City of St. Petersburg Police Department v. Dennis
The Second DCA reversed a circuit court order denying probable cause for the seizure of $19,898 in cash under the Florida Contraband Forfeiture Act, holding that the seizing agency's application and sworn affidavit—viewed in the aggregate—established a sufficient probability that the currency was connected to illegal drug activity. The court reaffirmed that civil forfeiture probable cause at the seizure stage is less than a prima facie case and can be satisfied by circumstantial evidence through the aggregation of individually insufficient facts. Civil practitioners handling asset forfeiture disputes should note the court's express instruction that its appellate probable cause finding does not bind the trial court at the subsequent adversarial preliminary hearing.
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