State of Indiana v. $2,435 in United States Currency and Alucious Q. Kizer

Summary

The Indiana Supreme Court held that Article 1, Section 20 of the Indiana Constitution guarantees a jury trial to a claimant in an in rem civil-forfeiture action. Applying a historical test focused on the nature of the claim and relief sought, the Court concluded that forfeiture of money allegedly used in or obtained from criminal activity is essentially legal rather than equitable. The Court affirmed the trial court and remanded for a jury trial.