United States v. 1980 Lear Jet, Model 35A, Serial Number 277

The holder of a mechanic’s lien against property subject to forfeiture appeals from that portion of the district court’s judgment denying costs, fees, and interest on the lien principal, arguing that the district court erred by concluding that an innocent lien-holder was not entitled to interest under federal forfeiture law. For the reasons which follow, we reverse and remand.

FACTS AND PRIOR PROCEEDINGS

On April 13, 1989, Aero Servicios Ejecuti-vos Sinaloenses, S.A. de C.V. (“ASES”), a Mexican corporation and owner of a 1980 Lear Jet airplane (“jet”), entered into a maintenance and repair agreement with the Arizona office of Learjet, Inc. (“Learjet”), a Delaware corporation. Learjet performed the work requested and billed ASES therefor on June 12, 1989. When ASES failed to pay the $55,736.53 repair bill, Learjet placed the jet in its hangar. The federal government seized the jet on or about August 4,1989, and filed the instant forfeiture action on February 13, 1990.

ASES, Learjet, and Mike Donahoe dba Mike Donahoe Aviation Company (“Dona-hoe”) filed claims with the district court regarding the disposition of the jet. ASES defaulted and the district court later entered summary…