Illinois Appellate Court
Civil Court
Forfeiture
State initiated forfeiture proceedings after money was discovered in vehicle driven by Claimant, who claimed ownership of currency but was barred from testifying or presenting evidence after invoking Fifth Amendment rights. Court properly entered summary judgment in favor of State. State need show only reasonable grounds for belief that a nexus between property and illegal drug activity existed, and burden can be met without showing that such a nexus actually existed. Summary judgment can be entered without assumption or inference that bag exchanged for currency actually contained narcotics. Totality of circumstances leads to a finding of probable cause in forfeiture proceedings.(HOFFMAN and DELORT, concurring.)