The court affirmed the district court’s denial of claims presented by the spouses of two convicted drug traffickers. The claimants requested relief from forfeiture of proceeds of trafficking under an “innocent spouse” theory. The court held that no such theory applied to prevent forfeiture of proceeds, except when the claimant was a bona fide purchaser who had no knowledge of the illegal activity. Here, the claimants were not bona fide purchasers. They only claimed a community property interest. The court noted the result may have been different had the property been “instrumentalities of crime,” but the forfeiture in this case was only of proceeds.
Case Summaries