No. 98-2261’s Empirical Analysis
2001
Citation profile
2 district · 1 state decisions
How this case has been cited
Cited by 21 later decisions — most recently March 2025
2 district · 1 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Landgraf v. USI Film Products · Bradley v. School Board of City of Richmond · Bowen v. Georgetown University Hospital · Murphy v. Beck · Adventure Communications Incorporated v. Donald T. Vaughn
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 21 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In a suit or action brought under any civil forfeiture statute for the civil forfeiture of any property— (1) the burden of proof is on the Government to establish, by a preponderance of the evidence, that the property is subject to forfeiture; (2) the Government may use evidence gathered after the filing of a complaint for forfeiture to establish, by a preponderance of the evidence, that property is subject to forfeiture; and (3)if the Government’s theory of forfeiture is that the property was used to commit or facilitate the commission of a criminal offense, or was involved in the commission of a criminal offense, the Government shall establish that there was a substantial connection between the property and the offense.”
2 later decisions quote this exact passage · from the majority“any forfeiture proceeding commenced on or after [August 23, 2000].”
2 later decisions quote this exact passage · from the majoritye.g. No. 02-1925 · No. 02-1925“No definition is given of what it means for forfeiture to be “commenced.” Does this mean seizure of the property, the filing of a document in court, a finding of probable cause, the establishment of a preponderance of the evidence or some other act by the government or the court? Because forfeiture does not occur until a court acts, does it mean that forfeiture is not “commenced” until the court finally allows the forfeiture to take place — at which time the actual forfeiture “commences?” The new act says it is applicable to “any forfeiture proceeding commenced” 120 days after enactment. Does an appellate proceeding qualify?”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.