Verified Complaint – Page 1 

IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF TEXAS 

BEAUMONT DIVISION 

UNITED STATES OF AMERICA § 

Plaintiff, § 

 § 

v. § Civil No. 1:23-cv-00326 

§ 

$46,640.00 IN UNITED STATES § 

CURRENCY, § 

Defendant. § 

 

VERIFIED COMPLAINT FOR FORFEITURE IN REM 

In accordance with Fed. R. Civ. P. Supplemental Rule G(2), the United States of 

America, Plaintiff, brings this complaint and alleges as follows: 

Nature of the Action 

1. This is an action to forfeit property to the United States pursuant to 21

U.S.C. § 881(a)(6). 

Defendant In Rem 

2. The property is $46,640.00 in United States Currency (Defendant 

Property). Deputies with the Jefferson County Sheriff’s Office seized the Defendant 

Property on March 23, 2023. The Defendant Property is currently in the custody of the 

United States Marshals Service. 

Jurisdiction and Venue 

3. The Court has subject matter jurisdiction over an action commenced by the 

United States pursuant to 28 U.S.C. § 1345, and over an action for forfeiture pursuant to 

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28 U.S.C. § 1355(a). 

4. The Court has in rem jurisdiction over the Defendant Property pursuant to 

28 U.S.C. § 1355(b)(1)(A) because acts or omissions giving rise to the forfeiture occurred 

in this district. 

5. Venue is proper in this district pursuant to 28 U.S.C. §1355(b)(1)(A) 

because acts or omissions giving rise to the forfeiture occurred in this district. 

Basis for Forfeiture 

6. The Defendant Property is subject to forfeiture pursuant to 21 U.S.C. 

§ 881(a)(6) because it constitutes (i) money, negotiable instruments, securities and other 

things of value furnished and intended to be furnished in exchange for a controlled 

substance in violation of the Controlled Substances Act; (ii) proceeds traceable to such an 

exchange; or (iii) money, negotiable instruments, and securities used and intended to be 

used to facilitate a violation of the Controlled Substances Act. 

Facts

 7. On March 22, 2023, Jefferson County Sheriff’s Officer conducted a traffic 

stop on a Ford Expedition on IH 10 at Major Drive, Beaumont, Jefferson County, Texas. 

The driver was identified as Byron Jaquin Hills, and the passenger was identified at 

Rondell Jerome Smith. 

The Deputy made contact through the passenger side window and explained to the 

driver, Hills, that he was speeding and driving in the left lane without passing. The 

Deputy asked Hill for the vehicles insurance and Smith provided him with the Hertz 

rental paperwork. Hill also provided a Texas Driver’s license. The Deputy asked Smith if 

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he rented the vehicle and Smith stated his mother had. The Deputy looked at the name on 

the paperwork and it was in Smith’s name and rented on 3/21/23 in New Orleans, 

Louisiana. During the conversation through the passenger window the Deputy noticed a 

faint smell of marijuana. The Deputy asked Hills to exit the vehicle and asked where he 

was headed, Hills stated he was headed to check on his grandmother and aunt, but didn’t 

know where it was, only that it was in Texas. The Deputy asked Hills where they were 

traveling from today, Hills stated Baton Rouge and that they had been there for a week 

and a half visiting family and had been to Lego Land in Florida and back to Baton Rouge. 

The Deputy found it odd that they had been in Baton Rouge for a week but had just 

rented the vehicle the day before. The Deputy asked Hills if they were traveling with 

anything illegal today like firearms, illegal narcotics or large sums of currency, Hills 

stated they were not. The Deputy requested to search the vehicle, which Hills agreed to.

The Deputy also spoke to Smith about travel and Smith stated they had been in 

Orlando, Florida with the kids and were just leaving from there. The Deputy asked from 

Florida? Smith replied they flew from Orlando back to Baton Rouge and were now 

heading back. The Deputy found it odd that they flew from Florida to Baton Rouge, to 

rent a car to drive back. The Deputy told Smith that Hills gave permission to search his 

bag and asked Smith if he could search his bag too. The Deputy asked Smith if there was 

any illegal in the vehicle, such as firearms, illegal narcotics, or large sums of currency, 

which Smith stated there was not. Smith was questioning the reason to searching the 

vehicle then denied the Deputy consent to search. The Deputy had Smith exit the vehicle 

and stand with Hills at the patrol car. While Smith was getting out of the vehicle, the 

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deputy saw a large bulge in his pants pocket. The Deputy asked if he had anything on his 

person and he stated he had some money. The Deputy asked to see, and he removed a 

large bundle of currency held together with rubber bands from his pocket. When asked 

him how much money it was, Smith stated about $4,500.00.

At this point, the Deputy requested K9 assistance, and another Jefferson County 

Sheriff’s Deputy arrived on scene and deployed a K9 who alerted a positive narcotic 

response to the vehicle.

During the search of the vehicle, the Deputies could smell marijuana had been in 

the vehicle. One of the Deputies found a duffle bag on the driver’s side back seat. The 

Deputy searched and located the Defendant Currency rubber banded in different bundles 

inside a plastic bag that was inside of a large sock within the duffle bag as well as inside 

the side pockets of the same bag. The Defendant Currency was held together with rubber 

bands in a manner that is consistent with narcotic trafficking. The Deputy resumed 

searching the vehicle. While searching a suitcase from the rear cargo area, the Deputy

located a Florida driver’s license issued to Lorenzo Smith but the picture on the license 

the Deputy recognized to be Rondell Smith. The film was pulling off the license and 

could see the photo and the information was printed on the film and not the card. The 

Deputy believed it was a fake driver’s license. Also found in the vehicle were airline 

receipts that show Smith had flown from New Orleans, Louisiana to Atlanta, GA on 3-

14-23.

Hills has a prior criminal drug history. Hills does not have reported wage and 

earnings.

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Smith has a prior criminal drug history such as conspiracy to distribute cocaine 

and money laundering, where he served 6 years in prison. Smith does not have reported 

wage and earnings. 

Due to the conflicting travel itinerary, finding a fake driver’s license and how the 

Defendant Property was packaged, the Deputy believed the Defendant Currency is drug 

proceeds. 

Potential Claimant

8. The only known potential claimant to the Defendant Property is: 

 Rondell Jerome Smith 

 Represented by Peter F. Doyle, Jr. 

 Attorney at Law 

 2901 Turtle Creek Dr., Suite 105 

 Port Arthur, Texas 77642; and 

 Byron Hills 

 16203 Fleethaven LN 

 Houston, Texas 77084 

Claim for Relief 

9. The United States respectfully requests that the Court forfeit the Defendant 

Property to the United States, award costs and disbursements in this action to the United 

States and order any other relief that the Court deems appropriate. 

Respectfully submitted, 

DAMIEN M. DIGGS 

UNITED STATES ATTORNEY 

 /s/ Michael W. Lockhart 

MICHAEL W. LOCKHART 

Assistant United States Attorney

Eastern District of Texas 

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Texas Bar No. 12472200 

550 Fannin Street, Suite 1250 

Beaumont, Texas 77701 

(409) 839-2538 

(409) 839-2643 (fax) 

michael.lockhart@usdoj.gov

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 VERIFICATION PURSUANT TO 28 U.S.C. § 1746 

I, Michael W. Lockhart, hereby state that: 

1. I am an Assistant United States Attorney for the Eastern District of Texas. 

2. I have read this Complaint, and the information contained herein is true and 

correct to the best of my knowledge. 

3. The information contained in this Complaint comes from the official files 

and records of the United States and information received from law 

enforcement officers.

I state and verify under penalty of perjury that the foregoing is true and correct. 

 /s/ Michael W. Lockhart 

 MICHEAL W. LOCKHART 

 Assistant United States Attorney

Dated: August 31, 2023. 

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