& Bldg. Known as 303 West 116th Street, New York, New York, 901 F.2d 288, 291 (2d Cir.1990); United States v. One 56-Foot Motor Yacht Named Tahuna, 702 F.2d 1276, 1281 (9th Cir.1983). Third, summary seizure procedures are available to the federal government in forfeiture cases. See 21 U.S.C. § 881(b). The ability to seize a leaseholder’s property using such procedures — without proof that it is more likely than not that the resident engaged in, or permitted, drug-related criminal activity — is an awesome power, which both Congress and the Supreme Court have seen fit to rein in. See id. § 881(a)(7) (incorporating “innocent tenant” exception and allowing seizure of property only where the drug offense is punishable by more than one year imprisonment); Bajakajian, 118 S.Ct. at 2031 (<HOLDING>). Congress sensibly limited forfeiture to the
holding that forfeitures may violate the eighth amendment excessive fines clause recognizing culpability as important criteria for eighth amendment excessive fines claim holding that excessive fines clause of eighth amendment does not apply to punitive damage awards between private parties holding that the fines imposed by the challenged city ordinances are not excessive even if the excessive fines clause is applicable holding that excessive fines clause does not apply to civiljury award of punitive fines