## Facts

- Missouri State Highway Patrol and DEA stopped and searched a 1995 Volkswagen Golf driven by Roberto Lopez‑Velez and Guadalupe Cortez‑Amezcua.
- Agents found $24,000 concealed in the vehicle’s battery compartment and seized both the cash and the car as suspected drug proceeds.
- The DEA pursued administrative forfeiture; Lopez‑Velez initially contested but abandoned the challenge, and the DEA forfeited the car and $24,000 to the United States.
- The United States later sold the forfeited Volkswagen as surplus property; Helen Chappell purchased it from the government.
- After purchase, a mechanic discovered $82,000 in bundled U.S. currency hidden in the vehicle’s fuel tank and notified the DEA.
- The DEA seized the $82,000 from the mechanic.
- Jeffery and Helen Chappell filed suit seeking return of the $82,000; the government asserted the money was drug proceeds subject to forfeiture and superior federal title.

## Issues

1. Whether the government, after forfeiting and selling the vehicle, could assert superior title to currency later discovered hidden inside the vehicle.
2. Whether the Chappells, as purchasers of the forfeited vehicle from the United States, acquired ownership of the hidden currency found within it.
3. Whether forfeiture principles, including any relation-back theory, allowed the government to defeat the claim of bona fide purchasers for value in these circumstances.

## Decision

- Summary judgment was entered for the Chappells.
- The court held the United States was not entitled to the $82,000 discovered in the fuel tank after the government’s sale of the forfeited vehicle.
- The court ordered return of the $82,000 to the Chappells.

## Legal Principles

- When the government takes title to property through forfeiture and then sells that property without reserving rights to undiscovered contents, the purchaser takes the government’s conveyed interest in the property, including hidden contents later found within it.
- Forfeiture is statutory; the government must follow prescribed procedures to obtain title to specific property, and it cannot use a later assertion of forfeiture to override rights created by its own completed disposition of the forfeited res.
- Relation-back concepts do not permit the government, after selling forfeited property to an innocent purchaser, to reclaim subsequently discovered currency hidden inside the sold property where the government had control and opportunity to discover and seize it before sale.
- Bona fide purchasers for value from the government are protected where the government’s post-sale claim would undermine finality and reasonable reliance on government forfeiture and sale processes.

## Conclusion

The court concluded that, because the United States forfeited the Volkswagen, sold it to an innocent purchaser, and did not separately seize or forfeit the $82,000 before the sale, the government could not later claim the hidden currency against the purchasers; the $82,000 had to be returned to the Chappells.


In re Seizure of $82,000 More or Less, 119 F. Supp. 2d 1013 (W.D. Mo. 2000)