Leonard v. Texas

Issue: (1) Whether the hybrid nature of forfeiture proceedings supports the adoption of a clear and convincing standard of proof; (2) whether the Court of Appeals for the Ninth District of Texas at Beaumont's rejection of the petitioner's Eighth Amendment assertion violates due process; (3) whether the adjudicating and prosecuting tribunals' direct pecuniary interests in the outcome of forfeiture proceedings infringe on the neutrality requirement of due process and create a culture of inherent conflict of interest; and (4) whether the Texas Code of Criminal Procedure, Title 1, Chapter 59, as applied to this line of cases, is impermissibly vague in enumerating innocent-owner expectations.