Campbell v City of Spencer

Agents of City seized 44 horses from Campbell and obtained title to them in a state forfeiture proceeding. Campbell did not raise any 4th Amendment challenges to the seizure at trial or on appeal. She filed a 1983 action seeking the value of the horses. The federal district court granted judgment to City on claim preclusion grounds and the panel affirmed. It held that because Campbell could have raised her 4th Amendment claim in the forfeiture procedure under both Oklahoma and federal law, made the tactical decision not to raise them and granting her judgment here would necessarily impair the property rights City obtained during the forfeiture proceeding, she was barred from bringing them in her 1983 Action. The panel noted and this also leads to applying claim preclusion