HomeMy WebLinkAbout98-0028 MiscellaneousCOMMONWEALTH
VS.
LE NGUYEN
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
98-0028 MISCELLANEOUS
COMMONWEALTH
VS.
ONE 1991 PLYMOUTH LASER, :
RED, VIN: 4P3CS34T4ME066474 :
ONE 1991 PLYMOUTH LASER, :
BLACK, :
VIN: 4P30S44R6ME150645 :
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
· 98-0058 MISCELLANEOUS
ONE PELOUZE DIGITAL SCALE ·
IN RE: THE PETITION OF LE NGUYEN FOR RETURN OF PROPERTY AND THE
PETITION OF THE COMMONWEALTH FOR FORFEITURE
BEFORE HESS, J.
ORDER
AND NOW, this 2.. ~-"-a day of July, 1998, the petition of the Commonwealth
for the forfeiture of one 1991 red Plymouth Laser, VIN 4P3CS34T4ME066474, is GRANTED.
The petition of Le Nguyen for return of property is DENIED.
BY THE COURT,
Travis Gery, Esquire
Sr. Assistant District Attorney
Matthew Gover, Esquire
For Le Nguyen
A. Hess, J.
COMMONWEALTH
VS.
LE NGUYEN
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
98-0028 MISCELLANEOUS
COMMONWEALTH
VS.
ONE 1991 PLYMOUTH LASER,
RED, VIN: 4P3CS34T4ME066474
ONE 1991 PLYMOUTH LASER,
BLACK,
VIN: 4P30S44R6ME150645
ONE PELOUZE DIGITAL SCALE
IN RE: THE PETITION OF LE
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
98-0058 MISCELLANEOUS
NGUYEN FOR RETURN OF PROPERTY AND THE
PETITION OF THE COMMONWEALTH FOR FORFEITURE
BEFORE HESS, J.
OPINION AND ORDER
This case is before us on the Commonwealth's petition for forfeiture of a 1991 red
Plymouth Laser, VIN 4P3CS34T4ME066474. The vehicle was seized after an arrest warrant was
served on Thoai A. Nguyen and a search warrant was executed on the vehicle. The vehicle was
used to facilitate the transportation, possession, concealment, and distribution of marijuana, and
is therefore subject to forfeiture under 42 Pa.C.S.A. Section 6801 (a)(4). The vehicle registration
and title are in the name of Mr. Nguyen's mother, Le Nguyen. Ms. Le Nguyen has filed a motion
for return of property contending that she is an "innocent owner" under the Forfeiture Act.
98-0028 MISC.
98-0058 MISC.
On October 31, 1997, Thoai A. Nguyen was arrested for possession and delivery of
marijuana and cocaine after Mr. Nguyen made sales of these drugs to an undercover police
officer. A search warrant was also executed on the red Plymouth Laser, and marijuana was
recovered from that vehicle. According to the Stipulation of Fact filed in this matter, Mr.
Nguyen did in fact use the vehicle for the transportation and delivery of marijuana. The title to
the vehicle and the vehicle registration are in Le Nguyen's name as it was Ms. Le Nguyen who
purchased the vehicle. Thoai, however, has had complete and exclusive use of the vehicle, and
has been solely responsible for the maintenance of the car. Le has driven the vehicle on only two
occasions.
The Commonwealth has instituted an action pursuant to the Forfeiture Act, 42 Pa.C.S.A.
Section 6801. Ms. Le Nguyen claims the benefit of the following provision of the Act:
(ii) no conveyanc.e shall be forfeited under the
provisions of this section by reason of any act or
omission established by the owner thereof to have
been committed or omitted without his knowledge
or consent, which absence of knowledge or consent
must be reasonable under the circumstances
presented;
42 Pa.C.S.A. Section 6801 (a)(4)(ii).
Pennsylvania's Forfeiture Act is modeled after its federal counterpart, the Comprehensive
Drug Abuse Prevention and Control Act of 1970, 21 U.S.C. Section 881(a)(4). Consequently,
the courts of our Commonwealth have looked to federal cases for guidance in determining
questions of ownership and, specifically, the parameters of the "innocent owner" defense under
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98-0058 MISC.
Section 6801(a)(4)(ii). See Commonwealth v. One 1985 Cadillac Seville, 371 Pa. Super. 390,
397, 538 A.2d 71, 75 (1988).
In a case with facts strikingly similar to the matter sub judice, the court in
Commonwealth v. One 1988 Suzuki Samurai, 139 Pa. Cmwlth. 68, 72, 589 A.2d 770, 773 (1991)
noted "our review of federal cases reveals that an owner must have a possessory interest in the
property with attendant characteristics of dominion and control." The court went on to conclude
that it was not sufficient that one have title to a car and have paid for it to be able to claim the
"innocent owner" defense. In deciding Whether property should be forfeited, the question is who
has control over the property that was seized, not who paid for and has title to the property.
"[H]olding title to an automobile does not, in and of itself, prove actual legal ownership for the
purposes of the Forfeiture Act." Strand v. Chester Police Department, 687 A.2d 872, 876 (Pa.
Cmwlth. 1997).
For purposes of the Forfeiture Act, we conclude that the owner of the Plymouth is Thoai
Nguyen. The Stipulation of Fact states that "[s]ince the purchase of the vehicle, Thoai Nguyen
has had complete and exclusive use of the vehicle" and that "Thoai Nguyen was solely
responsible for maintaining the car and ensuring its good operating condition. This included all
necessary repairs as well as filling the tank with gasoline." In light of these factual conclusions,
we will grant the Commonwealth's petition.
AND NOW, this
ORDER
day of July, 1998, the petition of the Commonwealth
98-0028 MISC.
98-0058 MISC.
for the forfeiture of one 1991 red Plymouth Laser, VIN 4P3CS34T4ME066474, is GRANTED.
The petition of Le Nguyen for return of property is DENIED.
BY THE COURT,
Travis Gery, Esquire
Sr. Assistant District Attorney
Matthew Gover, Esquire
For Le Nguyen
:rlm
Kevin ~z~Hess, J.
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