Commonwealth v. One (1) 1984 Z-28 Camaro Coupe

The majority’s historical analysis in this case is doubtful on two grounds. First, this Court, in a case of relatively *533recent vintage, held that a jury trial is not required in all forfeiture proceedings. See Commonwealth v. Bowers, 304 Pa. 253, 155 A. 605 (1931).

The Court in Bowers was addressing the issue of forfeiture used in illegal alcohol distribution. The case is analogous to the case at bar in that the statute there was also directed towards the seizure of non-contraband items based on their alleged relationship to the contraband itself. Under the then extant forfeiture statute no…