In the case of Honeycutt v. United States, Terry Honeycutt managed sales and inventory at a store owned by his brother Tony Honeycutt. The brothers sold an iodine-based water purification product that can also be used to manufacture methamphetamine. After making significant profits from this product, they were charged with federal drug offenses. While Tony pleaded guilty and forfeited $200,000 in assets acquired through the illegal activity, Terry argued he was not liable for forfeiture because he did not personally profit from the sales. The Supreme Court ruled in favor of Terry Honeycutt stating that forfeiture liability under 21 U.S.C §853 is limited to property the defendant himself actually acquired as a result of the crime; it does not extend to property obtained by other individuals involved in the same criminal act but which was never possessed by or belonged to him directly.

In the dissenting opinion for Honeycutt v. United States, Justice Clarence Thomas argued that the majority's interpretation of the Comprehensive Forfeiture Act was incorrect. He contended that under a plain reading of the statute, co-conspirators should be held jointly and severally liable for forfeiture judgments regardless of their individual contributions to profits from illegal activity. The justice believed this approach would align with traditional principles of conspiracy liability and serve as an effective deterrent against criminal enterprises by ensuring all participants could be held accountable for full restitution. Furthermore, he expressed concern that limiting forfeiture to direct proceeds might incentivize criminals to structure their operations in ways that shield most members from significant financial penalties.