United States v. JP Morgan Chase Bank Account
2016 U.S. App. LEXIS 16200
9th Cir.2016Background
- Claimants Ladislao Samaniego and Manuel Castro — both Mexican residents tied to a Mexican currency‑exchange business (Centro Cambiario Sonorense / CSC) — opened two J.P. Morgan Chase accounts (one in each name) that together held roughly $807,000.
- The government seized both accounts as part of a civil asset‑forfeiture action, alleging the accounts were used to launder proceeds from Welton, a Mexican grocery business operated in part by Jorge Salas Alvarez.
- Samaniego and CSC had a longstanding, oral arrangement with Salas Alvarez to collect, hold, and temporarily use Welton’s cash; Claimants sometimes described the funds as belonging to Welton and sometimes as belonging to themselves/CSC.
- Claimants filed verified claims asserting ownership and/or possessory interests; the district court granted the government’s motion (styled a motion to strike / treated as summary judgment) holding Claimants lacked Article III and prudential standing.
- On appeal the Ninth Circuit reviewed de novo and held that while ownership claims were undermined by inconsistent testimony, Claimants presented sufficient evidence of a possessory interest (declarations, deposition testimony, bank records) to survive summary judgment and to confer both Article III and prudential standing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Article III standing to challenge forfeiture | Samaniego and Castro asserted ownership and/or possessory interests in the seized accounts and submitted declarations, deposition testimony, and bank records showing control/possession. | Government argued Claimants produced no specific indicia of ownership or lawful interest; prior inconsistent statements showed funds belonged to Welton, so no standing. | Ownership claims failed due to contradictions, but Claimants showed enough evidence of possessory interests to survive summary judgment and have Article III standing. |
| Sufficiency of evidence at summary judgment stage | Claimants argued their declarations and corroborating testimony created a triable issue about who held the funds and whether they had dominion. | Government contended summary judgment was appropriate because Claimants’ late declarations contradicted deposition admissions and bare possession is insufficient. | Court: summary‑judgment standard requires viewing evidence for nonmovant; Claimants’ evidence, when construed favorably, raised a factual dispute about possession. |
| Possessory vs. ownership interest | Claimants maintained they held either ownership or at least lawful possessory interests (joint/control) in the accounts. | Government emphasized Claimants repeatedly admitted funds belonged to Welton and were merely transporting/holding them. | Court: possessory interest can exist short of ownership; evidence supported reasonable inference of possessory control by each claimant. |
| Prudential standing (raising another’s rights / zone of interests) | Claimants argued they suffered direct injury from seizure and fall within the class Congress authorized to litigate forfeiture claims. | Government argued Claimants were asserting Welton’s rights and thus lacked prudential standing. | Court: prudential requirements satisfied — claimants alleged personal, redressable injury and fall within statutory zone of interests for forfeiture claims. |
Key Cases Cited
- United States v. Real Prop. Located at 475 Martin Lane, 545 F.3d 1134 (9th Cir.) (Article III standing requirement in forfeiture actions)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (Sup. Ct.) (constitutional standing principles)
- United States v. $133,420.00 in U.S. Currency, 672 F.3d 629 (9th Cir.) (ownership/possession standards for standing in forfeiture cases)
- United States v. $191,910.00 in U.S. Currency, 16 F.3d 1051 (9th Cir.) (possessory interest can exist when holding property for another)
- United States v. $100,348.00 in U.S. Currency, 354 F.3d 1110 (9th Cir.) (courts require more than conclusory assertions to defeat summary judgment in forfeiture cases)
- Anderson v. Liberty Lobby, 477 U.S. 242 (Sup. Ct.) (summary judgment and reasonable jury standard)
- Lexmark Int'l, Inc. v. Static Control Components, Inc., 134 S. Ct. 1377 (Sup. Ct.) (analysis of prudential standing and zone of interests)
- United States v. Currency, U.S. $42,500.00, 283 F.3d 977 (9th Cir.) (construing summary‑judgment procedures in forfeiture proceedings)