that civil forfeiture of money connected with conspiracy and money laundering, after the claimants had been convicted and sentenced for those crimes, violated the constitutional prohibition against double jeopardy. 405, 33 F.3d at 1220. Although the criminal conviction in 405 preceded the civil forfeiture, the Ninth Circuit emphasized that its holding applied equally to situations in which the sequence was reversed. Id. at 1222; see also United States v. Chick, 61 F.3d 682, 686 (9th Cir.1995). A court cannot invalidate a criminal conviction on double jeopardy grounds unless jeopardy attached in the civil forfeiture proceeding against the claimant-defendant’s property or currency before it attached in the criminal action. See United States v. Kearns, 61 F.3d 1422, 1428 (9th Cir.1995) (<HOLDING>). Thus, Garcia would only be entitled to relief
holding that double jeopardy clause did not apply to forfeiture proceeding before the court holding that convictions for the crimes of conspiracy and continuing criminal enterprise violate double jeopardy holding that conviction did not violate double jeopardy where jury was empaneled and sworn in criminal trial before defendant filed answer to forfeiture complaint holding that where a conviction is reversed after trial the double jeopardy clause does not bar a government appeal that if successful would only reinstate the conviction and would not subject defendant to a second trial holding that conviction of and punishment for both the underlying predicate offense and continuing criminal enterprise does not violate double jeopardy