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Property used in the commission of certain crimes is forfeited by statute to the government.1 Forfeitures may be either criminal or civil.2 A criminal forfeiture is part of the punishment of a convicted individual.3 Seizure for forfeiture follows conviction.4 In contrast, civil forfeiture, with which this comment is concerned, is aimed at the "guilty" property itself.5 Seizure precedes a civil, in rem forfeiture trial.' Most courts hold that a judicial warrant is not required for the

Forfeiture Seizures and the Warrant Requirement