"If agents have probable cause to believe that a car is or has been used for carrying contraband, they may summarily seize it pursuant to the federal forfeiture statute and search it."

Rather, the government must show reasonable beZief that a connection to the ille-gal activity exists. 14s The government's belief must be supported by less than "prima facie proof but more than mere suspicion."'14 9 Once the government seizure and the subsequent warrantless search of an automobile, noting that there was an independent exception to the warrant …

—upheld a warrantless automobile search on the ground that the federal agent had probable cause to believe that the car was subject to seizure and forfeiture under 49 USC §§ 781-83 for having been used to transport counterfeit currency.

—the forfeiture statutes, when coupled with probable cause, do give agents the authority to seize and search vehicles.

—another case cited as evidence of the "historical acceptance" of warrantless seizures, Judge Henry Friendly relied primarily on Boyd and Carroll

The Second Circuit has interpreted Harris as requiring that there be a "fair basis for belief that the place searched... would contain instruments or fruits of the crime for which the arrest was made."

[PDF] Civil Forfeiture of Property for Drug Offenders under Illinois and Federal …

[CITATION] Criminal Justice Journal

[CITATION] University of Baltimore Law Review

[CITATION] Constitutional rights of the accused