J.W. Goldsmith, Jr.Grant Co. v. United States, 254 U.S. 505, 512, 41 S.Ct. 189, 191, 65 L.Ed. 376 (1921) (expressly reserving question whether "property stolen from the owner or otherwise taken from him without his privity or consent” may be forfeited); Peisch v. Ware, 8 U.S. (4 Cranch) 347, 361-63, 2 L.Ed. 643 (1808) ("a forfeiture can only be applied to those cases in which the means that are prescribed for the prevention of a forfeiture may be employed”). 15 . See, e.g., Clagett, 3 F.3d at 1357 (property owners have right to adequate notice prior to administrative forfeiture); United States v. Rogers, 984 F.2d 314, 317 (1993) (recognizing possibility of due process challenge to forfeiture statute in specific case of prosecutorial misconduct); One 1985 Mercedes, 917 F.2d at 420 (<HOLDING>); Wiren, 542 F.2d at 763 (recognizing due
holding that due process encompasses the right to counsel in a civil contempt proceeding holding discovery rules apply to civil forfeiture proceedings holding that both fourth amendment warrant and probable cause and fifth amendment due process requirements apply to civil forfeiture proceedings holding that exclusionary rule applies to civil forfeiture proceedings holding that vindictive prosecution claims in civil forfeiture proceeding may raise due process questions