Mathias, J.
The State appeals the Allen Circuit Court’s order setting a jury trial on the State’s in rem forfeiture complaint against $2,435 in cash seized from Alucious Kizer during an arrest. The State raises a single issue for our review, namely, whether the trial court erred when it concluded that Article 1, Section 20 of the Indiana Constitution requires a jury trial in civil forfeiture proceedings. We reverse and remand for further proceedings.
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The State appeals the trial court’s order setting the State’s in rem forfeiture complaint for a jury trial. Article 1, Section 20 of the Indiana Constitution provides that, “[i]n all civil cases, the right of trial by jury shall remain inviolate.” “Whether certain claims are entitled to a trial by jury presents a pure question of law” that we will review de novo. Lucas v. U.S. Bank, N.A., 953 N.E.2d 457, 460 (Ind. 2011).
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The trial court erred when it concluded that Article 1, Section 20 of the Indiana Constitution requires a jury trial on the State’s in rem forfeiture complaint. Our Supreme Court has been clear on the scope of Article 1, Section 20: “This constitutional provision preserves the right to a jury trial only as it existed at common law, and a party is not entitled to a jury trial on equitable claims.” Lucas, 953 N.E.2d at 460; see also Ind. Trial Rule 38(A) (“Issues of law and issues of fact in causes that prior to the eighteenth day of June, 1852, were of exclusive equitable jurisdiction shall be tried by the court . . . .”).
The Indiana Supreme Court has long held that a complaint by the State for the forfeiture of illegal property is “not a civil case under the common law when the Constitution was adopted . . . and so it has been uniformly held in this state that . . . [the] parties are not entitled to trial by jury as a constitutional right.” Campbell v. State, 171 Ind. 702, 87 N.E. 212, 214-15 (1909). We have similarly recognized that, “[b]y denying individuals the ability to profit from ill-gotten gain, an action for forfeiture resembles an equitable action for disgourgement or restitution.” Caudill v. State, 613 N.E.2d 433, 437 (Ind. Ct. App. 1993), clarified on other grounds, Katner v. State, 655 N.E.2d 345, 349 (Ind. 1995).
It is well-settled that the State’s civil forfeiture complaints are outside of Article 1, Section 20, and are instead equitable claims to be tried by the court. We therefore reverse the trial court’s order setting the State’s complaint here for a jury trial and remand for further proceedings consistent with this decision.
Reversed and remanded.
Robb, J., and Crone, J., concur.