Mikell v. State

Phipps, Chief Judge.

In this civil in rem forfeiture action, Ricky Mikell appeals the trial court’s order finding that his residence was subject to forfeiture because the property had been used to facilitate a drug transaction. Mikell contends that the trial court erred by failing to perform the proper constitutional analysis on the record. As discussed below, the record does not reveal whether the trial court performed the detailed analysis required by Howell v. State of Ga.1 in determining whether the forfeiture constituted an excessive fine.2 We therefore vacate the trial court’s order and…