is AFFIRMED, and its final judgment for Howerin is VACATED. The case is REMANDED for further proceedings consistent with this opinion. SO ORDERED. 1 . Section 881(a)(7) states that any real property that is used to facilitate the commission of a drug offense is subject to forfeiture to the United States. 2 . The procedure for in rem forfeiture actions under 21 U.S.C. § 881 is set forth in the Supplemental Rules for Certain Admiralty and Maritime Claims. See 21 U.S.C. § 881(b). 3 .Other circuits have reached similar, but distinguishable, conclusions. See United States v. Smith, 966 F.2d 1045, 1053-54 (6th Cir.1992) (using deed to define "property” in 21 U.S.C. § 853(a)(2), a criminal forfeiture statute); see also United States v. Plat 20, Lot 17, 960 F.2d 200, 205-06 (1st Cir.1992) (<HOLDING>). The Ninth Circuit has stated that the deed
holding that a cause of action for damages to property resulting from a permanent nuisance accrues to the owner of the land at the time the injury begins to affect the land and mere transfer of the land by deed does not transfer the claim for damages holding that for purposes of initial seizure warrant in forfeiture action the government may seize land according to the description contained in the deed holding that the deed and not the historical description of the land determines what land constitutes the forfeitable property holding a quitclaim deed yields only such interest in land as the grantor had at the time of the making of such deed holding that a typographical error in a security deed does not necessarily invalidate the legal description when the deed also referred to the propertys physical address