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Table of Contents

900 – Forfeitures, Generally

900 – Forfeitures, Generally
  • 905 Jurisdictional Issues
  • 910 Constitutional Issues
  • 920 Procedural Issues, Generally
  • 950 Probable Cause
  • 960 Innocent Owner Defense
  • 970 Property Forfeited

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§960 Forfeitures, Innocent Owner Defense

Supreme Court
First Circuit
Second Circuit
Third Circuit
Fourth Circuit
Fifth Circuit
Sixth Circuit
Seventh Circuit
Eighth Circuit
Ninth Circuit
Tenth Circuit
Eleventh Circuit
Miscellaneous

Supreme Court holds lack of knowledge that home was pur­chased with drug proceeds is de­fense to forfei­ture. (960) In a plurality opinion announced by Jus­tice Stevens, the Supreme Court concluded that an owner’s lack of knowledge of the fact that her home had been purchased with the proceeds of ille­gal drug transactions constituted a defense to a forfei­ture pro­ceeding under the statute.  In 1982 respon­dent re­ceived $240,000 from her boyfriend to pur­chase a home.  In 1989 the government filed an in rem action against the parcel of land on which the home was lo­cated.  There was probable cause to be­lieve that the funds used to buy the house were pro­ceeds of illegal drug trafficking, but re­spondent swore she had no knowledge of its origins.  The plurality concluded that the “innocent owner” protection is not limited to bona fide purchasers.   In addition, the gov­ernment is not the owner of a property before forfeiture has been decreed.  The two concur­ring Jus­tices con­cluded that the result was correct because the “rela­tion back” principle recited in 21 U.S.C. section 881(h) is the fa­miliar, traditional one and the term “owner” in section 881(a)(6) bears its ordinary meaning.  U.S. v. Parcel of Land Bldgs., Appurtenances and Improvements, Known as 92 Buena Vista Ave., Rumson, N.J.,, 507 U.S. 111, 113 S.Ct. 1126 (1993).

 

1st Circuit upholds denial of attorneys’ fees to claimants who presented successful innocent owner defense. (960) In a forfei­ture action against property jointly owned by three siblings, the govern­ment eventu­ally stipulated that two of the sib­lings were inno­cent owners.  Nevertheless, the 1st Circuit upheld the denial of attor­neys’ fees under the Equal Ac­cess to Justice Act (EAJA).  The govern­ment’s deci­sion to seize the prop­erty was warranted because there was probable cause to believe that it was used for illegal ac­tivity.  Once probable cause is established, it is the claimant’s bur­den to prove the innocent owner de­fense.  It would be unreasonable to require the gov­ernment to foresee an owner’s possi­ble affirmative defenses.  The govern­ment also had substantial justi­fication for the manner in which it seized the prop­erty under 21 U.S.C. 881.  Even if the statutory proce­dures were ultimately found to be in­sufficient, the government was reasonable in using those procedures.  Although the 2nd Circuit recently found constitutional problems with section 881, the government was not required to follow the 2nd Cir­cuit. U.S. v. One Parcel of Real Property with Buildings, Appurte­nances, and Improvements, Known as Plat 20, 960 F.2d 200 (1st Cir. 1992).

 

1st Circuit rules that claimant’s failure to furnish cross-statement of facts consti­tuted admission of government’s asser­tions. (960) The 1st Circuit re­jected claimant’s contention that he was an inno­cent owner.  The burden of proving the defense of in­nocent ownership rests with the claimant.  Claimant’s initial opposition to the govern­ment’s motion for summary judgment in­cluded no affidavits, only a general denial of some allegations in the forfeiture complaint and a “weasel-worded challenge” to the thrust of the detailed affidavits supporting the forfei­ture complaint.  More­over, claimant failed to furnish the required cross-statement of facts.  Thus, his un­excused omissions had the legal effect of admitting the government’s factual as­sertions.  U.S. v. Parcel of Land and Resi­dence at 18 Oakwood Street, 958 F.2d 1 (1st Cir. 1992).

 

2nd Circuit rejects innocent owner de­fense where drug paraphernalia was found in plain sight in shared bedroom. (960) A forfeiture action was brought against claimant’s residence based upon her hus­band’s drug activities.  The 2nd Circuit re­jected claimant’s innocent owner defense since drugs and drug paraphernalia were found throughout their shared bedroom and some drug paraphernalia was found in plain sight.  Even if claimant’s husband had exclu­sive control of the dresser, closet and jewelry box where drugs were found, the fact that a sifter, grinder, sheets of paper, and funnel were in plain view on top of the dresser belied claimant’s ignorance of drug activities in the bedroom.  Her purported ig­norance was at best “willful blindness,” and at worst perjuri­ous.  The abundance and visibility of the nar­cotics evidence contradicted any contention that claimant took all reasonable steps to prevent the ille­gal use of the property.  Judge Van Graafeiland dis­sented.  U.S. v. One Par­cel of Property, Located at 755 Forest Road, 985 F.2d 70 (2nd Cir. 1993).

 

2nd Circuit finds that claimants knew of drug traf­ficking on their property. (960) The 2nd Cir­cuit upheld the forfeiture of real property, finding that there was probable cause and that claimants were not innocent own­ers.  Due to the extraordinary volume of drug trans­actions occurring on, nearby, or directly related to the premises (66 drug-re­lated ar­rests over a three-year period), the trial court cor­rectly found probable cause that the property had been used to facilitate drug trafficking.  Further, the court did not err in rejecting claimants’ improbable testi­mony that they had no knowledge of drug-traf­ficking on their prop­erty and had not con­sented to it, particularly given their own drug-related arrests on the site and their presence during arrests for various other drug trans­actions.  A claimant who has knowl­edge that his property is being used for drug-related purposes must take reasonable steps to pre­vent this illicit use in order to show a lack of consent.  Claimants failed to show that they took those steps.  That similar drug activity may have pervaded the neighborhood did not excuse them.  U.S. v. All Right, Title, and In­terest in Real Property and Appurte­nances Thereto Known as 785 St. Nicholas Ave., 983 F.2d 396 (2nd Cir. 1993).

 

2nd Circuit instructs district court to comply with re­cent decision concerning innocent owner defense. (960) The dis­trict court instructed the jury that in or­der to be an innocent owner, claimant must prove two things:  (a) that she did not have actual knowledge of drug activity at her property; and (b) that she did not consent to the illegal drug activity.  After this instruction the 2nd Circuit decided U.S. v. 141st Street Corp., 911 F.2d at 878 (2nd Cir. 1990) which held that a claimant may avoid forfeiture by estab­lishing either that she had no knowledge of the nar­cotics ac­tivity or, if she had knowl­edge, that she did not consent to it.  The case was re­manded on other grounds, and in the event of a new trial, the district court was di­rected to give an instruc­tion consistent with 141st Street Corp. U.S. v. Cer­tain Real Property and Premises, Known as 8890 Noyac Road, 945 F.2d 1252 (2nd Cir. 1991).

 

3rd Circuit holds that wife had no interest in property solely owned by husband. (960) Claimant’s husband was the sole record owner of certain property he pur­chased during his marriage to claimant.  She claimed to have an ownership interest in the property for purposes of the innocent owner defense by virtue of the definition of “marital property” in the Divorce Chapter of the Penn­sylvania Domestic Relations Act.  The 3rd Circuit rejected this interpretation.  After re­viewing relevant decisions of the Pennsylvania Supreme Court and those of federal courts interpreting analogous state law, it concluded there was no indication that the Pennsylvania Supreme Court would interpret the marital property provision of the Divorce Chapter to confer a present ownership interest in the property on claimant solely by virtue of her marriage.  Thus, claimant could not assert the federal forfeiture statute’s innocent owner defense.  U.S. v. Premises Known as 717 South Woodward Street, 2 F.3d 529 (3rd Cir. 1993).

 

3rd Circuit finds claimant’s bare denial of knowledge sufficient to withstand sum­mary judgment. (960) One claimant and her husband owned a residence and a food mar­ket as tenants by the entireties.  The husband also owned a club in which a second claimant had an interest by virtue of his contribution to the down payment.  In a forfeiture action against the three properties based on the husband’s drug dealings, claimants asserted the innocent owner defense.  The 3rd Circuit held that the claimants’ bare denial of knowl­edge was sufficient to create a genuine issue of fact and thus summary judgment was in­appropriate.  A rational jury could believe the second claimant’s testimony that he had no knowledge of the husband’s drug dealings at the club.  Similarly, a rational jury could be­lieve the wife’s testimony that she had no knowledge of her husband’s drug dealing from their house or market.  No evidence was tendered placing the wife at her residence or at the scene of any drug-related transaction.  Judge Seitz concurred and dissented.  U.S. v. Premises Known as 717 South Woodward Street, 2 F.3d 529 (3rd Cir. 1993).

 

3rd Circuit gives innocent spouse right to exclusive use and possession of property during her lifetime. (960) Claimant and her husband owned the property as tenants by the en­tirety.  A tenant by the entirety has title to the whole prop­erty.  In a forfeiture action based on the hus­band’s drug ac­tivities, the government conceded that claimant had a valid innocent owner defense.  The district court then dismissed the forfei­ture com­plaint, ruling that as an innocent owner, claimant was entitled to retain her ti­tle to the entire property.  The govern­ment then moved to amend the judgment, arguing that it had a right to the hus­band’s in­terest, but that claimant could retain exclusive use of it dur­ing her life­time, and the right to ob­tain title in fee simple absolute if her husband pre­deceased her.  The 3rd Circuit re­versed the district court’s ruling and adopted the gov­ernment’s interpretation.  That interpreta­tion best served the dual pur­poses of 21 U.S.C. sec­tion 881(a)(7), permitting the immedi­ate forfeiture of the in­terest of the guilty spouse, and fully protecting the property rights of the innocent owner under the tenancy by the en­tireties.  U.S. v. Parcel of Real Property Known as 1500 Lincoln Avenue, 949 F.2d 73 (3rd Cir. 1991).

 

4th Circuit holds lienholder is entitled to assert inno­cent owner defense. (960) The 4th Circuit reaf­firmed its decision in In re Metmor Fin., Inc, 819 F.2d 446 (4th Cir. 1987) and held that a lienholder is an “owner” within the meaning of 21 U.S.C. section 881 and is thus entitled to as­sert the innocent owner de­fense.  This interpretation was con­sistent with re­cent decisions by at least two other courts of appeals and was supported by the legislative his­tory.  In this case, because claimants were lienholders, and because the government had conceded their innocence, their inter­ests in the subject prop­erty could not be for­feited.  The lienholders were enti­tled to recover outstanding princi­pal, unpaid pre-seizure interest, and post-seizure in­terest.  In addition, if the mortgage doc­uments so pro­vided, costs and attorneys’ fees would be avail­able.  The case was remanded for a determination of whether claimants’ mort­gage docu­ments provided for the re­covery of attorneys’ fees and costs.  U.S. v. Federal Na­tional Mortgage Associa­tion, 946 F.2d 264 (4th Cir. 1991).

 

5th Circuit rejects innocent owner defense for purchaser of illegally imported goods. (960) Claimant purchased goods that were imported into the United States in violation of Customs law.  The 5th Circuit rejected an in­nocent owner defense to the forfeiture of the goods.  Cases suggesting the exis­tence of a constitutional innocent owner defense to cus­toms violations all involved situations where the owner of the property subject to forfeiture attained ownership rights prior to the illegal use of the prop­erty.  In contrast, claimant’s ownership of the goods arose only after the unauthorized importation.  It would render useless the current system of public recorda­tion if purchasers of imported items could ig­nore the listings and obtain good title simply by ask­ing their sellers, as claimant did, whether the im­ports were authorized.  U.S. v. Eighty-Three Rolex Watches, 992 F.2d 508 (5th Cir. 1993).

 

5th Circuit upholds forfeiture of sheep un­der Lacey Act because Pakistan law pro­hibited export. (960) The 5th Cir­cuit af­firmed summary judg­ment in fa­vor of the government in a forfeiture ac­tion brought against a sheep imported by claimant into the United States from Pakistan.  The action was brought under the forfeiture provisions of the Lacey Act.  The court held that the forfeiture statute pro­vides for strict liability, and con­tains no “innocent owner” defense.  Once the government es­tablishes proba­ble cause, the burden shifts to the claimant to establish ei­ther that a de­fense to the for­feiture applies or that the property is not subject to forfeiture.  Thus, the government needed to estab­lish only that importation of the sheep violated the laws of Pak­istan. The Pak­istani Imports and Export Act prohib­ited the sheep’s export out of Pakistan.  Al­though defendant pos­sessed an export permit issued by the province of Baluchistan, this permit was void to the extent it conflicted with the Imports and Export Act.  U.S. v. One Afghan Urial Ovis Orientalis Blanfordi Fully Mounted Sheep, 964 F.2d 474 (5th Cir. 1992).

 

5th Circuit upholds forfeiture because claimant did not perfect ownership inter­est in automobile under state law. (960) Claimant, an attorney, made an oral agree­ment with his client to represent the client for $50,000.  The client offered $6,500 in cash and his 1977 Porsche Carrera 911.  Claimant then entered into a written form contract in which the client agreed to pay a retainer in the amount of $50,000.  The contract did not mention the car.  Nonethe­less, that day, claimant took physical possession of the car.   Although the client had obtained the car sev­eral months be­fore, he did not register his ti­tle to it until after claimant ob­tained posses­sion of the car.  The certificate assigning ti­tle to claimant remained unrecorded during a subse­quent forfeiture action against the car based on the client’s drug activities.  The 5th Circuit held claimant’s posses­sory interest gave him standing to challenge the forfei­ture, but rejected his innocent owner defense be­cause his interest in the vehicle was not valid against third parties under Texas law.  Since neither claimant or his client had a perfected title in the car when it was seized, claimant acquired the car subject to the forfei­ture in­terest of the government. U.S. v. 1977 Porsche Carrera, 946 F.2d 30 (5th Cir. 1991).

 

6th Circuit reverses summary judgment against spouse who denied knowledge of drugs in home. (960) Claimant’s husband was convicted of drug of­fenses, and claimant was tried but acquitted.  Subse­quently, the government sought to forfeit the family’s mo­bile home and the tract on which it sat, as well as other property owned by the family.  The district court granted summary judgment to the government, but the 6th Circuit re­versed with respect to claimant’s interest in the parcel.  The only evidence tying drug ac­tivity to the home was proof that a bag of marijuana and a jar containing several thou­sand marijuana seeds were found in the mo­bile home.  At her crimi­nal trial and in an af­fidavit in the forfeiture action, claimant de­nied knowing that these items were in her home.  A reasonable trier of fact could have con­cluded that claimant satisfied the inno­cent-owner defense.  U.S. v. Three Tracts of Property Lo­cated on Beaver Creek, 994 F.2d 287 (6th Cir. 1993).

 

7th Circuit holds that manager’s knowl­edge of drug activities could not be im­puted to corpora­tion. (960) A corporation owned the defendant prop­erty, and three in­dividuals owned stock in the corpo­ration.  A husband and wife owned 2/3 of the stock, and their son owned the remaining 1/3.  The son’s shares were a gift from his parents.  The son lived on the property and directed its day-to-day operations while his par­ents lived else­where.  Without the knowledge or consent of his parents, the son began engaging in drug transactions on the property in his personal resi­dence. He never used corporate funds to purchase drugs and never put any drug pro­ceeds into the corporation.  In a for­feiture ac­tion against the property, the 7th Circuit re­versed a summary judg­ment in favor of the government and held that the corporation was an inno­cent owner.  The son’s knowledge of his own criminal activity could not be im­puted to the corporation to defeat the corpo­ration’s innocent owner defense.  Section 881(a)(7) focuses on the claimant’s actual knowledge of the illegal ac­tivities, not whether the claimant should have known of the illegal activi­ties.  Thus, the son’s knowledge of his own illegal activities would not be im­puted to the corporation because the son was dealing drugs to benefit himself, and not the corpora­tion.  Judge Pos­ner dissented.  U.S. v. One Parcel of Land Located at 7326 Highway 45 North, 965 F.2d 311 (7th Cir. 1992).

 

8th Circuit rules government did not prove corpo­ration’s willful blindness of em­ployee’s drug deal­ings. (960) The govern­ment sought forfeiture of a Jeep owned by claimant, a family-owned cor­poration, based on drug dealing by Mark, a minority share­holder who used the Jeep as his company car.  In grant­ing summary judgment, the dis­trict court re­jected the corporation’s innocent owner de­fense, finding that it could not prove the absence of willful blindness.  The 8th Cir­cuit ruled that the govern­ment did not prove willful blindness as a matter of law, and re­manded for trial.  “Willful blindness involves an owner who deliberately closes his eyes to what otherwise would have been obvious and whose acts or omission show a con­scious purpose to avoid knowing the truth.”  Here, the record showed that Mark had difficulty with drugs over a period of time and had been treated sev­eral times.  He was al­lowed to return to work because the family felt he was no longer using drugs.  Family members were monitor­ing Mark’s work and atten­dance.  Moreover, Mark had a personal car in addi­tion to the Jeep. U.S. v. One 1989 Jeep Wagoneer, 976 F.2d 1172 (8th Cir. 1992).

 

9th Circuit rejects innocent owner de­fense even though owner moved be­fore mari­juana was found. (960) The claimant sepa­rated from the woman with whom he had been living and moved out of the mo­bile home in Au­gust, 1987.  The woman contin­ued to live in the mobile home, and the claimant continued to operate a shake mill on the property.  On several occa­sions after he moved out, he was al­lowed to use the tele­phone in the mobile home and once or twice, the bathroom.  Two years after the claimant had moved out, federal agents executed a search warrant at the mobile home.  They found 66 live marijuana plants, equip­ment for a marijuana-growing operation, and vari­ous quantities of pro­cessed marijuana.  Based on the claimant’s knowl­edge of the smell of marijuana, the boarded up win­dows, and his visits in­side the mobile home after he had moved out, the 9th Circuit upheld the district court’s finding that he was not an “innocent owner.” U.S. v. Real Prop­erty Lo­cated at Section 18, 976 F.2d 515 (9th Cir. 1992).

 

10th Circuit holds innocent lienholder is entitled to re­cover attorneys’ fees if pro­vided for in pre-ex­isting deed of trust. (960) The 10th Circuit held that where a pre-ex­isting deed of trust gives a lienholder the right to re­cover at­torneys’ fees, the innocent lien­holder is enti­tled to recover such fees even though the fees are in­curred after the acts giving rise to the forfeiture and af­ter the govern­ment’s seizure of the property.  In such a situation, a lien­holder’s right to recover at­torneys’ fees is secured by the property, and its right to recover such fees is an interest in the prop­erty.  This is true even if the fees are in­curred af­ter the acts giving rise to the for­feiture.  The lien­holder’s right to reim­bursement of at­torneys’ fees were cre­ated at the time the deed of trust was formed.  This right pre­dated the commis­sion of the bad acts that gave rise to the for­feiture.  U.S. v. Real Property Located at 2471 Venus Drive, 949 F.2d 374 (10th Cir. 1991).

 

11th Circuit remands to determine whether county tax collector could be in­nocent owner. (960) The district court re­jected the argument that a tax lien resulting from unpaid ad valorem property taxes pro­vided the county tax collector with standing as an innocent owner to challenge a civil for­feiture under 21 U.S.C. section 881(a)(6) and (a)(7).  The 11th Circuit remanded for recon­sideration in light of U.S. v. A Parcel of Land, Buildings, Appurtenances and Improve­ments, Known as 92 Buena Vista Avenue,  113 S.Ct. 1126 (1993).  The district court concluded that the innocent owner defense applies only to owners whose interests vest before the act giving rise to the forfeiture. The court thus relied on the relation-back doc­trine, under which a judgment of forfeiture relates back to the time of the unlawful act, cutting off the rights of subsequent lienhold­ers or purchasers.  However, this doctrine was rejected by the Supreme Court in Buena Vista.  U.S. v. 2350 N.W. 187 Street, 996 F.2d 1141 (11th Cir. 1993).

 

11th Circuit rules that lender had no ac­tual knowledge that drug proceeds were traceable to mortgage property. (960) At the request of a long-time customer, claimant loaned money to a shell corporation as a bridge loan pending the sale of the corpora­tion’s sole asset, a residence.  The loan was secured by a first mortgage on the property.  The undisclosed true owner of the property was a drug dealer, who had purchased the property four years earlier with drug pro­ceeds.  In a forfeiture action against the prop­erty, the district court rejected claimant’s in­nocent owner defense.  The 11th Circuit re­versed, ruling that claimant proved it had no actual knowledge that drug proceeds were traceable to the mortgaged property. It was uncontradicted that the drug dealer was not known to the claimant and played no role in the mortgage process.  He was never a record owner of the property.  There was no evi­dence that when the lender made the loan in 1987, it knew that four years earlier a drug dealer purchased the land and constructed the residence with drug proceeds.  U.S. v. One Single Family Residence Located at 6960 Miraflores Avenue, 995 F.2d 1558 (11th Cir. 1993).

 

11th Circuit holds that innocent owner must prove either lack of knowledge or lack of consent to drug activities. (960) The innocent owner provisions in 21 U.S.C. section 881(a)(7) provides a defense to the forfeiture of property for those owners who can prove that they had no knowledge of il­legal activity occur­ring on their property or who did not consent to that activity.  The 11th Circuit held that this means an owner can avoid forfeiture by proving ei­ther igno­rance or non-consent.  Cases which require owners to prove both non-consent and igno­rance read sec­tion 881(a)(7) incorrectly.   U.S. v. One Par­cel of Real Es­tate at 1012 Germantown Road, 963 F.2d 1496 (11th Cir. 1992).

 

11th Circuit holds that lack of consent re­quires proof that claimant made all rea­sonable efforts to prevent illicit use of his property. (960) The jury was presented with a special interrogatory concern­ing claimant’s innocent owner defense which asked whether claimant proved, by a preponderance of the evi­dence, that he did everything that he could rea­sonably be expected to do to prevent the subject property from being used for drug ac­tivity.  The 11th Circuit held that this accu­rately stated the law in the circuit under 21 U.S.C. section 881(a)(7).  The same standard applies to actions under section 881(a)(6).  Nonetheless, the court erred in failing to in­struct the jury on the definition of consent and the “all reason­able efforts” standard.  The court should have made clear that the stan­dard does not require the claimant to make all efforts, but merely all reason­able ones.  The “all reasonable efforts” standard can be sat­isfied by contacting and cooperating with law en­forcement authorities, especially when a claimant is unable to halt drug traffic on his own.   U.S. v. One Parcel of Real Es­tate at 1012 Germantown Road, 963 F.2d 1496 (11th Cir. 1992).

 

11th Circuit finds genuine issue of fact concern­ing claimant’s knowledge of hus­band’s drug activity. (960) The government brought a civil forfeiture action against prop­erty jointly owned by claimant and her hus­band, which was used by her husband as a drop-off point for co­caine de­liveries.   The district court denied claimant’s mo­tion for summary judgment.  The 11th Circuit dis­missed claimant’s appeal for lack of jurisdic­tion, but then ruled that if it had ju­risdiction, it would affirm the district court’s denial of the summary judg­ment motion.  Claimant failed to show there was no is­sue of fact as to her innocent owner status.   Defen­dant was present when the police arrived to search the home but elected to leave during the search.  The evidence also in­dicated that defendant’s husband used the home reg­ularly for illegal drugs.  This raised an infer­ence that the claimant was not entirely ignorant of the cir­cumstances sur­rounding her hus­band’s ac­tivities.  U.S. v. Certain Real and Per­sonal Property Belonging to Ronald Jerome Hayes, 943 F.2d 1292 (11th Cir. 1991).

 

New York District Court rules shareholders have no standing to assert “innocent owner” defense. (960) The government filed an in rem forfeiture action against a restau­rant, alleging it had been used in drug and money laundering violations.  Twenty-six shareholders of the corporation that owned the restaurant filed claims, alleging that they were “innocent owners.”  District Judge Glasser ruled that the shareholders had no standing to file claims, because “shareholders do not hold legal title to any of the corpora­tion’s assets.”  The court noted that if share­holders had standing, “drug dealers could set up a corporation and sell stock to innocent shareholders or to those acting in concert, who could then assert an innocent owner de­fense in any pending forfeiture proceeding.”  “Strawmen” and “nominal” holders of legal ti­tle do not have standing, and neither do shareholders.  U.S. v. New Silver Palace Restaurant, 810 F.Supp. 440 (E.D.N.Y. 1992).

Browse Contents

  • 100 Pre-Guidelines Sentencing, Generally
  • 110 Guidelines Sentencing, Generally
  • 150 Application Principles, Generally
  • 200 Offense Conduct, Generally
  • 400 Adjustments, Generally
  • 500 Criminal History, Generally
  • 550 Determining the Sentence
  • 700 Departures, Generally
  • 750 Sentencing Hearing, Generally
  • 780 Plea Agreements, Generally
  • 800 Violations of Probation and Supervised Release
  • 840 Sentencing of Organizations
  • 850 Appeal of Sentence (18 U.S.C. §3742)
  • 880 Habeas Corpus / 28 U.S.C. 2255 Motions
  • 900 – Forfeitures, Generally

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