From the Introduction: "In 'United States v. Saccoccia', the United States Court of Appeals for the First Circuit (First Circuit) recently refused to vacate a 1993 judgment ordering Stephen Saccoccia--who is serving a 660-year prison sentence for money laundering--to forfeit $136 million to the government, the amount of money that Saccoccia and others had laundered through bank accounts that Saccoccia controlled. Saccoccia did not ask the court to overturn his convictions or to shorten his prison sentence. He sought only the return of the $136 million he forfeited as a consequence of his convictions. Saccoccia argued that the Supreme Court's 2017 decision in 'United States v. Honeycutt'--which held that the doctrine of joint-and-several liability does not apply to federal forfeiture actions arising from drug crimes--should be read to retroactively invalidate the forfeiture order in his case. The First Circuit rejected that argument, holding that Saccoccia would not be entitled to relief even if 'Honeycutt' applied retroactively."
CRS Legal Sidebar, LSB10477
Congressional Research Service: https://crsreports.congress.gov/