Stapleton v. Two Million Four Hundred Thirty-Eight Thousand, One Hundred & Ten Dollars

Although I agree with the result reached by the majority, my views differ sufficiently to warrant a separate statement regarding the jurisdictional problem and the interpretation of the New Jersey forfeiture statute.

The dispute here centers on whether Hudson County, New Jersey or the United States is the rightful owner of the $2,438,110 found in garage #48 in Jersey City, New Jersey. Hudson County claims the money as a consequence of the operation of the New Jersey Forfeiture Statute, N.J.Stat.Ann. § 2A:152-6 et seq. The United States asserts that the money is due it because of a valid tax…