Angela Y. Smith v. State of Indiana

Summary

The Indiana Supreme Court reversed the forfeiture order because the State failed to identify an applicable criminal offense and failed to prove a substantial connection between that offense and the seized money. The Court clarified that, in a contested money-forfeiture action, the State must first satisfy the burden applicable to the statutory avenue it invokes, and if it fails, the money must be returned to the person who proves ownership. Because Angela Smith was the only claimant and her ownership evidence was uncontradicted, the Court directed the trial court to release the money to her.