Culley v. Marshall
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Culley v. Marshall and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Culley v. Marshall.
In Culley v. Marshall, the Supreme Court addressed the issue of whether due process requires a preliminary hearing before a forfeiture hearing in civil forfeiture cases involving personal property. The Court affirmed the Eleventh Circuit's decision, holding that a timely forfeiture hearing satisfies due process requirements and no separate preliminary hearing is needed. The case involved the seizure of cars under Alabama's civil forfeiture law after arrests for drug-related offenses.
Holding
The single most important “bottom line” of what the Court decided in Culley v. Marshall.
The Court held that in civil forfeiture cases involving personal property, the Due Process Clause requires a timely forfeiture hearing but does not require a separate preliminary hearing.
Constitutional Concepts
These are the Constitution-related themes that appear in Culley v. Marshall. Click a concept to see other cases that involve the same idea.
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Why Procedural Due Process is relevant to Culley v. Marshall
The case primarily addresses whether due process requires a preliminary hearing before a forfeiture hearing in civil forfeiture cases.
Syllabus excerpt (verbatim)Held: In civil forfeiture cases involving personal property, the Due Process Clause requires a timely forfeiture hearing but does not require a separate preliminary hearing.
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Why Search and Seizure is relevant to Culley v. Marshall
The case involves the seizure of personal property (cars) incident to an arrest, which implicates Fourth Amendment considerations.
Syllabus excerpt (verbatim)Petitioner Halima Culley loaned her car to her son, who was later pulled over by Alabama police officers and arrested for possession of marijuana.
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Why Excessive Fines is relevant to Culley v. Marshall
While not central, the case involves civil forfeiture, which can raise issues under the Excessive Fines Clause.
Syllabus excerpt (verbatim)The State of Alabama filed forfeiture complaints against Culley's and Sutton's cars just 10 and 13 days, respectively, after their seizure.
Key Quotes
Short excerpts from the syllabus in Culley v. Marshall that support the summary and concepts above.
The Court's decisions in $8,850 and Von Neumann make crystal clear that due process does not require a separate preliminary hearing.
Due process requires a timely post-seizure forfeiture hearing.
Petitioners' efforts to distinguish Von Neumann on the ground that the statutory remission procedure in that case was discretionary fail.
