Vazquez v. United States Drug Enforcement Administration

Juan Antonio Vazquez filed an action against the Drug Enforcement Administration (DEA) seeking to set aside the 2006 forfeiture of more than $7,000, and citing 28 U.S.C. § 1331 and Federal Rule of Criminal Procedure 41. The district court held that the forfeiture was based on 21 U.S.C. § 881 and that Vazquez’s exclusive remedy for setting aside the forfeiture was found at 18 U.S.C. § 983(e). The district court granted summary judgment and dismissed the action as untimely under the five-year limitations- period of § 983(e)(3). Vazquez appealed, and this court granted him leave to appeal in…