FEAR's Brief Bank II
 
Motions, pleadings and briefs


Brief Bank II: indexed by issue

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Sovereign immunity [ 377 ]

POINTS AND AUTHORITIES IN SUPPORT OF CLAIMANT’S MOTION FOR

RECONSIDERATION OF THE ORAL RULING ON SOVEREIGN IMMUNITY

The Civil Asset Forfeiture Reform Act of 2000 (“CAFRA”) waived sovereign immunity to allow successful

forfeiture claimants to sue for money damages under the Federal Tort Claims Act for “any claim based on

injury or loss of goods, merchandise or other property” while held by law enforcement agencies for the

purpose of forfeiture. Here, the Flash II was also sold for a tenth of its value while the forfeiture litigation was

pending. Now that he has prevailed in the forfeiture litigation, Dr. Lane is entitled to the full fair market value of

his interest in Flash II. The government nevertheless attempts to hide behind the discretionary function

exception to the Federal Tort Claims Act, 28 U.S.C. § 2680(a). It argues that “the law presumes that a decision

is grounded in policy (social, economic or political)” and claims that unless Dr. Lane can show that the

government conduct violated a mandatory regulation its conduct must be deemed discretionary. The

government claimed Dr. Lane bears the burden of proof on this issue. This is a misstatement of the law. …

“Where all interested parties do not agree to the interlocutory sale, federal statutes and case law provide means

of obtaining the court’s approval for a contested sale, pursuant to complex and strict guidelines.” …

Procedure for conducting a contested interlocutory sale

by Grantland, Brenda

U.S. v. ONE STAR CLASS SLOOP SAILBOAT NAMED “FLASH II” D.Mass. 05-10192 ( 2007 )

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Monday, October 08, 2007 Page 1 of 1



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