United States v. One 1985 Bmw 318i, Vin Wbaac8401f0685314

696 F. Supp. 336, 1988 WL 98953
CourtDistrict Court, N.D. Illinois
DecidedOctober 20, 1988
Docket87 C 3208
StatusPublished
Cited by9 cases

This text of 696 F. Supp. 336 (United States v. One 1985 Bmw 318i, Vin Wbaac8401f0685314) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. One 1985 Bmw 318i, Vin Wbaac8401f0685314, 696 F. Supp. 336, 1988 WL 98953 (N.D. Ill. 1988).

Opinion

MEMORANDUM OPINION AND ORDER

SHADUR, District Judge.

In this in rem proceeding, the United States seeks the forfeiture of a 1985 BMW automobile (the “BMW”) pursuant to 21 U.S.C. § 881(a)(4). 2 Stella Ifueko Ajibade (“Stella”), the owner of the BMW, has filed a claim in opposition to the forfeiture. Both the government and Stella have now moved for summary judgment under Fed. R.Civ.P. (“Rule”) 56. For the reasons stated in this memorandum opinion and order both motions are denied.

*338 Facts 3

Forfeiture of the BMW was occasioned by the arrest and later conviction of Stella’s husband Michael Kolawole Ajibade (“Kola”) 4 on drug charges. 5 Events both before and after the arrest bear on the sustainability of the forfeiture and on Stella’s claim and therefore require review.

In the early morning of November 12, 1986 Drug Enforcement Administration (“DEA”) officers had Ajibades’ residence at 6033 North Sheridan Road, Chicago under surveillance (Christopher Hacias (“Hacias”) Aff. 11111-2). Special Agent Hacias relates (Hacias Aff. 113):

At approximately 7:30 a.m., a red BMW 3181 [sic] which belong [sic] to the Aji-bades drove into the parking garage. After identifying ourselves as Drug Enforcement Agents we arrested the individual driving the car whom we subsequently learned was Peter Adeleke [“Adeleke”]. A search incident to the arrest revealed a white crystalline powder that we subsequently learned was approximately 24 grams of cocaine. 6

After arresting Adeleke the agents proceeded to Ajibades’ apartment. Kola was not home, but the government says Stella granted permission for the agents to enter and await his return. 7 At about 9:30 a.m. Kola appeared and was arrested, and a packet containing heroin was recovered from his shirt pocket. 8 Later that day the government took possession of the BMW. Stella says she was told at the time of the seizure that the agents were taking the car “downtown” to verify its ownership (Stella Dep. 47). Nonetheless the BMW has been in the government’s possession since November 1986.

Adeleke’s stay in custody was brief: On November 13, 1986 he was released on $4,500 bail. Stella says (and the government does not dispute) that the charges against Adeleke were dismissed within a week on the government’s motion (S. Mem. 4). Stella further asserts (though without marshalling any record support) the dismissal was occasioned by the government’s lack of probable cause for Adeleke’s arrest (S.R. Mem. 2-3) — another irrelevancy in this action (though discussed later in this opinion).

On April 6, 1987 the government filed its Complaint here seeking forfeiture of the BMW on the ground that Adeleke had used the vehicle to transport cocaine. After considerable delay Stella filed a claim seeking return of the car, 9 asserting she bought the *339 car in March 1985 with funds she had received as beneficiary of a life insurance policy on her father. 10 Stella also denies any knowledge of, or consent to, the BMW’s use by any person for any illegal purpose.

Legal Standards

As this Court has all too often had occasion to point out (and as litigants all too often appear to misunderstand), summary judgment is essentially a substitute for trial. For example, Hights v. International Harvester Co., 675 F.Supp. 418, 424 (N.D.Ill.1987) put the role of a successful Rule 56 motion in these terms:

It shows no evidentiary hearing is needed to resolve the parties’ legal dispute because no outcome-determinative facts are contested.

Although the normal Rule 56 principle is that the movant bears the burden of establishing the lack of a genuine issue of material fact (Celotex Corp. v. Catrett, 477 U.S. 317, 322-25, 106 S.Ct. 2548, 2552-54, 91 L.Ed.2d 265 (1986)), that burden is met if, in response to the motion, the nonmovant (id. at 322, 106 S.Ct. at 2552):

fails to make a showing sufficient to establish the existence of an element essential to that party’s case, and on which that party will bear the burden of proof at trial.

Section 881(a)(4) (on which the government relies here) calls for the forfeiture of:

All conveyances, including aircraft, vehicles, or vessels, which are used, or are intended for use, to transport, or in any manner to facilitate the transportation, sale, receipt, possession, or concealment of [controlled substances]....

Such forfeitures involve a shifting burden of proof. Initially the government must show probable cause exists to warrant the forfeiture (United States v. $84,000 U.S. Currency, 717 F.2d 1090, 1101 (7th Cir. 1983), cert. denied, 469 U.S. 836, 105 S.Ct. 131, 83 L.Ed.2d 71 (1984). That requires the demonstration of a “reasonable ground for belief or guilt; supported by less than prima facie proof but more than mere suspicion” (United States v. $250,000 in United States Currency, 808 F.2d 895, 897 (1st Cir.1987), quoting United States v. $364,-960, 661 F.2d 319, 323 (5th Cir.1981)). Once the government meets that test, the burden of proof shifts to a claimant “to show by a preponderance of the evidence that the property was not subject to forfeiture” ($84,000, 717 F.2d at 1101). 11

Claimants have three possible routes to defeat the government’s forfeiture efforts:

1. They can simply disprove the use or intended use of the conveyance to transport a controlled substance. 12
2. They can also establish one of the two express exceptions built into the statute:
(a) conveyances used as common carriers, unless the owner was a consenting party or was privy to a drug violation (Section 881(a)(4)(A)) or
(b) conveyances “unlawfully in the possession of a person other than the owner in violation of the criminal laws of the United States, or of any State” (Section 881(a)(4)(B)).

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Cite This Page — Counsel Stack

Bluebook (online)
696 F. Supp. 336, 1988 WL 98953, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-one-1985-bmw-318i-vin-wbaac8401f0685314-ilnd-1988.