Matthew Cline v. United States

Petitioner Matthew Cline served as an intermediary in a scheme in which he received funds from a government agency and forwarded the vast majority of the money to the scheme’s ringleader. Although most of the money never came to rest with Cline, the Tenth Circuit interpreted 18 U.S.C. § 981(a)(1)(C) to require him to forfeit the full amount that traveled through his bank account, meaning that he was ordered to forfeit property transferred to a co-conspirator. In so holding, the Tenth Circuit joined four of its sister circuits and rejected the Ninth Circuit’s contrary rule that permits forfeiture only when the relevant property “came to rest” with the defendant. The question presented is: Whether under 18 U.S.C. § 981(a)(1)(C) a defendant may be ordered to forfeit property to the government that he transferred to a co-conspirator merely because it was at one point under his control. (i)