— the subsection under which the bars were forfeited— was not enacted until 1978. Since the ex post facto clause of the United States Constitution prohibits application of a statute in a way which imposes punishment for an act that was not punishable at the time it was committed, Griffin concludes, the ex post facto clause bars the forfeiture of the nine gold bars in this case. It is beyond dispute that the ex post facto clause applies only to criminal cases. Harisiades v. Shaughnessy, 342 U.S. 580, 594, 72 S.Ct. 512, 521, 96 L.Ed. 586 (1952); Colder v. Bull, 3 U.S. (3 Dali.) 386, 400, 1 L.Ed. 648 (1798). However, the ex post facto effect of a law cannot be evaded by simply giving a civil form to that which is essentially criminal. Burgess v. Salmon, 97 U 4, 29 L.Ed. 746 (1886) (<HOLDING>). However, for other purposes, the civil nature
holding that forfeiture statute is subject to the fourth amendments prohibitions against unreasonable searches and seizures holding that adam walsh act violates the eighth amendments prohibition against excessive bail the fifth amendments guarantee of procedural due process and separation of powers holding that adam walsh act violates the eighth amendments prohibition against excessive bail and the fifth amendments guarantee of procedural due process holding that because of its quasicriminal nature forfeiture proceeding was subject to the fifth amendments prohibition against selfincrimina tion holding that tribal courts are not subject to the fifth amendments requirement of indictment by grand jury