Buchanan v. State

Dillard, Judge.

Following a bench trial in this in rem civil forfeiture action, James Buchanan forfeited his truck to the State on the ground that it was used to facilitate his possession of methamphetamine. Buchanan appeals, arguing that the trial court erred in finding that the forfeiture was not excessive and in failing to make the required findings supporting the forfeiture on the record. We agree that the record does not indicate whether the trial court considered the mandatory guidelines outlined by our Supreme Court in Howell v. State of Georgia1 in determining whether the forfeiture…