May 28, 1992 UNITED STATES COURT OF APPEALS
FOR THE FIRST CIRCUIT



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No. 91-2141

UNITED STATES OF AMERICA,
Plaintiff, Appellee,

v.

ONE PARCEL OF REAL PROPERTY WITH THE BUILDING,
APPURTENANCES, AND IMPROVEMENTS KNOWN AS
384-390 WEST BROADWAY, SOUTH BOSTON, MASSACHUSETTS,
Defendant.
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EMANUEL L. ROSENGARD,
Claimant, Appellant.
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APPEAL FROM THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS

[Hon. Edward F. Harrington, U.S. District Judge]
___________________
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Before

Selya, Circuit Judge,
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Campbell, Senior Circuit Judge,
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and Boyle,* District Judge.
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William F. Spallina for appellant.
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Frederick E. Dashiell, Assistant United States Attorney,
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with whom Wayne A. Budd, United States Attorney, was on brief,
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for appellee.

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SELYA, Circuit Judge. This appeal asks us to determine
SELYA, Circuit Judge.
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whether a district court, almost two years after it issued a

forfeiture order, acted properly in enlarging the order's reach

beyond the property specifically identified in the government's

complaint. We hold that, in the circumstances of this case, the

district court did not possess such untrammeled authority.

I. BACKGROUND
I. BACKGROUND

On February 12, 1987, law enforcement officers found a

cache of marijuana, cocaine, and diazepam at premises owned by

claimant-appellant Emanuel Rosengard. Later that month, the

federal government initiated a forfeiture action. The

government's complaint described the defendant property as "384-

390 West Broadway, South Boston, Massachusetts." An exhibit

attached to the complaint delineated the property's boundaries,

replicating the language of a deed by which the Broadway property

had been conveyed to Rosengard in 1971.1 The complaint made no

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1The description reads:

A certain parcel of land together with a building,
appurtenances, and improvements, situated in that part of Boston
called South Boston, in the County of Suffolk, Commonwealth of
Massachusetts, bounded and described as follows:

SOUTHEASTERLY by Broadway (between E and F Streets)
about sixty-five feet, six inches;
NORTHWESTERLY by land formerly of Wright and others, one
hundred and forty-five feet, six inches; and
NORTHEASTERLY by a twenty foot street now called Athens
Street, about sixty-five feet, six inches;
and
SOUTHEASTERLY by land late of John Redman, one hundred
forty-five feet, six inches, together with
the rights, easements, privilegesand appurte-
nances thereto belonging.


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mention of an abutting parcel, known as 309 Athens St., which

Rosengard bought from a different seller in 1973.

Following pretrial discovery, the district court

granted summary judgment in favor of the government. The Court's

order declared forfeit "the defendant real property with the

building, appurtenances, and improvements, known as 384-390 West

Broadway, South Boston, Massachusetts." Final judgment was

entered on November 22, 1989. An appeal was taken but, later,

withdrawn.

On August 23, 1991, the government attempted to breathe

new life into the corpse. It filed a motion which it

euphemistically styled as one for clarification of the forfeiture

order. In that motion, the government asked the district court

to rewrite the order and judgment to encompass both the Broadway

and Athens St. properties. The government averred that, as far

back as 1974, the two properties had been pledged as joint

security for a construction mortgage obtained from South Boston

Savings Bank (which mortgage financed Rosengard's erection of a

commercial structure that occupied the Broadway site at the time

of the drug raid); that the Athens St. property was used for

parking in connection with the operation of the commercial

building throughout the period of Rosengard's ownership; and

that, in 1974, a "compiled plan" linking the two parcels was

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The parties agree that the government made a typographical error
in the directional signal relating to the fourth boundary
description. That signal should have read "SOUTHWESTERLY" rather
than "SOUTHEASTERLY." No one was misled by this bevue. At any
rate, it has no bearing on the problem at hand.

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filed in the Recorder of Deeds' office.



On these bases, the government asserted that forfeiture

of the Athens St. property was subsumed under the terms of the

original order and judgment. It claimed that the two pieces of

property were actually a single tract of land or, alternatively,

that the Athens St. property was "appurtenant" to the Broadway

property. Rosengard opposed the motion, claiming prejudice and

offering a salmagundi of reasons why the government's

afterthought maneuver should be thwarted. Moreover, Rosengard

urged that, if the earlier judgment were to be reopened for any

purpose, it should be vacated entirely and the case as a whole

relitigated.

The district court took no evidence. Rather, it

disposed of this burgeoning controversy in a single sentence,

writing that: "Forfeiture of [the] entire tract of land is

allowed." The parties agree that the effect of this ruling was

to bring the Athens St. property within the encincture of the

existing judgment. Rosengard appeals. We reverse.

II. THE LEGAL LANDSCAPE
II. THE LEGAL LANDSCAPE

We turn first to some general principles pertaining to

the forfeiture of real property under the statute invoked by the

government.2 We then discuss the procedures prescribed by law

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2The statute provides in pertinent part:

The following shall be subject to
forfeiture to the United States and no
property right shall exist in them:

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for the exercise of this forfeiture power.

A. Forfeitable Property.
A. Forfeitable Property.
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21 U.S.C. 881(a)(7) authorizes the federal government

to bring forfeiture proceedings against certain real property.

The government urges that the statutory phrase "the whole of any

lot or tract of land" is capacious enough to justify the

forfeiture of the two properties as a unit. Since the tract

encompasses both properties, this thesis runs, Rosengard's

illegal activities on the Broadway parcel authorized forfeiture

of the entirety. See United States v. 2 Burditt St., 924 F.2d
___ ______________ ______________

383, 385 (1st Cir. 1991) ("in a forfeiture proceeding under

section 881(a)(7), property in its entirety is forfeitable even

if only a portion of it was used for illegal purposes"); accord
______

United States v. One Parcel, Etc. (Great Harbor Neck, New
______________ _____________________________________________

Shoreham, R.I.), ___ F.2d ___, ___ n.7 (1st Cir. 1992) [No. 91-
______________

1681, slip op. at 15 n.7]; United States v. 6250 Ledge Rd., 943
______________ ______________

F.2d 721, 726 (7th Cir. 1991); United States v. 3097 S.W. 111th
_____________ _______________

Ave., 921 F.2d 1551, 1557 (11th Cir. 1991); United States v.
____ ______________

141st St. Corp., 911 F.2d 870, 880 (2d Cir. 1990), cert. denied,
_______________ _____ ______

111 S. Ct. 1017 (1991); United States v. One 107.9 Acre Parcel of
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____________________

. . .

All real property, including any right,
title, and interest in the whole of any lot
or tract of land and any appurtenances or
improvements, which is used, or intended to
be used, in any manner or part, to commit, or
facilitate the commission of [certain drug-
related felonies] . . . .

21 U.S.C. 881(a)(7) (1982 & Supp. 1988).

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Land, 898 F.2d 396, 400 (3d Cir. 1990); United States v. 40 Moon
____ _____________ _______

Hill Rd., 884 F.2d 41, 45 (1st Cir. 1989); United States v. 300
________ _____________ ___

Cove Rd., 861 F.2d 232, 233-35 (9th Cir. 1988), cert. denied, 493
________ _____ ______

U.S. 954 (1989); United States v. Reynolds, 856 F.2d 675, 676
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(4th Cir. 1988).3

In this case, however, there is a rub. While the law

permits the government to seize an entire tract of land if a

portion of it is used in contravention of section 881(a)(7),

neither the statute nor the case law mandates that the government

must pursue this course. This appeal, therefore, does not

require that we address the government's power to forfeit both

parcels had it tried to do so when it undertook to sue. Rather,

this appeal focuses on a much different question: Even assuming

that the government might successfully have urged that

Rosengard's two properties constituted a single tract for

purposes of the forfeiture law, did the government take the

procedural steps necessary to bring the full weight of its

statutory authority to bear? If the government did not do what


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3Although the government may define a lot or tract of land
by the description contained in a deed or other record of land
evidence, see Great Harbor Neck, ___ F.2d at ___ [slip op. at
___ __________________
10]; United States v. Santoro, 866 F.2d 1538, 1543 (4th Cir.
_____________ _______
1989), it is not obligated to describe a lot or tract in that
way. See, e.g., United States v. 4492 S. Livonia Rd., 889 F.2d
___ ____ _____________ ____________________
1258, 1270 (2d Cir. 1989) ("It is also possible to construe 'any
lot or tract' to refer to real estate of the size usually
associated with a lot or a tract of fairly limited acreage,
rather than whatever land area is encompassed within the deed by
which the owner acquire title."); see also Great Harbor Neck, ___
___ ____ _________________
F.2d at ___ [slip op. at 10] (suggesting that the government may
also delineate a tract, for purposes of section 881(a)(7), by
acts of an individual which signify dominion and ownership).

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was necessary to forfeit the Athens St. property as a segment of

the whole, it could not lay claim to that parcel, after the fact,

as if it were part of the original suit.

It is against this backdrop that we turn to the

applicable procedures.

B. Prescribed Procedures.
B. Prescribed Procedures.
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Forfeiture complaints filed pursuant to 21 U.S.C. 881

are governed by the Supplemental Rules for Certain Admiralty and

Maritime Claims.4 See 21 U.S.C. 881(b); United States v. Pole
___ _____________ ____

No. 3172, 852 F.2d 636, 638 (1st Cir. 1988). Two rules address
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the level of particularity required in forfeiture complaints.

Admiralty Rule C(2) states that the complaint "shall describe

with reasonable particularity the property that is the subject of

the action." Admiralty Rule E(2)(a) states that "the complaint

shall state the circumstances from which the claim arises with

such particularity that the defendant or claimant will be able,

without moving for a more definite statement, to commence an

investigation of the facts and to frame a responsive pleading."

The cases are consentient that the Admiralty Rules

demand more particularity in the crafting of forfeiture

complaints than is generally required in authoring complaints

under the Civil Rules. See United States v. 2323 Charms Rd., 946
___ _____________ _______________

____________________

4Resort may also be had to the Federal Rules of Civil
Procedure for interstitial matters or where the Admiralty Rules
are silent; but, in the event of a conflict, the Admiralty Rules
control. See United States v. $38,000.00 in United States
___ _____________ _____________________________
Currency, 816 F.2d 1538, 1547 n.20 (11th Cir. 1987); United
________ ______
States v. $39,000 in Canadian Currency, 801 F.2d 1210, 1216 (10th
______ ____________________________
Cir. 1986).

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F.2d 437, 441 (6th Cir. 1991); United States v. 4492 S. Livonia
_____________ _______________

Rd., 889 F.2d 1258, 1266 (2d Cir. 1989); Pole No. 3172, 852 F.2d
___ _____________

at 640-41; United States v. $38,000.00 in United States Currency,
_____________ ____________________________________

816 F.2d 1538, 1547 n.20 (11th Cir. 1987); United States v.
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$39,000 in Canadian Currency, 801 F.2d 1210, 1216 (10th Cir.
______________________________

1986). While all the facts necessary to satisfy this mandate

need not be recited in the complaint's text the Admiralty

Rules' requirements can be satisfied by information contained in

affidavits or other documentation attached to the complaint, see
___

United States v. One Parcel of Real Property, 921 F.2d 370, 376
_____________ ____________________________

n.10 (1st Cir. 1990); United States v. Parcels of Land, 903 F.2d
_____________ _______________

36, 48 (1st Cir.), cert. denied, 111 S. Ct. 289 (1990) the
_____ ______

facts must nonetheless clearly appear so that all persons

potentially interested in the property will be afforded fair

notice of the sovereign's position and intention.

Moreover, despite the fact that the case law has not

fully fleshed out the ossature of Admiralty Rule C(2), it is

plain from the rule's text that a forfeiture complaint must

achieve a meaningful level of detail in describing the property

to be forfeited. This conclusion follows both from our belief

that it is proper to interpret Admiralty Rules C(2) and E(2)(a)

in pari materia and from the gloss that we have previously placed
__ ____ _______

on Admiralty Rule E(2)(a). That rule is

designed to assure that the forfeiture
complaint apprises potential claimants of the
circumstances which support the government's
contention that there is probable cause to
believe that the defendant property was
connected with illegal drug activity, thus

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enabling claimants "to commence an
investigation of the facts and to frame a
responsive pleading."

One Parcel, 921 F.2d at 375 (emphasis deleted; citations omitted)
__________

(quoting Rule); accord Parcels of Land, 903 F.2d at 48; Pole No.
______ _______________ ________

3172, 852 F.2d at 638. Other courts read Admiralty Rule E(2)(a)
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in much the same way. See, e.g., 3097 S.W. 111th Ave., 921 F.2d
___ ____ ____________________

at 1554-55; $38,000.00, 816 F.2d at 1548; $39,000, 801 F.2d at
__________ _______

1216, 1219.

The exacting particularity standard applicable to

forfeiture actions "is not merely a procedural technicality,"

Pole No. 3172, 852 F.2d at 638, but is, instead, a significant
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legal rule designed to curb excesses of government power and

afford property owners some protection from the harshness of a

forfeiture's attendant sanctions. See 2323 Charms Rd., 946 F.2d
___ ________________

at 441; 4492 S. Livonia Rd., 889 F.2d at 1266; Pole No. 3172, 852
___________________ _____________

F.2d at 638. So viewed, the stringent pleading rules applicable

in the forfeiture context mirror the drastic nature of the

remedy. See Pole No. 3172, 852 F.2d at 638; $39,000, 801 F.2d at
___ _____________ _______

1216, 1218; see also 12 Charles A. Wright & Arthur R. Miller,
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Federal Practice & Procedure 3242 (1973). Because Congress has
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supplied the government with one of the most potent weapons in

the judicial armamentarium, the courts must make certain that the

government is, at the very least, reasonably precise in its

deployment.

In sum, since forfeitures are strong medicine,

disfavored in our jurisprudence, it seems fitting to condition


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the medicine's availability on a proper regard for the

requirements of the law. Accord United States v. 4880 S.E. Dixie
______ _____________ _______________

Highway, 838 F.2d 1558, 1564 (11th Cir. 1988); $38,000.00, 816
_______ __________

F.2d at 1547.



III. ANALYSIS
III. ANALYSIS

Whether a forfeiture complaint is, or is not,

sufficiently particularized to reach a given piece of property is

an issue of law subject to plenary review. See, e.g., 2323
___ ____ ____

Charms Rd., 946 F.2d at 442; 3097 S.W. 111th Ave., 921 F.2d at
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1554. We now undertake that inquiry.

Fairly read, the government's complaint in this action

sought to forfeit the Broadway property nothing more. It did

not, in the idiom of Admiralty Rule C(2), describe the Athens St.

property with "reasonable particularity." Indeed, the complaint

did not describe, or even refer to, that parcel at all. Perusing
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the complaint and the paperwork associated with it, there was no

basis for a reasonably prudent reader or even an unusually

cautious reader to suspect that the Athens St. property was at

risk. We believe that the government's decision to focus

exclusively on the Broadway site was tantamount to a waiver of

any claim against the adjacent property. After all, as the

ancient maxim teaches, inclusio unius est exclusio alterius.
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It follows inexorably that the so-called motion for

clarification should have been denied. Most litigation involves

cost/benefit assumptions. A party who reasonably believes that


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he stands to lose only Parcel "X" may choose not to mount an all-

out defense against threatened forfeiture; yet the same party, on

the same facts, when faced with the combined loss of Parcels "X"

and "Y," may well commit more resources to the struggle. Thus,
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fundamental fairness requires that the government, when seeking

to forfeit property, must describe it with specificity if not

with mathematical precision.

Here, the government wholly failed to carry its burden.

The complaint in this case apprised the claimant only of the

government's intention to seek forfeiture of the Broadway

property. The claimant was entitled to rely on what the

complaint indicated. The government cannot be allowed to obtain a

judgment against a carefully defined piece of property and, after

the battle has been won, unfairly increase the stakes.5

IV. CONCLUSION
IV. CONCLUSION

To recapitulate, the government originally sought to

take one bite of the apple. After receiving the district court's

blessing, it then sought to double the size of the bite. By that


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5In reaching this result, we pronounce ourselves unwilling
to indulge the government's claim that the Athens St. parcel is
merely an "appurtenance" to the Broadway parcel. While such a
claim, if made with adequate detail in the original complaint,
might conceivably have had a modicum of merit a question that
we need not reach and, therefore, do not address it is
perfectly clear that the government cannot be allowed to bypass
its obligation to give claimants fair notice by including a
cryptic reference to "appurtenances" in a complaint and then
reading section 881(a)(7)'s reference to that word so broadly as
to cover an independently deeded piece of property not
specifically identified in the forfeiture complaint. The
stringent requirements of the Admiralty Rules cannot so blithely
be skirted.

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time, judgment had entered. Since the government made no showing

legally sufficient to warrant relief from the original decree,6

the district court was without lawful power to modify the

judgment by increasing its scope.

We need go no further. We hold that, given the

complete absence of any description of, or reference to, the

Athens St. parcel in either the original complaint or the

paperwork associated with it, the particularity requirements of

Admiralty Rules C(2) and E(2)(a) were not satisfied as to that

parcel. Hence, the judgment below must be reversed and the

original judgment reinstated. At the same time, however, we deny

the claimant's cursory request for attorneys' fees under the

Equal Access to Justice Act, 28 U.S.C. 2412 (1988). See Ryan
___ ____

v. Royal Ins. Co., 916 F.2d 731, 734 (1st Cir. 1990) (an
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appellate court will ordinarily decline to consider "issues

adverted to on appeal in a perfunctory manner, unaccompanied by

some developed argumentation"); United States v. Zannino, 895
______________ _______

F.2d 1, 17 (1st Cir.) (same), cert. denied, 494 U.S. 1082 (1990).
_____ ______



Reversed and remanded.
Reversed and remanded.
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6This would be a different case if, after entry of final
judgment, the government were able to show, within the time
parameters allowed by law, that the original judgment should be
set aside for some reason cognizable under Fed. R. Civ. P. 59(e)
or Fed. R. Civ. P. 60(b). The government, however, has not
advanced any such asseveration.

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