safeguards, have failed to extend Eighth Amendment protections to civil forfeitures. See United States v. One Parcel of Property Located at 508 Depot Street, 964 F.2d 814, 817 (8th Cir.1992), cert. granted, — U.S. —, 113 S.Ct. 1036, 122 L.Ed.2d 347 (1993) (court reluctantly agrees that the Eighth Amendment does not apply in a civil forfeiture action); United States v. One Parcel of Real Property With Bldgs., 960 F.2d 200, 207 (1st Cir.1992) (recognizing that although the Second Circuit decided section 881(a)(7) forfeitures are subject to a proportionality analysis, the First Circuit "has ruled the other way, taking the unequivocal position that proportionality analysis is inappropriate in civil forfeiture cases brought under section 881(a)(7)."); Certain Real Property, 943 F.2d at 727 (<HOLDING>); United States v. Real Property and Residence
holding that directed verdict does not violate seventh amendment 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 that the seventh circuit continues to adhere to the view that the eighth amendment does not apply to civil in rem actions 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 holding the fourteenth amendment does not apply to the actions of the federal government