What is the burden of proving innocent owner of property?

To qualify as an innocent owner of property, however, the ownership interest must be more than nominal. While "[t]he claimant in a forfeiture action has the burden of showing that he owns or has an interest in the forfeited property," United States v. One Parcel of Land, Known as Lot 111-B, 902 F.2d 1443, 1444 (9th Cir.1990), she must also demonstrate that her interest is "more than nominal." Id. at 1445. "Possession of mere legal title by one who does not exercise dominion and control over the property is insufficient ... to establish standing to challenge a forfeiture." Id. at 1444 (citations and internal quotations omitted). No standing exists where "the title holder is a strawman holding nominal title as a subterfuge for a drug trafficker, rather than being a true owner of an interest in the property." United States v. Vacant Land, 15 F.3d 128, 130 (9th Cir.1993). In the latter case we said that