element of a seizure because the facts of Good involved some level of physical intrusion. The Supreme Court never indicated, however, that the exercise of physical control over the defendant real property should be regarded as the sine qua non of a constitutionally cognizable seizure. To the contrary, the Supreme Court employed the term seizure more broadly to refer to governmental action that deprived claimant Good of significant property interests. See Good, 510 U.S. at 49, 114 S.Ct. at 498 (stating that “[t]he Government does not, and could not, dispute that the seizure of Good’s home and four-acre parcel deprived him of property interests protected by the Due Process Clause”); see also United States v. Jacobsen, 466 U.S. 109, 113, 104 S.Ct. 1652, 1656, 80 L.Ed.2d 85 (1984) (<HOLDING>). In essence, the Supreme Court declared in
holding that in the fourth amendment context a seizure of property occurs when there is some meaningful interference with an individuals possessory interests in that property holding that a seizure occurs when there is a significant interference with a persons possessory or ownership interest in property holding that forfeiture of real property may be adjudicated before the seizure occurs because real property cannot abscond holding that an initially reasonable seizure can become an unreasonable seizure that violates the fourth amendment when officers refuse to return seized property holding that there was no fourth amendment seizure where delivery of package was not delayed because it is the extent of the interference with the defendants possessory interest in the property that determines whether a seizure has occurred