On August 10, a panel of the Second Circuit held that the government may not rely on “exigent circumstances” to indefinitely seize property in the absence of a warrant.  The defendant, William R. Cosme, was arrested in December 2012 and charged with wire fraud.  At the time of his arrest, the government froze two of his bank accounts and seized several of his cars.  No warrant was ever obtained, but the district court issued an order allowing the government to hold the seized property until the conclusion of its criminal case.   On appeal, the Second Circuit panel vacated that order, holding that under the Fourth Amendment, the government could not indefinitely seize the property without a warrant or a judicial determination that probable cause supported the forfeitability of the assets.  United States v. Cosme, 14-1625-cr (2d Cir.).