United States v. Ramirez, 421 F. App'x 950

Ramirez was convicted of structuring financial transactions to evade reporting requirements under 31 U.S.C. § 5324(a)(3), (d).
The district court answered a jury question about whether Ramirez needed knowledge of the Currency Transaction Report form and reporting requirements.
The United States cross-appealed, challenging the forfeiture of the entire amount involved in the structuring.
The district court declined to forfeit the full amount, citing the Excessive Fines Clause and its proportionality concerns.
The district court conducted an implicit Eighth Amendment analysis, guided by Bajakajian, and upheld a reduced forfeiture amount.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the district court abuse discretion in answering the jury question?	Ramirez argues the answer was confusing.	Ramirez maintains the answer was erroneous and prejudicial.	The district court did not abuse discretion.
Is forfeiture of the entire amount involved excessive under the Excessive Fines Clause?	The United States contends full forfeiture is permissible.	Ramirez argues full forfeiture would be grossly disproportionate.	Full forfeiture was excessive and unconstitutional.
Was the amount forfeited properly limited to what was 'involved in' Ramirez’s crime?	United States seeks forfeiture of all funds involved.	Ramirez contends proportional forfeiture is required.	Forfeiture must be proportionate and not permit gross excess.

United States v. Bajakajian, 524 U.S. 321 (Supreme Court 1998) (forfeiture deemed punishment; must not be grossly disproportionate)
United States v. Elso, 422 F.3d 1305 (11th Cir. 2005) (guide on jury inquiries regarding reporting requirements)