.
The trial court admitted the expert testimony, found the currency was forfeitable because it was in close proximity to controlled substances, and found Brown not credible; it ordered forfeiture of the $6,000.
The Court of Appeals affirmed; the Mississippi Supreme Court granted certiorari, addressed (1) whether the expert testimony was improperly admitted and (2) whether the forfeiture was against the overwhelming weight of the evidence.
The Supreme Court held (a) the late expert designations violated Rule 4.04 and were error, but (b) the error was harmless because Brown failed to prove any ownership interest or standing under the innocent‑owner exception, so forfeiture was affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether expert witnesses were timely designated under Rule 4.04	Brown argued MBN’s experts were untimely designated and their expert testimony should be excluded	MBN argued special circumstances existed and Brown suffered no unfair surprise because the witnesses were previously disclosed as fact witnesses	Court: Designations were untimely and no special circumstances shown; admitting expert testimony was error but harmless
Whether Brown established ownership/standing to invoke the innocent‑owner exception	Brown claimed the $6,000 was his settlement money and he had given it to Cole to buy a car	MBN pointed to proximity of money to narcotics, Cole’s denials, and lack of corroboration linking Brown to the seized cash	Court: Brown failed to show a credible ownership interest or standing; presumption of forfeiture unrebutted; forfeiture affirmed

Galloway v. City of New Albany, 735 So. 2d 407 (Miss. 1999) (standard of review in forfeiture cases: substantial evidence/clearly erroneous)
One Ford Mustang Convertible, 676 So. 2d 905 (Miss. 1996) (courts must look beyond bare title to prevent manipulation of nominal ownership in forfeiture contexts)
United States v. 2004 Ferrari 360 Modeno, 902 F. Supp. 2d 944 (S.D. Tex. 2012) (claimant bears burden to establish standing/ownership in civil forfeiture proceedings)
Mississippi Dep’t of Wildlife, Fisheries & Parks v. Brannon, 943 So. 2d 53 (Miss. Ct. App. 2006) (expert testimony must be timely designated; error to admit undisclosed experts when discovery requested)