society because of the large and unpredictable variances in the values of real estate and conveyances in comparison to the harm inflicted upon government and society by the criminal act. Id. at 300. The court went on to contrast forfeitures under § 881(a)(6), noting that “the forfeiture of drug proceeds will always be directly proportional to the amount of drugs sold.” Id. The Tilley court asserted that Austin was but an application of Halper and that the proportionality review required under Halper must be applied anew in each case to determine whether a civil sanction imposes “punishment.” Id. at 298-99. The Tilley court also clari S. 232, 237, 93 S.Ct. 489, 492, 34 L.Ed.2d 438 (1972); Rex Trailer Co. v. United States, 350 U.S. 148, 153-54, 76 S.Ct. 219, 222-23, 100 L.Ed. 149 (1956) (<HOLDING>)). The Tilley court also recognized another
recognizing that detariffmg would result in some increased administrative costs but anticipating those costs to be initial and fixed costs only resulting from the shift to a detariffed environment  such as the cost of developing short standard contracts recognizing repayment of damages to society as remedial recognizing that an award of temporary attorneys fees and costs is based on an assessment of need and ability to pay as well as the reasonableness of the fees and costs holding that no distinction exists between investigatory costs and onsite cleanup costs for purposes of recovery recognizing market and societal costs resulting from wrongdoing and avoidance of unjust enrichment as remedial purposes