The following excerpt is from Kuck v. Danaher, 600 F.3d 159 (2nd Cir. 2010):
In precisely this way, we have recently held that deprivations may not be indefinite, particularly where delay cannot be attributed to any clear state interest or the risk of erroneous deprivation is significant. In Krimstock v. Kelly, 306 F.3d 40 (2d Cir.2002), for example, we considered New York City's civil forfeiture procedures for vehicles involved in alleged crimes such as driving while intoxicated. Under city policy, the city would seize vehicles immediately after an arrest, but forfeiture hearings awaited the completion of the underlying criminal proceedings. This practice frequently meant that owners were deprived of their vehicles for a year or more before they had any opportunity to challenge the seizure. See id. at 44-46. We concluded that this interval was simply too long in light of the private interests at stake. "To say that the forfeiture proceeding, which often occurs more than a year after a vehicle's seizure, represents a meaningful opportunity to be heard at a meaningful time on the issue of continued impoundment is to stretch the sense of that venerable phrase to the breaking point." Id. at 53. The seizure of real property, especially a vehicle used for daily transportation, called for a more timely opportunity to challenge the deprivation. See id. at 50, 60-62.
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