Honda Lease Trust v. Malanga''s Automotive
Split Score
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Case Summary
Disposition
Affirmed in Part
Honda Lease Trust challenged Butler Township’s towing ordinances after its leased vehicle was impounded for nearly a year without notice. The Third Circuit held that Butler’s notice and hearing procedures violate procedural due process, reversing and remanding on that claim, but affirmed the district court’s rejection of Honda’s Fourth- and Fifth-Amendment claims.
Circuit Split Identified
Legal Issue
Whether the prolonged retention of property that was lawfully seized at its inception is governed by the Fourth Amendment’s reasonableness requirement or solely by due-process principles.
Circuit Positions
Continued detention of lawfully seized property is not a Fourth-Amendment seizure; challenges lie under due process only.
Ongoing retention of property after a lawful initial seizure is itself subject to Fourth-Amendment reasonableness.
Conflict Summary
Five circuits (1st, 2nd, 6th, 7th, and 11th) hold that once a seizure is valid at its start, an owner’s remedy for extended detention sounds only in due process or state law; the Fourth Amendment is not implicated. The 9th and D.C. Circuits conclude that continued retention itself constitutes an ongoing Fourth-Amendment ‘seizure’ that must remain reasonable. In this opinion, the 3rd Circuit expressly adopts the latter view and joins the 9th and D.C. Circuits.