United States v. Enedeo Rodriguez, Jr., 20-2508

In 2016 the government seized a 2014 Nissan Altima used by Luis Jacquez in methamphetamine trafficking; Jacquez admitted using and swore he owned the car.
The government sent direct notice to a claimant Jacquez named and posted the vehicle on forfeiture.gov for 30 days under Fed. R. Civ. P. G; it did not directly notify Enedeo Rodriguez or his salvage company, RnR Auto Sales, Inc.
In February 2019 the district court entered an agreed forfeiture judgment with Jacquez and authorized a judicial sale after no claimants came forward.
One year later Rodriguez (pro se) moved for return of the vehicle claiming RnR owned it based on documents found in the glove compartment; he sought relief under 18 U.S.C. § 1963(1)(2) and Rule G.
The district court allowed limited intervention-type proceedings but denied relief, finding (1) no evidence Rodriguez personally held legal title or a protectable interest and (2) Rodriguez could not represent the company as a pro se litigant.
The Seventh Circuit affirmed: the government’s notice efforts were adequate, Rodriguez produced no title (a bill of sale is insufficient under Indiana law), and he lacked standing to assert RnR’s rights or obtain additional discovery.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing to challenge forfeiture / represent RnR	Rodriguez: RnR owned the car; glove-compartment documents and a bill of sale put government on notice and give RnR a superior interest	Government: Jacquez sworn ownership, vehicle records and title history show no RnR interest; Rodriguez produced no title and cannot represent a corporation pro se	Rodriguez lacked standing; no proof of personal title and he cannot represent RnR; relief denied and affirmed
Adequacy of Rule G notice	Rodriguez: Government should have directly notified RnR once documents existed showing its interest	Government: Complied with Rule G (direct notice to named claimant and public posting); no evidence it knew of RnR	Government’s efforts were adequate; absence of any proof RnR held title meant lack of prejudice from notice method
Request for additional discovery	Rodriguez: Additional discovery could uncover title or succession evidence to prove company ownership	Government: Existing record showed no evidence; discovery futile and Rodriguez cannot represent the company	District court did not abuse discretion in denying further discovery; pro se Rodriguez cannot pursue corporate claims

United States v. Bowser, 834 F.3d 780 (7th Cir. 2016) (standards for showing a property interest that the government should have been aware of under §1963(1)(6)(A))
United States v. Funds in the Amount of $239,400, 795 F.3d 639 (7th Cir. 2015) (standard of review for legal determinations reviewed de novo)
United States v. 8136 S. Dobson St., Chicago, Ill., 125 F.3d 1076 (7th Cir. 1997) (party who fails to file a claim while proceedings are pending is not a party to the action)
Old Ben Coal Co. v. Off. of Workers' Comp. Programs, 476 F.3d 418 (7th Cir. 2007) (a pro se litigant may not represent a corporation or other business entity)
Ambassador Fin. Servs., Inc. v. Indiana Nat. Bank, 605 N.E.2d 746 (Ind. 1992) (under Indiana law a bill of sale is not conclusive proof of a completed transfer of title)