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Bah v. United States, 2024 U.S. App. LEXIS 1157 (3d Cir. January 18, 2024) (Porter, C.J.).

Appellant Bah was a U.S. citizen, originally from Sierra Leone. He was stopped by police, who found that he was carrying cash. He was detained and then released, but U.S. Customs and Border Protection seized the cash. The money was returned with interest 2-1/2 years later. However, appellant commenced an action under the Detention Exception of the Federal Tort Claims Act, 28 U.S.C. § 2680(c). The court found that the government was immune. The Detention Exception applied to injury or loss of goods while in the possession of officer of customs. This was not an injury. The court also said that the property was seized for the purpose of forfeiture, but the appellant did not suffer a “injury or loss”. A broad reading of “injury” or “loss” ignores other relevant statutory provisions. Concerning seized hard currency, claimants are entitled to interest as well as attorney’s fees and litigation costs. Statute bars any further relief beyond this. The appellant was already paid interest for his seized cash.