held that a district court did not plainly err by instructing a jury that “proceeds” in § 853(a) means the “gross proceeds” of drug trafficking, not “net profits.” See 582 F.3d 108, 121-24 (1st Cir. 2009). True, Bucci analyzed the issue in terms of plain error. Id. But Bucci made clear that there was no error at all. See id. Pulling out all the stops, Ponzo claims the money judgment violated the Eighth Amendment’s excessive-fines clause because (in his view) it will deprive him of the ability to make a living. See United States v. Sepúlveda-Hernández, 752 F.3d 22, 37 (1st Cir. 2014) (“[assuming, without deciding, that deprivation of livelihood can constitute a basis for setting aside a criminal forfeiture judgment”); United States v. Aguasvivas-Castillo, 668 F.3d 7, 16 (1st Cir. 2012) (<HOLDING>). But as the government points out, “the
recognizing the severity of depriving someone of his or her livelihood holding that  545 entitles the government to civil forfeiture of certain funds subject to the eighth amendment holding that in excessive force cases the threshold question for the court is whether the officers conduct violated a clearly established constitutional right holding that forfeitures may violate the eighth amendment excessive fines clause holding that a defendant may raise whether the forfeiture order is so excessive under the eighth amendment that it would in extreme cases effectively deprive the defendant of his or her future livelihood