United States v. Kogan, 2022 WL 3362452, 2022 U.S. Dist. LEXIS 145659 (S.D.N.Y. Aug. 15, 2022):

In a strong rebuke to the government on an issue of great importance, the District Court rejected the government’s attempt to forfeit the interest of the spouses of two criminal defendants in real property held as tenants by the entireties in New Jersey and New York. The court held that the spouses’ interest in the properties, including their rights of possession and survivorship, were protected under the ancient real property doctrine, thereby precluding the government from forfeiting the real properties involved