Nichols v. Wayne County, Michigan

(1) Whether due process requires municipalities, after seizing a vehicle in the name of civil forfeiture, to provide the vehicle owner a prompt hearing before a neutral judge to decide whether the municipality may, while litigating the forfeiture, deny the owner continued possession and use of the vehicle; and (2) whether a claim alleging municipal failure to afford a constitutional right requires a plaintiff to plead not only the existence of a policy denying the right but also the existence of policies denying all the means by which the right may be afforded.