United States v. Ursery

Police found marijuana growing in a house belonging to Ursery (defendant). The United States (plaintiff) brought forfeiture proceedings against Ursery’s home on grounds that it had been used in the manufacture and distribution of an illegal substance. Ursery was also convicted of manufacturing marijuana. On appeal, the court reversed Ursery’s conviction. The court held that the Double Jeopardy Clause barred the criminal charge because Ursery had already been punished for the same conduct in the forfeiture proceeding. In a separate case, two men, Arlt and Wren, were convicted of making methamphetamine and money laundering. Both were sentenced to life imprisonment. Before their trial, the United States had brought an in rem action against property belonging to Arlt and Wren and to Payback Mines, a company Arlt owned. The forfeiture action was delayed until after Arlt and Wren’s criminal trial. The action was based on a statute that stated that any property involved in money laundering was subject to forfeiture. After the trial and conviction, the district court granted summary judgment in the forfeiture action in favor of the United States. On appeal, the court reversed the decision in the forfeiture action and held that the Double Jeopardy Clause barred the forfeiture action. Both the court in Ursery’s case and the court in Arlt and Wren’s case based their decisions on case law that they believed suggested that a forfeiture is punishment for double jeopardy purposes. The Supreme Court consolidated the two cases and granted certiorari.