In the 1992 case, United States v. A Parcel of Land, Buildings, Appurtenances and Improvements, Known as 92 Buena Vista Avenue, Rumson New Jersey et al., the U.S. government sought forfeiture of a property owned by Robert and Lawanda Good under federal drug laws after Mr. Good was convicted for conspiracy to possess with intent to distribute marijuana in Hawaii while living in his New Jersey home. The Supreme Court held that seizure of real property without prior notice or hearing violates the Due Process Clause of the Fifth Amendment unless there are exigent circumstances justifying such an action - which were not present in this case. The court ruled that even though Mr.Good had been convicted on drug charges earlier; it did not justify immediate seizure without due process because he posed no immediate threat nor was there risk that he would flee or remove assets from jurisdiction before they could be seized through proper procedures.

In the dissenting opinion for this case, it was argued that the majority's decision to allow civil forfeiture of property used in drug trafficking without requiring a proportionality review under the Eighth Amendment Excessive Fines Clause is incorrect. The dissenting justices believed that such forfeitures could potentially be excessive and therefore unconstitutional if they are grossly disproportionate to the gravity of an offender’s offense. They contended that by not considering whether or not these penalties were proportional, there was potential for abuse and violation of constitutional rights. Furthermore, they expressed concern over how broadly civil forfeiture laws could be applied under this ruling, leading to unjust outcomes where individuals lose their homes due to minor involvement in drug crimes.