Facts of the Case

Tyson Timbs purchased a Land Rover for approximately $42,000 in January 2013 using the proceeds from his father’s life insurance policy. During the following four months, Timbs used the vehicle for multiple trips within Indiana to transport heroin. After a series of controlled purchases involving a confidential informant, Timbs was arrested at a traffic stop. At the time of his arrest in May, the Land Rover had approximately 15,000 more miles on it than when he purchased it in January.

The state charged Timbs with two charges of felony dealing and one charge of conspiracy to commit theft. He later pleaded guilty to one charge of felony dealing and one charge of conspiracy to commit theft in exchange for the state dismissing the remaining charge. After accepting the plea, the trial court sentenced Timbs to six years, five of which were to be suspended. Timbs also agreed to pay fees and costs totaling approximately $1200.

In addition, the state sought to forfeit Timbs’ Land Rover. The trial court denied the state’s action, ruling that the forfeiture would be an excessive fine under the Eighth Amendment, characterizing it as grossly disproportional to the seriousness of the offense. The court also noted that the maximum statutory fine for Timbs’ felony dealing charge was $10,000, and the vehicle was worth roughly four times that amount when Timbs purchased it. The trial court ordered the state to release the vehicle immediately. The court of appeals affirmed.

The Indiana Supreme Court reversed, concluding that the U.S. Supreme Court had never clearly incorporated the Eighth Amendment against the states under the Fourteenth Amendment. The court also ruled that the state had proven its entitlement to forfeit the Land Rover under state law.