Prevailing Winds has an article in the latest issue about the Donald Scott
attempted seizure that may inform our understanding of the mechanics of
seizure cash flows and how the federal seizure industry has grown.

My impression from reading the DOJ Asset Forfeiture Fund financial
statements is that the state and local rebates flow back through judicial
districts. The main players on the federal side appear to be the District
Offices of the US Attorney's around the country which must be organized and
hence the cash flows back through judicial districts corresponding somehow
to the federal district courts. (The HUD Housing Fraud initiative was
legislated to correspond to judicial districts.)

When the rebates dropped substantially in 1996 (at the same time that the
GAO audit was published--March 1996---with a very negative report on the DOJ
asset forfeiture fund), the drop appeared to be concentrated in only some of
the markets---generally the larger ones. The largest cash flows appear to
correspond to the markets with the highest concentration of traditional HUD
defaults and financial fraud. The biggest looks to be California's Central
District, which is LA and the LA area. California Central District also
appears to be the target of one of the HUD Housing Fraud Initiatives which
should be going on now. If the Donald Scott case is representative it would
appear that the main players for local government are the District
Attorney's offices and the county Sheriffs. The courts must figure in, but I
do not know how yet. Comdenation and bankruptcy issues appear to be two of
the pieces important at the local level to some of the action.

The Donald Scott attempted seizure was on October 2 1992 (we should put in
chronology).  There was a 32 man assault team supported by the efforts of
additional team members before the raid. Present for the federal government
was:

The National Park Service
The Jet Propulsion Laboratory (a private government contractor described as
one of the most significant NASA and DOD contractors)
The DEA
A US Border Patrol search unit using a US Army surveillance aircraft

The primary player for the local government was the LA County Sheriff's
Office which the article indicates would participate in substantial cash
booty (presumably this is the local rebate piece----more and more it looks
like it flows through the county's and the sheriff's offices...I do not
understand the structure of enforcement, but it appears the sheriffs also
attach the IRS tax liens to homes. Perhaps the Sheriffs are the folks who
deal with all the property issues) It turns out that individual cash rewards
were also involved "And, perhaps most troubling, the lead investging officer
would get a cash percentage of the total value. He is Los Angeles County
Sheriff's Office narcotics detective Gary Spencer." (Prevailing Winds,
Murder in Malibu, by Joseph Bosco). The article mentions that no teams from
the Ventura County District Attorney's office or Shefiff's officer were
present, where Scott's ranch was located. It appears that the District
Attorney in Ventura County (Bradbury) has made an important contribution to
getting the facts of what happened illuminated.

Spencer was the officer who shot and killed Scott during the raid, that
produced no evidence of drugs or wrongdoing and did not result in a seizure.
Members of the LAPD canine unit were also present as was the California
National Guard and members of the California DEA. Also present was an
informant who had given testimony that there was marijauna growing on
Scott's ranch and who stood to make a % of the profits.

There is an indication in the article that Scott had sued or been involved
in litigation against the National Park Service and the Jet Propulsion
Laboratory over the land. It appears that they wanted it, but I can not tell
what the facts are.

One of the most informative pieces in this article as it may relate to our
situation is the presence of individual financial incentives allocated to
government officials from seizures. The behavior that we have seen from the
HUD IG office and the attorneys at the District US Attorney's office and
Commercial Litigation branch is compatible with such personal cash
incentives for themselves or for some of the players in the system. The
behavior of this portion of the team is much more compatible with
commissioned bond salesmen or real estate brokers than government officials.

In the HUD IG audit of the Operation Safe Home program, the HUD IG audit
team remarked on the substantial number of LEAP payments that were being
made without documentation or supporting paperwork. I wonder if LEAP is
being used to provide a % cash bonus system sub rosa to individuals who
consummate successful cash transactions (seizures, civil money penalties,
negotiated settlements).








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