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Culley v. Marshall, 601 U.S. 377 (2024), is a case decided by Supreme Court of the United States regarding the timing of post-seizure probable cause hearings under the Due Process Clause of the 14th Amendment.[1] The Court has been asked to determine whether the "speedy trial" test from Barker v. Wingo or the balancing test from Mathews v. Eldridge applies to a judicial-forfeiture proceeding.
| Culley v. Marshall | |
|---|---|
 | |
| Argued October 30, 2023 Decided May 9, 2024 | |
| Full case name | Halima Tariffa Culley, et al. v. Steven T. Marshall, Attorney General of Alabama, et al. |
| Docket no. | 22-585 |
| Citations | 601 U.S. 377 (more) |
| Argument | Oral argument |
| Decision | Opinion |
| Case history | |
| Prior | 2022 WL 2663643; 2022 U.S. App. LEXIS 18975 |
| Court membership | |
| |
| Case opinions | |
| Majority | Kavanaugh, joined by Roberts, Thomas, Alito, Gorsuch, Barrett |
| Concurrence | Gorsuch, joined by Thomas |
| Dissent | Sotomayor, joined by Kagan, Jackson |
The case is on appeal from the United States Court of Appeals for the Eleventh Circuit.[1]
On February 17, 2019, Halima Tariffa Culley's son was arrested while driving his mother's car.[2] Police charged Culley with possession of marijuana and seized the car. Culley's mother was unable to recover the vehicle, and the State of Alabama filed a civil asset forfeiture case against the vehicle. 20 months later, Culley won summary judgment under Alabama's innocent-owner defense.[2]
Culley then filed a class-action lawsuit under the Ku Klux Klan Act, alleging that Alabama officials had violated her right to a post-deprivation hearing under the 8th and 14th Amendments to the Constitution.[2] The District Court found for Alabama and the 11th Circuit affirmed.[2]
On October 30, 2023, the US Supreme Court heard oral arguments in Culley v. Marshall.[3][4][5]
On May 9, 2024, the Court decided for the government. It held that "the Due Process Clause requires a timely forfeiture hearing but does not require a separate preliminary hearing". The majority opinion, written by Justice Brett Kavanaugh, based its conclusion on two prior Supreme Court decisions, United States v. Von Neumann[6] and United States v. $8,850.[7]
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