In the 1938 case United States v. One 1936 Model Ford V-8 De Luxe Coach, the U.S. Supreme Court ruled on a matter involving civil forfeiture laws. The federal government had seized a vehicle used to transport illegal alcohol during Prohibition and sought to retain possession of it under forfeiture statutes, despite the owner's claim that he was unaware of its illicit use at the time. The court held that innocent owners could not be deprived of their property without due process under the Fifth Amendment, even if their property was involved in criminal activity unbeknownst to them. This ruling set an important precedent for future cases involving civil asset forfeiture by establishing protections for innocent owners whose property is implicated in crimes they did not commit or were unaware of.

In the dissenting opinion for United States v. One 1936 Model Ford V-8 De Luxe Coach, Justice Black disagreed with the majority's decision to uphold the forfeiture of a vehicle used in committing a federal liquor law violation. He argued that such punishment was excessive and disproportionate to the offense committed, thus violating constitutional protections against cruel and unusual punishments as well as due process rights. Furthermore, he contended that this case represented an overreach by Congress in its authority to regulate interstate commerce under which it had enacted prohibition laws. According to him, while Congress could punish individuals who violated these laws directly or indirectly through their property use, it should not have power to confiscate personal property without providing compensation or proving individual guilt beyond reasonable doubt.