United States v. Richard A. Ginsburg

RIPPLE, Circuit Judge,

with whom, FAIRCHILD, Senior Circuit Judge, joins, dissenting.

Today, the Court establishes a broad remedial device which Congress, at least at the time of the passage of the statute in question,1 was unwilling to provide. While posing a narrow question couched in procedural language, the Court actually answers a considerably broader question. The Court frames the issue as whether the government, before obtaining a forfeiture, must prove beyond a reasonable doubt the existence, at the time of the defendant’s conviction, of any interest that the defendant acquired in violation of section 1962 of the Racketeer Influenced and Corrupt Organizations chapter of the Organized Crime Control Act of 1970 (RICO), 18 U.S.C. §§ 1961-68 (1982). However, the Court answers a broader question by holding that the government need not establish any relationship between the interest ordered forfeited in the judgment upon conviction and the RICO violation. Consequently, the Court allows the government to reach the defendant’s personal assets and to seize any property equivalent to $225,000, whether or not the assets have any connection with the illegal enterprise. The Court provides the government with a valuable and possibly necessary weapon in the war on organized crime. However, the proper inquiry is not whether the government needs this weapon but whether Congress, when it enacted the statute which governs this case, authorized a forfeiture of property not derived from a violation of section 1962.

The Court’s reluctance to give a comparatively restrictive interpretation to a section of RICO is understandable. Both the executive and the legislative branches of government have invested a great deal of time, money and energy in dealing with a serious national problem which requires an approach different from that used to combat ordinary criminal activity. Indeed, the Congress has specifically mandated that the Judiciary interpret the statute so as to effectuate its broad remedial purposes. Pub.L. No. 91-452, § 904(a), 84 Stat. 947 (1970) — a mandate which the Supreme Court has emphasized consistently in its own interpretation of the statute. Sedima, S.P.R.L. v. Imrex Co., — U.S.-,-, 105 S.Ct. 3275, 3286, 87 L.Ed.2d 346 (1985); Russelo v. United States, 464 U.S. 16,-, 104 S.Ct. 296, 302, 78 L.Ed.2d 17 (1983). These considerations are quite important in interpreting all sections of RICO. They are only the beginning of the inquiry, however, and do not, by themselves, provide a sufficient framework for the interpretation of any specific section. A more precise analysis of the text of the particular section and its legislative history is necessary. We therefore turn to an examination of the text of the forfeiture provision, as it existed at the time of Ginsburg’s conviction, and of the relevant legislative history.

I.

The Court holds that its broad interpretation of section 1963(a)(1) is required by the “plain language” of this section. However, the statute is hardly clear or unambiguous. The words of the statute — standing alone— do not manifest a congressional intent to *805subject to forfeiture the defendant’s property owned at the time of conviction or acquired thereafter, even if it has no connection to the illegal enterprise. Indeed, the ambiguity of the statutory language has, until now, been acknowledged by commentators who have critiqued it,2 courts, including this one, which have interpreted it,3 and by a later Congress which found that its ambiguity was so pervasive as to require new legislation.4

At the time of Ginsburg’s conviction, section 1963(a) provided:

Whoever violates any provision of section 1962 of this chapter shall be fined not more than $25,000 or imprisoned not more than twenty years, or both, and shall forfeit to the United States (1) any interest he has acquired or maintained in violation of section 1962, and (2) any interest in, security of, claim against, or property or contractual right of any kind affording a source of influence over, any enterprise which he has established, operated, controlled, conducted, or participated in the conduct of, in violation of section 1962.

18 U.S.C. § 1963(a). The Court is correct that nothing in section 1963(a)(1) explicitly provides that- the interest to be forfeited must be in existence at the time of conviction. However, it is also true that nothing in that section suggests that the government may seize any property equivalent in value to the interest acquired or maintained in violation of section 1962. Certainly, until today, this Court did not consider such a broad interpretation to be dictated by the words of the statute. In United States v. McManigal, 708 F.2d 276, 289 (7th Cir.1983) (reaffirmed in United States v. McManigal, 723 F.2d 580, 581 (7th Cir.1983)); United States v. Alexander, 741 F.2d 962, 968 (7th Cir.1984) and an unpublished order in this case, United States v. Ginsburg, 753 F.2d 1079 (7th Cir.1985), panels of this Court have interpreted the section contrary to the Court’s interpretation of the same provision today. These conflicting opinions offer at least some evidence that the “plain language” of section 1963(a)(1) is not as clear as the Court suggests.

Other courts certainly have not considered the language to be clear. In United States v. Martino, 681 F.2d 952 (5th Cir.1982), the Fifth Circuit, while not deciding whether the government had an obligation to trace and identify the current form of monetary proceeds before it collected on a forfeiture order, recognized that the statutory language was ambiguous. Id. at 960-61. In reviewing that case, the Supreme Court also noted that the statute was not a model of clarity. Russello, 104 S.Ct. at 304 n. 3 (1983).

Certainly, in amending the statute in 1984, Congress did not believe that the previous language clearly mandated the result reached by the Court today. Indeed, the legislative history of the amended statute notes the ambiguity of its predecessor. The Senate Report stated that the General Accounting Office attributed the failure of forfeiture statutes (including the one at issue in this case) partly to “the numerous limitations and ambiguities of the statutes.” S.Rep. No. 225, 98th Cong., 1st Sess. 191-92 (1983), U.S.Code Cong. & Admin.News 1984, pp. 3374, 3375.

*806II.

Since the wording of the statute is not clear, it is necessary to turn to its legislative history. Blum v. Stenson, 465 U.S. 886,-, 104 S.Ct. 1541, 1548, 79 L.Ed.2d 891 (1984). The legislative history with respect to the forfeiture provision is not extensive. It is evident that Congress wanted to fashion a forfeiture provision. However, there is some evidence that it did not intend to enact a provision which would reach all of the defendant’s property whether or not obtained in violation of section 1962 or traceable to such funds. The Senate Committee on the Judiciary incorporated into its report on the forfeiture provision the Attorney General’s observations:

It is felt that this revival of the concept of forfeiture as a criminal penalty, limited as it is in Section 1963(a) to one’s interest in the enterprise which is the subject of the specific offense involved here, and not extending to any other property of the convicted offender, is a matter of Congressional wisdom rather than of constitutional power.

S. Rep. No. 612, 91st Cong., 1st Sess. 80 (1969).

The lack of extensive legislative history supports the view that Congress intended something other than the all-encompassing provision fashioned by the Court. Forfeiture is, in American criminal law, a novel remedy. Ever since the days of the American Revolution, it has been regarded with deep suspicion.5 While law enforcement authorities need special weapons to combat organized crime and might well require an expanded forfeiture provision, the Court ought to presume that Congress, acting against this historical background, would approach the matter carefully and would not employ vague language to fashion such a far-reaching remedy. If Congress had wanted to implement the drastic remedy formulated today by the Court, it knew how to do so. It has employed unequivocal language to achieve a similar result elsewhere. For instance, section 6331(a) of the Internal Revenue Code provides that the government may collect the taxes of a delinquent taxpayer “by levy upon all property and rights to property ... belonging to such person.” 26 U.S.C. § 6331(a). See generally United States v. National Bank of Commerce, — U.S. -, 105 S.Ct. 2919, 86 L.Ed.2d 565 (1985). Similar language could have been used here if Congress had in fact intended the result which the Court reaches today.

The decision to subject to forfeiture all of the defendant’s property and not just that connected to the criminal activity is a very significant policy choice. It affects not only the ability of the Government to curtail organized crime but also the capacity of the convicted individual to return someday to a lawful pursuit and to support his family. It is not asking too much for the Court to insist that the Congress — not the Judiciary — expressly make that policy choice.

The 98th Congress, in enacting the Comprehensive Crime Control Act of 1984, certainly did not believe that the predecessor statute at issue here contained such a sweeping provision. The Senate Report, for instance, noted the ambiguities of the statute6 and also assumed that the only way by which the government could ensure the presence of assets subject to forfeiture after conviction was through the use of a *807restraining order.7 More importantly, in formulating a new section which would have permitted precisely what the Court seeks in this case, the Committee referred to the provision as “new to the law.”8

III.

The Court assumes that a tracing requirement would place on the government the obligation to prove beyond a reasonable doubt that the assets obtained in violation of section 1962 still exist. We see no reason for that assumption. The continued existence of an interest in the enterprise is not an element of the crime proscribed by section 1962. The language of the statute provides no guidance as to how the government ought to meet the burden of showing that the interest it wishes to subject to forfeiture was acquired or maintained in violation of section 1962. Since establishing a burden of proof does not expand the scope of property subject to forfeiture, it is quite proper, in our view, for the Court to require the government to prove by a preponderance of the evidence that the specific property to be seized was acquired or maintained in violation of 18 U.S.C. § 1962. To assist the prosecutor in tracing tangible assets, a rebuttable presumption would arise that the property is subject to forfeiture under section 1963(a) once the government established that: (1) the property to be seized was acquired by the person during the period of the violation of section 1962 or within a reasonable time after the violation; and (2) there was no likely source for the property other than the violation.

CONCLUSION

The Court eliminates any burden on the government to establish a nexus between the interest to be seized and the violation of section 1962. In effect, the Court permits the government to substitute assets currently owned or even later acquired. The Court thus expands the scope of property subject to forfeiture beyond that clearly intended by Congress. Neither the statute itself nor the legislative history of section 1963(a) supports this judicial expansion. We, therefore, respectfully dissent. We would vacate the forfeiture and remand the case to the district court to permit the government to prove by a preponderance of the evidence that the property it seeks to seize was obtained in violation of section 1962 or is traceable to such property.

. As part of the Comprehensive Crime Control Act of 1984, Pub.L. No. 98-473 (1984), Congress amended 18 U.S.C. § 1963. Since the majority did not reach the question of the retroactive application of the amended statute or whether such retroactive application would violate the ex post facto clause, we decline to address those issues as well.

. See generally Storey, RICO Forfeitures: A General View, in Techniques in the Investigation and Prosecution of Organized Crime 296 (G. Blakey ed. 1980).

. See United States v. McManigal, 708 F.2d 276, 289 (7th Cir.1983) (reaffirmed in United States v. McManigal, 723 F.2d 580, 581 (7th Cir.1983)). See also United States v. Ginsburg, 753 F.2d 1079 (7th Cir.1985) (The panel in this case, after citing Alexander and McManigal, wrote, "[njothing that the government argues persuades us that these cases should be overruled.”); United States v. Alexander, 741 F.2d 962, 968 (7th Cir.1984).

. In its Report on the Comprehensive Crime Control Act of 1983, Pub.L. No. 98-473 (1984), the Committee on the Judiciary, United States Senate, noted that the General Accounting Office found the current forfeiture provisions replete with limitations and ambiguities. The new bill was intended to address these ambiguities. S.Rep. No. 225, 98th Cong., 1st Sess. 191-92 (1983).

. The Constitution limits punishment for treason to forfeiture of the convicted individual’s life estate. U.S.Const. art. Ill, § 3, cl. 2 provides: “The Congress shall have Power to declare the Punishment of Treason, but no Attainder of Treason shall work Corruption of Blood, or Forfeiture except during the Life of the Person attainted.”

The first Congress enacted a statute declaring that "no conviction or judgment for any of the offenses aforesaid shall work corruption of blood or any forfeiture of estate.” 18 U.S.C. § 3563. In 1984, Congress repealed 18 U.S.C. § 3563 effective November 1, 1986. Pub.L. 98-473, 98 Stat. 1987 (1984). Congress replaced section 3563 with 18 U.S.C. § 3554 which permits forfeiture in accordance with RICO, 18 U.S.C. § 1963 or the Comprehensive Drug Abuse and Control Act, 21 U.S.C. § 853.

. See supra note 4.

. The Senate Report indicated that:

No mechanism exists in current law to protect against improper transfers or concealment of assets at an earlier stage. Moreover, no standard for issuance of restraining orders is articulated in current statutes. Should a defendant succeed in transferring or concealing his forfeitable assets prior to conviction, there is no procedure to allow forfeiture of other assets of the defendant to satisfy the forfeiture judgment.

S.Rep. No. 225, 98th Cong., 1st Sess. 194 (1983), U.S.Code Cong. & Admin.News 1984, p. 3377.

. See id. at 201.