The Road to Recovery
Recently, the U.S. Supreme Court examined the due process required during civil forfeiture proceedings in Culley v. Marshall.5 The petitioners, two individuals seeking recovery of vehicles seized and subject to forfeiture in Alabama, asked the Court to rule that due process in civil forfeiture proceedings be examined under the doctrine developed by the Court in Mathews v. Eldridge. Specifically, the claimants attempted to retrieve their property through a preliminary postdeprivation hearing. In Zachary J.