United States of America v. $5,500 in U.S. Currency, More or Less Defendant Marain Larayondra Rankins Claimant -

United States Court of Appeals
For the Eighth Circuit
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No. 25-3170
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United States of America
lllllllllllllllllllllPlaintiff - Appellee
v.
$5,500 in U.S. Currency, More or Less
lllllllllllllllllllllDefendant
Marain Larayondra Rankins
lllllllllllllllllllllClaimant - Appellant
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Appeal from United States District Court
for the Southern District of Iowa - Central
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Submitted: June 9, 2026
Filed: June 12, 2026
[Unpublished]
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Before GRUENDER, BENTON, and SHEPHERD, Circuit Judges.
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PER CURIAM.
Marain Rankins appeals the district court’s entry of default judgment in favor
of the United States in this civil forfeiture action. Also pending are Rankins’s motion
to supplement the record and the government’s motion asking this court to take
judicial notice of related criminal case court records.
In May 2023, officers executed a search warrant at Rankins’s residence and
seized, among other items, $5,500 stuffed in a shoe. The government filed a
complaint seeking to forfeit the currency under 21 U.S.C. § 881(a)(6). Rankins filed
a pro se verified claim and answer contesting the government’s action, asserting as
relevant that “I Marain Rankins is the claimant I have interest in the property because
I got restitution fee will have other cost when I get out of jail/prison and also have
commissary etc to buy while incarcerated.” On the government’s motion, the district
court struck Rankins’s claim under Supplemental Rule G(8)(c)(i)(A) of the
Supplemental Rules for Admiralty or Maritime Claims and Asset Forfeiture Actions
for failure to comply with Supplemental Rule G(5)(a)(i)(B) (requiring person
asserting interest in property to identify the claimant and state the claimant’s interest
in the property). Thereafter, the court entered default followed by a default judgment
in favor of the government, forfeiting “all right, title, and interest in the Defendant
property” to the United States. This appeal followed.
We conclude that Rankins, by asserting he was the “claimant” of the currency
at issue, and that he had “interest in the property because he got restitution fee,”
satisfied the requirement of Rule G(5) to “state the claimant’s interest in the
property.” See United States v. $579,475.00 in U.S. Currency, 917 F.3d 1047, 1049-
50 (8th Cir. 2019) (en banc) (holding that Rule G(5) establishes “only a bare-bones
requirement” to state the claimant’s interest in the property, with additional
mechanisms in place to address unsubstantiated claims); see also Erickson v. Pardus,
551 U.S. 89, 94 (2007) (per curiam) (reiterating that a document filed pro se is to be
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liberally construed). For this reason, we reverse the district court’s order striking
Rankins’s claim, remand the case for further proceedings, and dismiss the pending
motions as moot.
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