Federal Civil Forfeiture Case Result: CAFRA Attorney’s Fees After Dismissal With Prejudice
Outcome: The government voluntarily dismissed the federal civil forfeiture action with prejudice, and on appeal the Eleventh Circuit vacated the district court’s denial of CAFRA attorney’s fees, holding that a claimant may substantially prevail under CAFRA without a merits ruling.
Sammis Law Firm represented the claimant at the trial level and on appeal in a federal civil asset forfeiture case involving the seizure of $8,500 in cash at an airport. The Eleventh Circuit’s ruling provides important guidance on the scope of the Civil Asset Forfeiture Reform Act (CAFRA) attorney’s fees provision after case dismissal.
Case Overview
Case: United States v. $8,500.00 in United States Currency
Jurisdiction: U.S. District Court for the Northern District of Georgia; U.S. Court of Appeals for the Eleventh Circuit
Legal Issue on Appeal: Whether a claimant can “substantially prevail” under CAFRA when the government dismisses a federal civil forfeiture case with prejudice before a merits ruling.
Procedural History
- Federal agents seized $8,500 in cash at an airport without filing criminal charges.
- The government filed a federal civil forfeiture complaint.
- The defense filed a motion to suppress and a motion for summary judgment.
- The government moved to dismiss the forfeiture action with prejudice.
- The district court denied CAFRA attorney’s fees.
- The Eleventh Circuit vacated the fee ruling and remanded for further proceedings.
What Happened at the Trial Level
Federal agents seized $8,500 in cash from the claimant at an airport. The government initiated a civil forfeiture action alleging the funds were connected to criminal activity. At the trial level, Sammis Law Firm vigorously defended the case rather than allowing it to proceed without testing the government’s evidence.
The defense took the following actions:
- Responded to discovery and challenged the evidentiary basis for forfeiture.
- Filed a motion to suppress challenging the legality of the airport stop, detention, search, and seizure under the Fourth Amendment.
- Filed a motion for summary judgment arguing the government could not meet its burden under CAFRA.
Shortly after filing dispositive motions, the government moved to voluntarily dismiss the forfeiture action with prejudice, stating it was not in the public interest to proceed. The district court granted the dismissal, ordered the return of the seized funds, and barred the government from refiling the same forfeiture claim.
The CAFRA Attorney’s Fees Dispute
Once the case was dismissed with prejudice, the claimant moved for attorney’s fees and litigation costs under the Civil Asset Forfeiture Reform Act (CAFRA). CAFRA provides that when a claimant “substantially prevails,” the United States must pay reasonable attorney’s fees and costs.
The district court denied the fee request on the basis that the court had not reached the merits of the forfeiture claims, and thus the claimant had not “substantially prevailed.” This raised an important legal question about how CAFRA applies after a government dismissal with prejudice.
For more on foundational forfeiture law and fee-shifting principles, see our article on federal civil asset forfeiture.
What Happened on Appeal
Sammis Law Firm represented the claimant in the Eleventh Circuit Court of Appeals. On appeal, the focus was whether a dismissal with prejudice materially alters the legal relationship between the government and the claimant in a way that satisfies CAFRA’s “substantially prevails” standard.
The Eleventh Circuit vacated the district court’s denial of attorney’s fees and remanded for further proceedings, holding that:
- A dismissal with prejudice can materially alter the parties’ legal relationship.
- A claimant does not need a merits ruling to substantially prevail under CAFRA.
- A court-ordered dismissal with prejudice can supply the judicial imprimatur necessary for CAFRA fee-shifting.
This ruling prevents the government from avoiding CAFRA fee liability by dismissing forfeiture cases after being confronted with strong defense motion practice.
Key Takeaways
- A dismissal with prejudice can satisfy CAFRA’s “substantially prevails” standard for attorney’s fees.
- The government cannot avoid CAFRA fee liability solely by dismissing a forfeiture action before a merits ruling.
- Strategic trial-level motion practice can meaningfully influence appellate outcomes in forfeiture litigation.
- The Eleventh Circuit clarified the application of the CAFRA fee-shifting provision.
Why This Case Matters
This decision reinforces that litigants who defend federal civil forfeiture cases successfully—even through a dismissal with prejudice—may recover statutory attorney’s fees under CAFRA. The ruling also shapes how defense counsel handle dispositive motions and settlement strategy in federal forfeiture litigation.
For example, in airport cash seizure contexts like this one, robust defense strategy can influence not only case outcomes but also the ability to recover litigation costs.
Related: Airport cash seizure defense strategies and how they intersect with federal forfeiture law.