U.S. v. Shaaban

Defendant was not entitled to remand for reconsideration of denial of his motion for return of property seized by police in conjunction with defendant's criminal proceedings where said motion was made after defendant's conviction for crimes associated with assisting Iraq. While Dist. Ct. should have permitted defendant to convert his Rule 41(g) motion to civil proceeding (upon defendant's payment of civil filing fee), rather than requiring defendant to initiate new lawsuit, defendant did not timely appeal Dist. Ct.'s denial order. However, defendant can initiate new civil action seeking return of his property since relevant limitations period permits said filing within 6 years from close of criminal proceeding.