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Supreme Court decisions
No. 22-585May 9, 2024Crime and Law EnforcementAffirmed

The question

Whether the Due Process Clause requires a separate preliminary hearing to determine whether police may retain personal property seized for civil forfeiture while the forfeiture case is pending.

Culley v. Marshall

What the Court decided

The Court affirmed the Eleventh Circuit. In civil forfeiture cases involving personal property, the Due Process Clause requires a timely forfeiture hearing but does not require a separate preliminary hearing on whether the State may retain the property while the case is pending. The Court reasoned that its prior decisions in United States v. $8,850 and United States v. Von Neumann establish that a timely post-seizure forfeiture hearing itself satisfies due process.

How the justices split

6-3
In favor 6Against 3
Kavanaugh
Roberts
Thomas
Alito
Gorsuch
Barrett
Sotomayor
Kagan
Jackson

The Court's opinion

Kavanaugh, joined by Roberts, Thomas, Alito, Gorsuch, Barrett

Held that due process requires a timely post-seizure forfeiture hearing but not a separate preliminary hearing to determine whether seized personal property may be retained pending the forfeiture hearing. Relied on United States v. $8,850 and United States v. Von Neumann, reading those decisions to establish that a timely forfeiture hearing satisfies due process and that $8,850 supplies the standard for when a hearing is timely.

Concurring

Gorsuch, joined by Thomas

Filed a concurring opinion joined by Thomas.

Dissenting

Sotomayor, joined by Kagan, Jackson

Filed a dissenting opinion joined by Kagan and Jackson.

How we know · 5 sourced claims
  • The Court held that the Due Process Clause requires a timely forfeiture hearing but does not require a separate preliminary hearing in civil forfeiture cases involving personal property.

    Source: syllabus, Held

  • The Eleventh Circuit had affirmed the dismissal of petitioners' Section 1983 due process claims, and the Supreme Court affirmed.

    Source: syllabus, Held

  • Kavanaugh delivered the opinion of the Court, joined by Roberts, Thomas, Alito, Gorsuch, and Barrett.

    Source: syllabus, lineup

  • Sotomayor filed a dissenting opinion, joined by Kagan and Jackson.

    Source: syllabus, lineup

  • Gorsuch filed a concurring opinion, joined by Thomas.

    Source: syllabus, lineup

Read the opinion on supremecourt.gov