Indiana Code

Ind. Code § 34-24-1-3 (2026)

Action for forfeiture; procedure

✓ current as of May 2026
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     Sec. 3. (a) The prosecuting attorney for the county in which the seizure occurs may, within twenty-one (21) days after receiving written notice from the owner demanding return of the seized property or within ninety (90) days after the property is seized, whichever occurs first, cause an action for forfeiture to be brought by filing a complaint in the circuit or superior court in the jurisdiction where the seizure occurred. The action must be brought:

(1) in the name of the state; and

(2) within the period that a prosecution may be commenced under IC 35-41-4-2 for the offense that is the basis for the seizure.

     (b) If the property seized was a vehicle or real property, the prosecuting attorney shall serve, under the Indiana Rules of Trial Procedure, a copy of the complaint upon each person whose right, title, or interest is of record in the bureau of motor vehicles, in the county recorder's office, or other office authorized to receive or record vehicle or real property ownership interests.

     (c) If, after the expiration of the twenty-one (21) or ninety (90) day period described in subsection (a), the prosecuting attorney has not filed a complaint initiating an action for forfeiture, the property shall be returned immediately to the owner, or to a lienholder or bona fide purchaser for value. If the property is returned without a complaint for forfeiture having been filed, the owner, lienholder, or bona fide purchaser for value is not liable for any costs or fees incurred in storing, transporting, or maintaining the property.

     (d) The owner of the seized property, or any person whose right, title, or interest is of record may, within twenty (20) days after service of the complaint under the Indiana Rules of Trial Procedure, file an answer to the complaint and may appear at the hearing on the action.

     (e) If, at the end of the time allotted for an answer, there is no answer on file, the court, upon motion, shall enter judgment in favor of the state and shall order the property disposed of in accordance with section 4 of this chapter.

[Pre-1998 Recodification Citation: 34-4-30.1-3.]

As added by P.L.1-1998, SEC.19. Amended by P.L.201-2011, SEC.108; P.L.47-2018, SEC.2.

 

Notes of Decisions
Cited in 20 cases (3 in the last 5 years), 1998–2024 · leading case: Jeana M. Horner v. Terry R. Curry, 125 N.E.3d 584 (Ind. 2019).
Jeana M. Horner v. Terry R. Curry, 125 N.E.3d 584 (Ind. 2019). · cites it 8× “See I.C. § 34-24-1-3. And instead of using the case-specific reimbursement scheme, as under the former law, the new Statute outlines a specific formula for distributing these costs.”
State v. Combs, 921 N.E.2d 846 (Ind. Ct. App. 2010). · cites it 6× “Ind.Code § 34-24-1-3. 2 . Combs' plea agreement is dated June 2, 2008, but a separate stipulation filed on July 14 in the civil action states that the trial court accepted Combs' plea agreement on May 30, 2008.”
Washington v. Marion Cnty. Prosecutor, 264 F. Supp. 3d 957 (S.D. Ind. 2017). · cites it 8× “Ind. Code § 34-24-1-3 . At the .end of the applicable time period, the government may file a complaint in the circuit or superior court in the jurisdiction where the seizure occurred for the reimbursement of law enforcement costs and forfeiture, or it may return the property to…”
$100 & a Black Cadillac v. State, 822 N.E.2d 1001 (Ind. Ct. App. 2005). · cites it 4× “Ind.Code § 34-24-1-3 contains one exception to its general rule that a judicial trial will occur prior to forfeiture of seized property.”
Martin v. Indiana State Police, 537 F. Supp. 2d 974 (S.D. Ind. 2008). · cites it 6× “In Count VI, he alleges that the defendants violated Indiana Code § 34-24-1-3 by keeping his property without bringing a forfeiture action in an Indiana court within 180 days after the seizure.”
Victor Hugo Mesa v. State of Indiana, 5 N.E.3d 488 (Ind. Ct. App. 2014). · cites it 14× “2 Mesa cited to Indiana Code § 34-24-1-3 but discussed the text of Indiana Code § 34-24-1-4.”
Lewis v. State, 755 N.E.2d 1116 (Ind. Ct. App. 2001). · cites it 2× “Ind.Code § 34-24-1-3 (Burns Code Ed. Repl1998) states that the court shall, upon motion, "enter judgment in favor of the [Sltate and the unit (if appropriate)," if the owner of the seized property, or anyone with *1122 right, title or interest of record in the property, fails to…”
Allburn v. State Ex Rel. Warrick Cnty. Sheriff's Dep't, 826 N.E.2d 682 (Ind. Ct. App. 2005). · cites it 2× “" "If, at the end of the time allotted for an, answer, there is no answer on file, the court, upon motion, shall enter judgment in favor of the state and the unit (if appropriate).”
Adams v. State, 967 N.E.2d 568 (Ind. Ct. App. 2012). “Specifically, Adams claims that his lack of notice of the motion violated Indiana Code Sections 34-24-1-3 and -4, which expressly require adherence to the Indiana Rules of Trial Procedure before a prosecutor finally disposes of seized property.”
Larry W. Wilson v. State of Indiana ex rel. Evansville-Vanderburgh Cnty. Drug Task Force (mem. dec.), 121 N.E.3d 151 (Ind. Ct. App. 2019). · cites it 6× “I.C. § 34-24-1-3(a) (2011). 4 [12] Wilson argues that the State did not timely file its complaint for forfeiture because the State failed to properly serve him for eight months.”
Angela Y. Smith v. State of Indiana (Ind. 2024). · cites it 4× “See Ind. Code § 34-24-1-3 (d). In fact, our review of the record and other documents on Odyssey suggest that he was never personally served.”
State of Ind., Consol. City of Indianapolis/Marion Co. v. El Rodeo 11, Llc., 25 N.E.3d 781 (Ind. Ct. App. 2015). · cites it 6× “2010); see also Ind.Code § 34-24-1-3 (authorizing the “prosecuting attorney for the county in which the seizure occurs” to bring a civil forfeiture action “in the name of .”
— Ind. Code § 34-24-1-3(a) — 3 cases
Jeana M. Horner v. Terry R. Curry, 125 N.E.3d 584 (Ind. 2019). “See I.C. § 34-24-1-3. And instead of using the case-specific reimbursement scheme, as under the former law, the new Statute outlines a specific formula for distributing these costs.”
Larry W. Wilson v. State of Indiana ex rel. Evansville-Vanderburgh Cnty. Drug Task Force (mem. dec.), 121 N.E.3d 151 (Ind. Ct. App. 2019). “I.C. § 34-24-1-3(a) (2011). 4 [12] Wilson argues that the State did not timely file its complaint for forfeiture because the State failed to properly serve him for eight months.”
City of Muncie v. Stanley Benford (Ind. Ct. App. 2013).
— Ind. Code § 34-24-1-3(b) — 1 case
Victor Hugo Mesa v. State of Indiana, 5 N.E.3d 488 (Ind. Ct. App. 2014). “2 Mesa cited to Indiana Code § 34-24-1-3 but discussed the text of Indiana Code § 34-24-1-4.”
— Ind. Code § 34-24-1-3(d) — 3 cases
$100 & a Black Cadillac v. State, 822 N.E.2d 1001 (Ind. Ct. App. 2005). “Ind.Code § 34-24-1-3 contains one exception to its general rule that a judicial trial will occur prior to forfeiture of seized property.”
Allburn v. State Ex Rel. Warrick Cnty. Sheriff's Dep't, 826 N.E.2d 682 (Ind. Ct. App. 2005). “" "If, at the end of the time allotted for an, answer, there is no answer on file, the court, upon motion, shall enter judgment in favor of the state and the unit (if appropriate).”
Angela Y. Smith v. State of Indiana (Ind. 2024). “See Ind. Code § 34-24-1-3 (d). In fact, our review of the record and other documents on Odyssey suggest that he was never personally served.”
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