U.S. Court of Appeals for the Ninth Circuit
United States v. Younes Nasri
September 2, 2026
Summary
The Ninth Circuit held that a district court may not exercise in rem jurisdiction over foreign assets in a civil forfeiture action without first establishing actual or constructive control over the property, as required by the Fifth Amendment Due Process Clause, and vacated and remanded the district court’s order. The panel emphasized historical in rem principles and rejected the district court’s reliance on statutory text alone. A dissent argued that the majority improperly intrudes on foreign‑policy judgments.