United States v. $8,040.00 United States Currency

CourtDistrict Court, W.D. New York
DecidedJuly 21, 2025
Docket6:21-cv-06323
StatusUnknown

This text of United States v. $8,040.00 United States Currency (United States v. $8,040.00 United States Currency) is published on Counsel Stack Legal Research, covering District Court, W.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. $8,040.00 United States Currency, (W.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA, 6:21-CV-6323-CJS Plaintiff, DECISION AND ORDER $8,040 UNITED STATES CURRENCY, Defendant.

INTRODUCTION This is an in rem action pursuant to 21 U.S.C. § 881(a)(6) for civil forfeiture of money seized during a drug trafficking investigation in Rochester, New York. Plaintiff United States Attorney’s Office (“Government”) initiated the proceeding against $8,040 in United States currency seized from the home of Claimant Cristal Starling. Before the Court is the Government’s notice of voluntary dismissal without prejudice under Rule 41(a)(1) of the Federal Rules of Civil Procedure (ECF No. 27), and the Government’s motion for voluntary dismissal without prejudice pursuant to Rule 41(a)(2) should dismissal by notice be unavailable. (ECF No. 36). Claimant Starling opposes the Government’s attempt to dismiss by notice and its motion for dismissal without prejudice. (ECF Nos. 38, 42). Also before the Court is Starling’s application for attorney fees, costs, and interest under the Civil Asset Forfeiture Reform Act (“CAFRA”) (28 U.S.C. § 2465). Id. For the reasons that follow, the Government is not entitled to voluntary dismissal by notice, the Government’s motion to dismiss without prejudice is granted, and Starling’s request for CAFRA fees is denied.

BACKGROUND This action arises from the seizure of $8,040 in United States currency from the home of Claimant Cristal Starling by the Rochester Police Department (“RPD”) on October 29, 2020. (ECF No. 1). The money was seized during the execution of a search warrant related to a drug trafficking investigation into Starling’s then-boyfriend K.B. Jd. After RPD turned the money over to the Drug Enforcement Administration (“DEA”), the DEA initiated an administrative forfeiture procedure to claim the funds as drug proceeds. (ECF Nos. 1, 28). Starling filed a claim to the currency with the DEA in January 2021, which terminated the administrative proceeding and prompted the United States Attorney’s Office to initiate the subject judicial forfeiture proceeding by filing a complaint against the currency in April 2021. Id. On June 14, 2021 the Government served Starling with a copy of the complaint and notice of the forfeiture action. (ECF No. 4). It also posted an official notice on the Government’s civil forfeiture website, (ECF No. 5). The notice stated that to contest the forfeiture, Starling needed to file a verified claim to the currency by July 16, 2021. (ECF No. 6 4] 4). Starling did not file a claim by that deadline, and the Government moved for an entry of default on August 20, 2021. (ECF. No. 6 § 7). This Court entered default on August 24, 2021. (ECF No. 7). The Government then moved for default judgment on September 3, 2021. (ECF No. 8). Roughly three months later, before the motion for default judgment was decided, Starling, acting pro se, wrote a letter to the U.S. Attorney’s office and this Court, seeking return of the currency. (ECF No. 9). Following a settlement offer from the Government, Starling wrote another letter, filed December 3, 2021. (ECF No. 10).

In the December 3, 2021 letter, Starling rejected the Government’s settlement offer. Jd. She also stated that “nothing illegal’ was found in her home. Jd. She said that she wanted “to move forward with court proceedings to have all of the funds returned to [her] promptly,” and that she was entitled to the return of the defendant currency because the criminal charges in the case against her then-boyfriend were “dismissed based on [a]cquittal of all matters in the City {C]ourt of Rochester NY.” Jd. On December 15, 2021 the Government moved to strike what it called Starling’s “late claim and answer,” since they were filed after the deadline given in the Government’s forfeiture notice. (ECF No. 11). On February 3, 2022 this Court granted the Government’s motion to strike and entered default judgment in favor of the Government. (ECF No. 18). Starling appealed to the Second Circuit Court of Appeals. The Second Circuit found that Starling’s December 3, 2021 filing should have been interpreted as both a motion to file a late claim and a motion to lift entry of default. See United States v. Starling, 76 F 4th 92 (2023). It said that this Court interpreted Starling’s pro se filings too narrowly, and used the wrong standard to assess her motions for lifting entry of default and to file a late claim. /d. On September 27, 2023 the Second Circuit issued a mandate vacating this Court’s entry of default and its denial of Starling’s late claim. (ECF No. 28). Considering the Second Circuit’s mandate, which allowed Starling to continue her judicial pursuit of the currency, the Government decided it no longer wished to proceed. As the Government later explained, the amount of currency at issue no longer met the “current thresholds of the USAO-WDNY.” (ECF No. 41 at 13).

On the day the Second Circuit issued its mandate, the Government filed notice of voluntary dismissal without prejudice, pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(i). The Government claimed that it was entitled to voluntarily dismiss its action, without court order, because Starling had not filed an answer to the Government’s complaint. against the currency. (ECF No. 27). Starling, now represented by counsel, indicated that she opposed the Government’s attempt to voluntarily discontinue the action. The Court then ordered the parties to brief the following issues: 1) whether the Government was able to voluntarily discontinue the action without prejudice as a matter of right; 2) ifnot, whether the Court should dismiss the action with prejudice or without prejudice; and 3) whether Starling was entitled to CAFRA fees. In the meantime, on December 14, 2023, the Government informed the Court that it intended to release the defendant currency to Starling, and the Court ordered its release. (ECF No, 34-35). On December 22, 2023 the Government submitted a motion to voluntarily dismiss without prejudice by court order, pursuant to Rule 41(a)(2), should dismissal by notice be unavailable under Rule 41(a)(1). (ECF No. 36). Starling opposes the Government’s attempts to dismiss without prejudice. Starling contends that the Government is not entitled to dismissal by notice because her December 3, 2021 pro se filing constitutes an answer and precludes dismissal under Rule 41(a)(1)(A)(i). She also argues that the court should order Rule 41(a)(2) dismissal with prejudice, based on relevant Second Circuit authority. Finally, she argues that she is entitled to attorney fees, litigation costs, and interest under the Civil Asset Forfeiture Reform Act (“CAFRA”) (28 U.S.C. § 2465) because she “substantially prevailed” in a civil forfeiture proceeding. (ECF Nos. 38, 42).

DISCUSSION The following issues are before the Court: 1) whether Starling filed an answer, and therefore whether the Government is entitled to voluntary dismissal by notice under Rule 41(a)(1)(A)(i); 2) whether, if Starling has filed an answer and dismissal by notice is not available, the Court should order dismissal with or without prejudice under Rule 41(a)(2); and 3) whether Starling has “substantially prevailed” under CAFRA, entitling her to attorney fees, litigation costs, and interest. I. The Government cannot dismiss by notice because Starling’s December 3, 2021 pro se filing qualifies as an answer.

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United States v. $8,040.00 United States Currency, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-804000-united-states-currency-nywd-2025.