Culley v. Marshall: Is there a due process right to an immediate post-seizure probable cause hearing?

On October 30, 2023, the Supreme Court will hear oral argument in Culley v. Marshall, a case that presents the question whether a person whose property has been seized for civil forfeiture under state law has the right to an immediate post-seizure probable cause hearing challenging the validity of the seizure.  I gave a presentation on that issue, discussing the status of the right to a post-seizure, pre-trial probable cause under current law in federal cases, the case law on that right in state civil forfeiture cases, and the arguments raised in the briefing in Culley, at a training conference for the FBI asset forfeiture program on September 13, 2023,  The following is the content of that presentation.

Culley v Marshall: Lecture Notes