United States v. Parcel Of Real Property Known As 6109 Grubb Road, Millcreek Township Erie County, Pennsylvania’s Empirical Analysis
886 F.2d 618 · 1989
Citation profile
36 federal appellate · 16 district · 3 state decisions
How this case has been cited
Cited by 122 later decisions (1 by the Supreme Court) — most recently February 2025 · most notably United States v. A Parcel of Land Buildings Appurtenances and Improvements Known As 92 Buena Vista Avenue Rumson New Jersey (1993), United States v. 4492 South Livonia Road (1989)
36 federal appellate · 16 district · 3 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
Applies 19 U.S.C. § 1618 (Tariff Act of 1930) · 21 U.S.C. § 843 (§ 403 of the Controlled Substances Act) · 21 U.S.C. § 846 (§ 406 of the Controlled Substances Act) · 21 U.S.C. § 881 (§ 511 of the Controlled Substances Act) · 26 U.S.C. § 6723
Relies on Boddie v. Connecticut · Calero-Toledo v. Pearson Yacht Leasing Co. · Reiter v. Sonotone Corp. · Federal Communications Commission v. Pacifica Foundation · United States v. Four Million, Two Hundred Fifty-Five Thousand
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 122 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“by reason of any act or omission established by that owner to have been committed or omitted without the knowledge or consent of that owner.”
7 later decisions quote this exact passage · from the majority“'adequate and sufficiently reliable to warrant the belief by a reasonable person that' the property was used to further the trafficking of illegal narcotics.”
5 later decisions quote this exact passage · from the majoritye.g. No. 91-5200 · No. 93-7265“5(5 * * * * * The construction of the innocent owner defense is a case of first impression in this court. Our research reveals only one published opinion in which a federal court has examined whether the “knowledge or consent” phrase in § 881(a)(7) has established independent defenses. In United States v. Certain Real Property & Premises Known as 171-02 Liberty Avenue, Queens, New York, 710 F.Supp. 46 (E.D.N.Y.1989), [171-01 Liberty Avenue ] the district court for the Eastern District of New York was presented with a case where the owner of property in a high drug-trafficking area knew that his property was being used as a base to sell “crack” although he received no profit from the dealings. The government claimed that the owner’s knowledge was sufficient to lose the innocent owner defense and forfeit the property. The owner countered that the statute provided an innocent owner defense to an individual who could show lack of “knowledge or consent” and therefore it was enough for him to establish that he did not consent to the illegal use of his property. 710 F.Supp. at 48-49 . The district court in 171-02 Liberty Avenue concluded that even if an owner has knowledge of the illegal use of his property, he may nonetheless prove innocent ownership by showing a lack of consent. The court reasoned that the use of or in the statute (knowledge or consent) means that each word must be given its independent and ordinary meaning. 171-02 Liberty Avenue, 710 F.Supp. at 50 . In so ruling,”
4 later decisions 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.