In U.S. v. One 1998 Tractor, Judge Jones of the W.D. Va. held that a criminal defendant's tractor was subject to forfeiture for being used in smuggling cigarettes across state lines, but that the man's trailer was not used in the smuggling and was not subject to forfeiture as part of the same "vehicle" within the meaning of 49 U.S.C. § 80302.
The underlying facts were these:
"On September 6, 2002, while returning to California after having delivered his trailer’s cargo of produce to its destination in New York, driver-owner Shimshiryan and a companion stopped at a tobacco sales outlet in Virginia in this judicial district. The two men purchased and loaded approximately twenty-three half cases of cigarettes (approximately 282,400 cigarettes) into the cab of the tractor and went on their way. Shimshiryan intended to take the cigarettes back to California and from there send them to his brother in Armenia who in turn would sell them for a profit. The sales outlet had been under surveillance by law enforcement officers and Shimshiryan was followed a few miles into the neighboring state of Tennessee. Agents from the Bureau of Alcohol, Tobacco, and Firearms, along with state and local law enforcement officers, stopped the tractor-trailer in Tennessee and recovered the cigarettes from the tractor. These cigarettes did not bear Tennessee state tax stamps as required by law. Shimshiryan’s criminal prosecution and this in rem forfeiture action followed."