UNITED STATES COURT OF APPEALS
 
FOR THE NINTH CIRCUIT
 

UNITED STATES OF AMERICA, No. 95-50094

Plaintiff-Appellant, D.C. No.

v. CR-94-00544-JD

HOSEP KRIKOR BAJAKAJIAN, aka: (JR)-1

JOE BAJAKAJIAN, OPINION

Defendant-Appellee.
 

Appeal from the United States District Court
for the Central District of California
John G. Davies, District Judge, Presiding
 

Argued and Submitted

February 6, 1996--Pasadena, California
 

Filed May 20, 1996
 

Before: J. Clifford Wallace, Warren J. Ferguson, and

Thomas G. Nelson, Circuit Judges.
 

Opinion by Judge Ferguson;

Concurrence by Judge Wallace
 

_________________________________________________________________
 

SUMMARY
 

______________________________________________________________
 

5977
 

5978
 

________________________________________________________________
 

COUNSEL
 

Ronald L. Cheng, Assistant United States Attorney, Los

Angeles, California, for the plaintiff-appellant.
 

James E. Blatt, Encino, California, for the defendant-appellee.
 

_________________________________________________________________
 

OPINION
 

FERGUSON, Circuit Judge:
 

The United States appeals the decision of the district court

following the defendant's guilty plea to failure to report cur-

rency in violation of 31 U.S.C. S 5316(a)(1)(A).1 Specifically,

the United States appeals the district court's determination

that the defendant was required to forfeit only $15,000 of the

$357,144 at issue.2 We affirm the decision of the district

court.

_________________________________________________________________

1 31 U.S.C. S 5316(a) provides in pertinent part: a person or an agent or

bailee of the person shall file a report under subsection (b) of this section

when the person, agent, or bailee knowingly -
 

(1) transports, is about to transport, or has transported, mone-

tary instruments of more than $10,000 at one time-
 

(A) from a place in the United States to or through a place

outside the United States . . . .

2 In addition to appealing the district court's decision regarding the

amount of currency which Bajakajian should be required to forfeit, the
 

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I. Factual and Procedural Background
 

On June 9, 1994, Bajakajian was attempting to board an

Alitalia Airways flight leaving Los Angeles, destined for

Cyprus. While Bajakajian was waiting to board his flight,

U.S. Customs discovered approximately $140,000 concealed

in four pieces of Bajakajian's checked luggage and $90,000

concealed in a false bottom of one of his bags. After discover-

ing the hidden currency, a Customs inspector stopped the

defendant and his family at the airport and informed them that

they were required to report all money in both their personal

possession and baggage which exceeded $10,000, irrespective

of whether the money belonged to them. Bajakajian told the

Customs inspector that he had $8,000 with him and that his

wife had an additional $7,000. Bajakajian informed the

inspector that his family had no additional money to report.
 

Customs inspectors discovered a total of $357,144 in

United States currency in the carry-on baggage, checked-in

baggage, wallet, and purse of the defendant and his wife.

After being advised of his rights, Bajakajian admitted to Cus-

toms agents that he knowingly and wilfully failed to report the

currency which was discovered.
 

On July 8, 1994, a grand jury returned a three count indict-

ment against the defendant. Count One charged the defendant

with violation of 31 U.S.C. SS 5316(a)(1)(A) and 5322(a) for

transporting currency of more than $10,000 outside of the

United States without filing a report with the United States

Customs Service. Count Two charged the defendant with

making a false material statement to the United States Cus-

_________________________________________________________________

government has also appealed the district court's calculation of Bajakaji-

an's base offense level and the district court's failure to enhance Bajakaji-

an's sentence for obstruction of justice. However, this opinion only

addresses the government's appeal of the district court's forfeiture calcula-

tion. The remaining issues will be resolved in a separate disposition.
 

5980
 
 
 
 

toms Service in violation of 18 U.S.C. S 1001. Count Three

sought the forfeiture of the $357,144 discovered by Customs

under 18 U.S.C. S 982(a)(1).
 

On October 27, 1994, pursuant to a plea agreement, the

defendant entered a guilty plea as to Count One of the indict-

ment and waived a jury trial as to Count Three. The govern-

ment agreed to dismiss Count Two at the time of sentencing.

On December 20, 1994, a bench trial was held for Count

Three. The district court found that the entire $357,144 dis-

covered by Customs agents was subject to criminal forfeiture

pursuant to 18 U.S.C. S 982(a)(1). However, at sentencing,

the district court ordered the defendant to forfeit only $15,000

of the $357,144. The district court concluded that forfeiture of

more than $15,000 would be disproportionate to Bajakajian's

culpability, and therefore unconstitutional under the Exces-

sive Fines Clause of the Eighth Amendment. In calculating

the amount of forfeiture, the district court recognized that all

of the money at issue had come from a lawful source, and was

to be used for a lawful purpose.
 

II. Discussion
 

A district court's interpretation of federal forfeiture law is

reviewed de novo. United States v. 1980 Lear Jet, 38 F.3d

398, 400 (9th Cir. 1994).
 

The government alleges on appeal that the district court

erred in requiring forfeiture of only $15,000 because the

entire $357,144 at issue should have been forfeited. In the

alternative, the government requests forfeiture of $170,000,

the amount of currency which Bajakajian asked a friend to lie

about to Customs agents.
 

The forfeiture statute relevant to this litigation, 18 U.S.C.

S 982(a)(1), provides in pertinent part: "The court, in impos-

ing sentence on a person convicted of an offense in violation

of section 5313(a), 5316 or 5324 of title 31 . . . , shall order
 

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that the person forfeit to the United States any property, real

or personal, involved in such offense, or any property trace-

able to such property."
 

[1] Therefore, pursuant to 18 U.S.C.S 982(a)(1), the entire

$357,144 at issue in the present case is potentially forfeitable.

However, a forfeiture is unconstitutional unless it survives

scrutiny under the Excessive Fines Clause of the Eighth

Amendment. "The Excessive Fines Clause limits the Govern-

ment's power to extract payments, whether in cash or in kind,

`as punishment for some offense.'" Austin v. United States,

509 U.S. 602, 113 S. Ct. 2801, 2805 (1993) (citation omitted).

See also Alexander v. United States, 509 U. S. 544, 113 S. Ct.

2766, 2775-76 (1993) (holding that criminal forfeiture is a

form of monetary punishment subject to the Eight Amend-

ment's Excessive Fines Clause); United States v. Sarbello,

985 F.2d 716, 717-18 (3d Cir. 1993) (holding that a court may

reduce an otherwise mandatory 100% statutory criminal for-

feiture on the basis of the Excessive Fines Clause of the

Eighth Amendment). Therefore, forfeiture in the present case

must be subjected to analysis under the Excessive Fines

Clause.
 

The Supreme Court, in Austin, declined to enumerate the

factors to be considered in determining whether a forfeiture

violates the Excessive Fines Clause. Austin, 113 S. Ct. at

2812. We recently addressed this issue and established a two-

pronged test for determining whether a forfeiture is unconsti-

tutionally excessive under the Eighth Amendment. United

States v. Real Property Located in El Dorado County, 59 F.3d

974, 982 (9th Cir. 1995).
 

[2] Pursuant to this court's Excessive Fines Clause test, a

forfeiture is constitutional if: (1) the property forfeited is an

"instrumentality" of the crime committed; and (2) the value of

the property is proportional to the culpability of the owner.3

_________________________________________________________________

3 The district court bypassed the instrumentality prong of the two part El

Dorado Excessive Fines test and examined only the proportionality of for-
 

5982

Id. at 982. Therefore, Bajakajian cannot be ordered to forfeit

any currency unless forfeiture in the present case would sat-

isfy both the instrumentality and proportionality prongs of our

recently established Excessive Fines Clause test.
 

Application of the instrumentality prong of the Excessive

Fines test to a 31 U.S.C. S 5316 violation was recently dis-

cussed by this court in United States v. $69,292 in United

States Currency, 62 F.3d 1161 (9th Cir. 1995). The court

questioned whether the currency involved in a S 5316 viola-

tion could ever be considered the instrumentality of the crime

of failure to report. The court explained that it was not per-

suaded "that currency lawfully acquired and possessed has

that necessarily close relationship to the crime simply because

it has not been reported. The crime is the withholding of

information, 31 U.S.C. S 5316, not the possession or the

transportation of the money." Id. at 1167. The court further

explained that the money at issue in a S 5316 violation is not

contraband, and the money is presumed under the statutory

scheme to be lawfully acquired and possessed. The statute

does not impose a limit on the amount of U.S. currency which

may be exported to foreign jurisdictions. Persons leaving the

United States are free, as they have always been, to take with

them such amounts of cash as they so choose. Id.
 

This court, in $69,292, also rejected the argument that the

currency in a S 5316 violation satisfies the instrumentality

requirement based upon the notion that the currency's exis-

tence was a precondition to the reporting requirement of 31

U.S.C. S 5316.
 

Simply put the existence of the currency as a precon-

dition does not make it an instrumentality. For exam-

_________________________________________________________________

feiture in the present case. This is probably due to the fact that the Ninth

Circuit's decision in El Dorado was handed down subsequent to the dis-

trict court's decision.
 

5983
 
 
 
 

ple, we would not characterize lawfully earned

income an instrumentality forfeitable as such simply

because a taxpayer wilfully failed to report that

income on his tax return in violation of the tax code.

The government would have us stretch the fiction of

an "instrumentality" to the breaking point.
 

Id. at 1167-68 (citation omitted). See also Austin v. United

States, 113 S. Ct. 2801, 2811 (1993) (rejecting expansive def-

initions as to what qualifies as the instrumentality of a particu-

lar crime).
 

The government argues that the majority opinion in

$69,292 conflicts with the Supreme Court's decision in One

Lot Emerald Cut Stones v. United States, 409 U.S. 232

(1972). There, the Court upheld the forfeiture of imported

goods pursuant to 19 U.S.C. S 1497,4 where the defendant

failed to declare one lot of emerald cut stones and a ring upon

his entry into the United States. Id. at 233.
 

[3] However, $69,292 and One Lot Emerald Cut Stones are

not in conflict. One Lot Emerald Cut Stones involved the

smuggling of contraband. When a defendant is convicted for

failure to report currency pursuant to 31 U.S.C.S 5316, the

crime is not the illegal possession, transportation, or smug-

gling of dutiable items. Rather, the crime is merely the failure

to provide information. Money in lawful possession, as it was

here, is not contraband. Moreover, the currency at issue in a

S 5316 violation is not contraband, is presumed to be lawfully

_________________________________________________________________

4 19 U.S.C. S 1497 has since been amended, but at the time of One Lot

Emerald Cut Stones, it provided:
 

Any article not included in the declaration and entry as made,

and, before examination of the baggage was begun, not men-

tioned in writing by such person, if written declaration and entry

was required, or orally if written declaration and entry was not

required, shall be subject to forfeiture and such person shall be

liable to a penalty equal to the value of such article.
 

5984
 
 
 
 

possessed and is not subject to duty. It is not illegal to take

currency out of the country. The key difference is that a viola-

tion of S 5316 merely deprives the government of informa-

tion, whereas the smuggling of goods across the border

deprives the government of revenue. $69,292, 62 F.3d at

1167. Therefore, there is a much tighter instrumentality con-

nection between property sought to be forfeited and the crime

when the crime committed is the failure to pay a duty.5
 

[4] We hereby adopt the logic of the court in $69,292.6 For-

feiture of currency is unconstitutional when the crime to

which the forfeiture is tied is a mere failure to report pursuant

to 31 U.S.C. S 5316. In such situations, there simply is not an

instrumentality relationship between the currency and the

crime to satisfy the instrumentality prong of the Excessive

Fines test.7

_________________________________________________________________

5 Such a distinction is not new. See Austin v. United States, 113 S. Ct.

2801, 2811-12 (1993) (The Supreme Court distinguished cases involving

drug forfeitures from cases involving customs violations.).

6 The government alleges that the reasoning of the majority in $69,292

with respect to the Excessive Fines Clause and 31 U.S.C. S 5316 is dicta

because the district court might not have needed to address this issue on

remand. However, this portion of $69,292 is not dicta. "[D]irection to the

district on how to proceed continues to be binding precedent, even if char-

acterized as an alternative holding." Operating Eng'rs Pension Trust v.

Charles Minor Equip. Rental, Inc., 766 F.2d 1301, 1304 (9th Cir.)

(explaining that it was not dicta for the Ninth Circuit in Sapper v. Lenco

Blade, Inc., 704 F.2d 1069 (9th Cir. 1983) to direct the district court on

how to resolve an issue on remand which might only arise, depending

upon the resolution of another issue), modified, 778 F.2d 538 (9th Cir.

1985).

7 The government argues that United States v. One 1985 Mercedes-Benz,

14 F.3d 465 (9th Cir. 1994) provides support for forfeiture in the present

case. In One 1985 Mercedes-Benz, the court held that vehicles used to

export currency in violation of 31 U.S.C. S 5316 are subject to forfeiture

under 18 U.S.C. S 982. However, One 1985 Mercedes-Benz does not pro-

vide support for forfeiture in the present case for two reasons. First, a car

used to transport money is clearly the instrumentality of a S 5316 violation

because the car itself is used to export and conceal the currency. Second,
 

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[5] Therefore, the district court erred in ordering Bajakajian

to forfeit $15,000. Forfeiture of any amount would be uncon-

stitutionally excessive under the El Dorado Excessive Fines

Clause test. However, Bajakajian failed to file a cross-appeal

requesting a modification of the district court's order that he

forfeit $15,000. If an appellee seeks a modification of the dis-

trict court's judgment, he must file a cross-appeal requesting

the modification. Unless an appellee files a cross-appeal, "the

appellee may not attack the [district court's] decree with a

view either to enlarging his own rights thereunder or of less-

ening the rights of his adversary, whether what he seeks is to

correct an error or to supplement the decree with respect to a

matter not dealt with below." United States v. One 1964 MG,

584 F.2d 889, 890 (9th Cir. 1978) (quoting United States v.

American Ry. Express Co., 265 U.S. 425, 435 (1924)).
 

[6] Although pursuant to the Excessive Fines Clause

Bajakajian cannot be ordered to forfeit any of the unreported

currency, he is nonetheless forced to accept the decision of

the district court. Bajakajian failed to file a cross-appeal, and

therefore, this court lacks jurisdiction to set aside the district

court's forfeiture order of $15,000.
 

III. Conclusion
 

The decision of the district court is AFFIRMED.
 

_________________________________________________________________
 

WALLACE, Circuit Judge, concurring:
 

The majority takes our dicta in United States v. $69,292.00

in U.S. Currency, 62 F.3d 1161 (9th Cir. 1995) ($69,292), to

_________________________________________________________________

One 1985 Mercedes-Benz was decided prior to both El Dorado, which

established the two-pronged Excessive Fines test, and $69,292, which

applied the El Dorado test for the first time to a S 5316 violation. There-

fore, the facts of One 1985 Mercedes-Benz are not analogous to the facts

of the present case, and its logic is questionable due to the recent decisions

handed down by this court in El Dorado and $69,292.
 

5986
 
 
 
 

an illogical extreme. In so doing, the majority strikes down a

portion of 18 U.S.C. S 982(a)(1), thereby unduly limiting the

government's forfeiture powers. I agree only with the majori-

ty's ultimate decision to affirm the $15,000 forfeiture.

Because I would do so for entirely different reasons, I concur

in result only.
 

We are not bound by the dicta in $69,292. In $69,292, we

explained the analysis used to determine whether a forfeiture

violates the Eighth Amendment. $69,292, 62 F.3d at 1166-67,

citing United States v. Real Property Located in El Dorado

County, 59 F.3d 974 (9th Cir. 1995) (El Dorado). To satisfy

the Eighth Amendment's prohibition against excessive fines,

forfeited property must be instrumental to the crime and pro-

portional in value to the culpability of the owner. El Dorado,

59 F.3d at 982. In $69,292, the district court did not analyze

the forfeiture in terms of our intervening decision in El

Dorado. Thus, we remanded to enable the district court to

make appropriate findings. $69,292, 62 F.3d at 1168.
 

The majority would read $69,292 as holding that currency

involved in a section 5316 violation is never an instrumental-

ity of the crime. Majority at 8 & n.6. The majority's reading

of $69,292 renders all forfeitures of currency in such circum-

stances unconstitutional under our test in El Dorado. But if in

$69,292 we had held that all forfeitures of currency involved

in reporting violations necessarily fail El Dorado, we would

not have written that, "[w]e make no assessment as to whether

the forfeiture meets the El Dorado test." $69,292, 62 F.3d at

1168. As Judge Rymer accurately wrote in dissent, $69,292's

instrumentality discussion is dicta. Id. at 1168 (Rymer, J., dis-

senting).
 

Not only is this $69,292 discussion clearly dicta, but there

are two additional interrelated problems -- one with the

majority's interpretation of the dicta in $69,292 and one with

the $69,292 dicta itself.
 

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First, the majority misreads our remarks in $69,292. We

asserted there that we were not "persuaded that currency

lawfully acquired and possessed has the necessarily close

relationship to the crime simply because it has not been

reported." Id. at 1167 (emphasis added). Our remarks were

focused on the source of the defendants' funds, and we sug-

gested that legally obtained funds might not be instrumental.

See id. (explaining that "the reporting requirement applies to

all currency, whether it is lawfully gained or not," and sug-

gesting that we should analyze forfeiture based in part on the

source of the funds). If on remand the district court in $69,292

had found that the defendants acquired the funds illegally,

nothing in $69,292 would have precluded forfeiture.
 

The majority, purporting to "adopt the logic of the court in

$69,292," maj. op. at 9, overlooks $69,292's underlying ratio-

nale. The majority holds that "[f]orfeiture of currency is

unconstitutional when the crime to which the forfeiture is tied

is a mere failure to report pursuant to 31 U.S.C.S 5316." Id.

Thus, even if a district court finds that money was illegally

acquired, the majority does not allow forfeiture. Or, even if a

defendant's failure to report is combined with another viola-

tion of United States law (and the other law does not indepen-

dently allow forfeiture), the majority would still not allow

forfeiture. Nothing in $69,292's dicta supports this result.
 

Second, it is precisely $69,292's focus on lawfully acquired

funds that makes $69,292's instrumentality dicta problematic.

$69,292 suggests that instrumentality should turn, at least in

part, on the source of the funds. However, I interpret the

instrumentality inquiry as being completely divorced from the

source of the funds. After all, why is currency any more

instrumental when the currency is legally obtained as opposed

to when it is illegally obtained? See United States v.

$145,139.00, 18 F.3d 73, 75 (2d Cir.) (Currency was "an

instrument of the crime [of failure to report]. It was the

`means' by which the crime was committed. . . . Indeed, it

was the very sine qua non of the crime."), cert. denied, 115
 

5988
 
 
 
 

S. Ct. 71 (1994); Austin v. United States, 113 S. Ct. 2801,

2815 (1993) (Scalia, J., concurring) (explaining the instru-

mentality inquiry as being whether "property has been

`tainted' by unlawful use . . . . [in other words,] whether the

confiscated property has a close enough relationship to the

offense" (emphasis omitted)), quoted in El Dorado, 59 F.3d

at 982. In this case, the crime was Bajakajian's failure to

report $357,144 that he had secretly stashed. I cannot agree

with the majority that there is an insufficient nexus between

the acquired currency and the offense -- without the cur-

rency, there can be no offense.
 

Of course, the source of the acquired funds does have a

place in our Eighth Amendment inquiry under El Dorado.

However, the inquiry into the source of the funds is part of the

proportionality analysis, not the instrumentality inquiry. El

Dorado, 59 F.3d at 985-86 (explicitly requiring district court

to consider, as part of proportionality determination, the

"culpability of the owner"); see also id. at 983 (adopting "the

proportionality test as a check on the instrumentality

approach" because of the instrumentality prong's "potentially

harsh results, when applied alone"). If, as the district court

held, Bajakajian's funds were lawfully obtained from friends

and family and were not to be illegally used, then these facts

might warrant a reduced forfeiture to avoid an excessive fine.
 

I therefore disagree with the majority's conclusion that the

currency was not instrumental as a matter of law. I would

hold that the district court properly found that the entire

amount of currency was potentially forfeitable. The currency

was instrumental. As to proportionality, I would review for

clear error the district court's factual findings underpinning its

decision to forfeit only $15,000. See United States v. Alcaraz-

Garcia, 79 F.3d 769, 772 (9th Cir. 1996) (findings of fact

underlying forfeiture reviewed for clear error). The district

court found that the funds were lawfully acquired and were to

be lawfully used. The district court next found that forfeiture

of only $15,000 was proportional to Bajakajian's culpability.
 

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I do not believe that the district court's findings were clearly

erroneous; therefore, I would affirm the $15,000 forfeiture.
 

5990