With no explanation, chose the best option from "A", "B", "C" or "D". & Bldg. Known as 303 West 116th Street, New York, New York, 901 F.2d 288, 291 (2d Cir.1990); United States v. One 56-Foot Motor Yacht Named Tahuna, 702 F.2d 1276, 1281 (9th Cir.1983). Third, summary seizure procedures are available to the federal government in forfeiture cases. See 21 U.S.C. § 881(b). The ability to seize a leaseholder’s property using such procedures — without proof that it is more likely than not that the resident engaged in, or permitted, drug-related criminal activity — is an awesome power, which both Congress and the Supreme Court have seen fit to rein in. See id. § 881(a)(7) (incorporating “innocent tenant” exception and allowing seizure of property only where the drug offense is punishable by more than one year imprisonment); Bajakajian, 118 S.Ct. at 2031 (<HOLDING>). Congress sensibly limited forfeiture to the

A: recognizing culpability as important criteria for eighth amendment excessive fines claim
B: holding that excessive fines clause of eighth amendment does not apply to punitive damage awards between private parties
C: holding that forfeitures may violate the eighth amendment excessive fines clause
D: holding that the fines imposed by the challenged city ordinances are not excessive even if the excessive fines clause is applicable
C.