United States v. JP Morgan Chase Bank Account

Ladislao Samaniego and Manuel Castro (collectively, Claimants) challenge the government’s seizure of two J.P. Morgan Chase bank accounts in a civil asset-forfeiture action. One account, totaling $446,377.36, was held in the name of Sa-maniego; the other, totaling $361,070.25, in the name of Castro. In a verified complaint seeking forfeiture, the government contends that Claimants unlawfully used the accounts to launder money connected with illicit drug proceeds.

Claimants answered and filed verified claims in response to the complaint, alleging that they held ownership and possesso-ry interests in the seized funds sufficient to confer standing. The parties filed cross-motions for summary judgment. The district court entered judgment in favor of the government, holding that Claimants failed to produce adequate evidence of their Article III and prudential standing to contest the forfeiture. We reverse.

STANDARD OF REVIEW AND JURISDICTION

We have jurisdiction pursuant to 28 U.S.C. § 1291 . We review summary judgment determinations de novo. Wright v. Incline Vill. Gen. Improvement Dist., 665 F.3d 1128, 1133 (9th Cir. 2011). Summary judgment is appropriate when, viewing the…