The thesis of this Article is that a claimant in a civil forfeiture proceeding can assert a counterclaim against the United States government. This assertion is based upon the scope of the Supplemental Rules and in rem jurisdiction.
Jack B. Harrison and Brendan Sullivan,
Emerging From Davy Jones’ Locker: The Revival of Counterclaims Against Government in Civil Forfeiture Actions,
104 Marq. L. Rev. 859
Available at: https://scholarship.law.marquette.edu/mulr/vol104/iss3/4