Sharpnack, J.
In March 2012, Curtis filed a Motion for Relief from Judgment Pursuant to Trial Rule 60(B)(1), (3), or (8). In the motion, Curtis again stated that his attorney did not notify him of the forfeiture order and again challenged the forfeiture on grounds that the pirated movies did not constitute stolen property. Specifically, Curtis cited Dowling and argued that “I.C. 34-24-1-1 does not provide for forfeiture of a vehicle for violating I.C. 4 35-43-5-4(10).” Appellant’s App. p. 28. The trial court denied the motion without a hearing. Curtis now appeals.
Here, the forfeiture of Curtis’s truck was based on the assumption that the content of the pirated movies sold out of the truck constituted “stolen . . . or converted property.” Ind. Code § 34-24-1-1(a)(1)(B). We must disagree. As noted in Dowling, “the property rights of a copyright holder have a character distinct from the possessory interest of the owner of simple goods, wares, or merchandise.” 473 U.S. at 217 (quotation omitted). Moreover, Section 34-24-1-1(a)(1)(B) clearly allows forfeiture in cases of theft or conversion but says nothing about copyright infringement or even fraud, the crime to which Curtis pleaded guilty. See Chan v. State, 969 N.E.2d 619, 621 (Ind. Ct. App. 2012) (“[F]orfeitures are not favored in the law, and statutes authorizing forfeitures are strictly construed.”).
. . . [T]he State argues that Curtis cannot challenge the forfeiture inasmuch as he already pleaded guilty to committing the underlying crime with his truck. The crime to which Curtis pleaded guilty, however, was not theft or conversion, and the forfeiture provision here allows seizure only in cases of stolen or converted property.
As the forfeiture of the truck was not authorized by statute, we conclude that Curtis has established extraordinary circumstances justifying relief.
ROBB, C.J., and KIRSCH, J., concur.