there is a rebuttable presumption that the forfeiture is punitive in nature. Id. at 36 (citation omitted; emphasis in original). The court ultimately determined, however, that “[e]ven assuming the entire amount of the forfeiture here is punishment, it does not violate the outer confines set by the Eighth Amendment.” Id. at 38. Similarly, several other circuits, while recognizing that civil forfeiture provisions have been limited by some crimin 3097 S.W. 111th Ave., 921 F.2d 1551, 1557 (11th Cir.1991) (noting that the Eighth Amendment proportionality analysis used in criminal forfeiture cases does not apply in civil forfeiture cases); United States v. On Leong Chinese Merchant Ass'n Bldg., 918 F.2d 1289 (7th Cir. 1990), cert. denied, — U.S. —, 112 S.Ct. 52, 116 L.Ed.2d 29 (1991) (<HOLDING>); United States v. Santoro, 866 F.2d 1538, 1542
holding the fourteenth amendment does not apply to the actions of the federal government holding that the seventh circuit continues to adhere to the view that the eighth amendment does not apply to civil in rem actions recognizing that courts have uniformly held that the eighth amendment does not apply to civil in rem actions since they are remedial in nature and not punishments for crimes holding the claimant does not consent to personal jurisdiction by appearing in in rem action holding that a party cannot waive in rem jurisdiction under florida law and a court proceeding pursuant to in rem jurisdiction must actually possess in rem jurisdiction over the property that is the subject of the matter