forfeiture of clothing store inventory because clothing store facilitated credit card scam by providing facade of respectability and lawfulness); United States v. Baker, 227 F.3d 955, 969-70 (7th Cir.2000) (upholding forfeiture of entire sex-oriented business, including legitimate operations, when used to launder proceeds of prostitution and other illegal activity); United States v. Swank Corp., 797 F.Supp. 497, 502 (E.D.Va.1992) ("[T]he ability to forfeit a business entity which is used to facilitate the offense of money laundering is well established”). The forfeiture of property used to "facilitate” a crime is subject to a ceiling established by the Eighth Amendment Excessive Fines Clause. See United States v. Bajakajian, 524 U.S. 321, 334, 118 S.Ct. 2028, 141 L.Ed.2d 314 (1998) (<HOLDING>). Yet, in this case the government has adduced
holding that excessive fines clause does not apply to civiljury award of punitive fines holding that punitive damages are not fines holding that forfeitures may violate the eighth amendment excessive fines clause holding that the fines imposed by the challenged city ordinances are not excessive even if the excessive fines clause is applicable holding that punitive forfeiture will violate the excessive fines clause if grossly disproportional to the gravity of the offense