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In re Forfeiture of 1985 Ford Ranger Pickup Truck, Vin 1FTBR10S7FUB74784, Florida License 802-DPU & $453 U.S. Currency

Citations: 582 So. 2d 3; 1991 Fla. App. LEXIS 3694Docket: No. 89-03063

Court: District Court of Appeal of Florida; April 18, 1991; Florida; State Appellate Court

Narrative Opinion Summary

In this case, the appellate court reviewed a trial court's decision concerning the forfeiture of a vehicle used in criminal activities, specifically drug-related activities and an attempted assault on a police officer. The vehicle, co-owned by a father and son, was initially ruled by the trial court to be exempt from forfeiture under the 'innocent spouse' exception in section 932.703(2) of the Florida Statutes, with the father deemed an innocent owner. However, the appellate court reversed this decision, disagreeing with the trial court's constitutional interpretation regarding due process and equal protection. The appellate court held that section 932.703(2) was constitutional and did not infringe on these principles. It clarified that an 'innocent owner' does not need to have full ownership if ownership is divisible and remanded the case for an evidentiary hearing to ascertain whether the father had knowledge of his son's illicit activities. The decision highlights the balance between state forfeiture rights and the protection of innocent property owners. Judge Booth dissented, offering a separate opinion.

Legal Issues Addressed

Constitutionality of Section 932.703(2), Florida Statutes

Application: The appellate court found that section 932.703(2) did not violate due process or equal protection clauses, unlike the trial court's interpretation.

Reasoning: The appellate court disagreed with the trial court's constitutional analysis, asserting that section 932.703(2) does not violate due process or equal protection clauses.

Forfeiture of Property Used in Criminal Activities

Application: The appellate court determined that the forfeiture of the vehicle was warranted as it was used in drug-related activities and an attempted assault on a police officer.

Reasoning: The appellate court reversed the trial court's decision denying the forfeiture of a 1985 Ford Ranger pickup truck, which had been seized by the State of Florida on July 1, 1989, due to its use in drug-related activities and an attempted assault on a police officer by Alan R. Barry.

Innocent Owner Defense under Florida Statutes

Application: The court recognized that an 'innocent owner' defense is valid if the co-owner had no knowledge of the criminal use of the property, requiring further proceedings to evaluate the father's awareness of the son's actions.

Reasoning: The court emphasized that the state has the right to pursue property involved in criminal activity, but cannot take property from individuals who have no knowledge of wrongdoing.