Alvarez v. Smith
Headline: Illinois forfeiture challenge is declared moot and appeals court ruling vacated, dismissing the case and allowing future relitigation while leaving state seizure procedures unchanged for now.
Holding: The Court held the case is moot because the seized cars and cash were returned or forfeited, vacated the Court of Appeals’ decision, and instructed that the appeal be dismissed.
- Clears the appeals court decision so the issue can be relitigated later
- Allows property owners to sue for damages over warrantless seizures
- Leaves no immediate nationwide rule because the appeals decision is vacated
Summary
Background
Six people said Chicago police seized their cars or cash without a warrant under an Illinois law that allows police to seize property used to “facilitate” a drug crime and to hold it for up to about 142 days before starting court proceedings. The six sued, seeking a fast post-seizure hearing and asking a court to stop the State’s practice of keeping property without a prompt judicial check. A federal district court dismissed the suit, the Seventh Circuit ruled for the plaintiffs, and the State asked this Court to review that decision.
Reasoning
At oral argument the parties told the Court that the State had returned the cars and that the cash disputes were resolved or forfeited, so there was no longer a live dispute about who owned or possessed the property. Because the case no longer presented an actual, ongoing controversy between these plaintiffs and the State, the Court held the case moot under the Constitution’s requirement that courts decide only live disputes. The Court then applied existing rules about what to do in moot cases and concluded the lower court judgment should be vacated as the terminations appeared to be happenstance rather than a settlement designed to avoid review.
Real world impact
The vacatur clears the Seventh Circuit’s ruling so future owners can raise the same issue again in a new case. The decision does not establish a nationwide rule on Illinois forfeiture and leaves in place the possibility that property owners may still sue for damages in separate proceedings.
Dissents or concurrances
Justice Stevens agreed the case was moot but disagreed with vacating the appeals court judgment, arguing the public interest favors leaving that ruling intact.
Opinions in this case:
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