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Criminal Law: Civil Forfeiture-Default Judgment-Motion to Supplement Record
Staff Report//June 17, 2026//
Marain Rankin appealed the entry of default judgment for the government in the civil forfeiture action and moved to supplement the record. The government moved for judicial notice of related criminal case records. The government sought forfeiture of cash seized during a search of Rankin’s residence.
Where Rankin had sufficiently alleged his status as a claimant of the currency, the district court erred in entering default judgment.
Judgment is reversed and remanded.
U.S. v. $5,500 in U.S. Currency (MLW No. 84930/Case No. 25-3170 – 3 pages) (U.S. Court of Appeals, 8th Circuit, per curiam) Appealed from U.S. District Court, Southern District of Iowa.
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