Congress has provided for the forfeiture of practically any type of property related to an illegal activity in order to take the profit out of crime. The federal forfeiture statute dealing specifically with criminal drug activity is commonly known as the Controlled Substances Act. This Comment focuses on the civil forfeiture proceedings4 of the Controlled Substances Act and the drug activity portion of Missouri's Criminal Activity Forfeiture Act' (CAFA). This Comment traces how the "War on Drugs" has turned a legitimate criminal penalty into a strong-arm tactic that has been abused by law enforcement agencies across the country.

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