United States v. Neil Chandran

── United States v. Neil Chandran ── Court: Court of Appeals for the Eighth Circuit Date: May 19, 2026 Category: General United States Court of Appeals For the Eighth Circuit ___________________________ No. 25-2217 ___________________________ United States of America Plaintiff - Appellee v. Neil Suresh Chandran Defendant - Appellant ____________ Appeal from United States District Court for the District of Nebraska - Lincoln ____________ Submitted: March 20, 2026 Filed: May 19, 2026 ____________ Before COLLOTON, Chief Judge, GRUENDER and KOBES, Circuit Judges. ____________ GRUENDER, Circuit Judge. Neil Chandran was indicted for wire fraud and money laundering. The indictment also alleged that certain property was forfeitable, and the Government restrained much of that property. Over Chandran’s objection, the district court1 1 The Honorable Susan M. Bazis, United States District Judge for the District of Nebraska. issued a set of pretrial orders enabling the Government to maintain custody of the property. Chandran filed this interlocutory appeal. Because Chandran has not established that we have jurisdiction, we dismiss his appeal. I. In June 2022, Chandran was indicted for wire fraud, see 18 U.S.C. §§ 1343, 2, and money laundering, see 18 U.S.C. §§ 1957, 2. The indictment also alleged that certain property was subject to forfeiture. See 18 U.S.C. § 981(a)(1)(C); 28 U.S.C. § 2461(c). This property included bank accounts, vehicles, and real estate. A magistrate judge issued seizure warrants for almost all of the property, and the Government—through executing the seizure warrants, conducting interlocutory sales, and recording a notice of lis pendens—then restrained much of it. Chandran filed a motion before the magistrate judge, requesting (1) the return of the restrained property pursuant to Rule 41(g) of the Federal Rules of Criminal Procedure, and (2) a hearing pursuant to Luis v. United States, 578 U.S. 5 (2016) to assess whether the Government had wrongfully restrained property that he needed to pay his counsel of choice. The magistrate judge denied Chandran’s motion in part, but also granted it in part, determining that to continue maintaining custody over certain restrained property, the Government needed to obtain a court order authorizing the continued custody. In light of this ruling, the magistrate judge declined to rule on whether to grant Chandran’s requested hearing. Chandran filed objections to the magistrate judge’s order before the district court. The Government, meanwhile, asked the district court for authorization to continue maintaining custody over the restrained property. The district court issued a set of orders (the “Pretrial Orders”), which overruled Chandran’s objections and authorized the Government to continue its custody over the property. In June 2025, while his criminal proceedings continued towards trial in the district court, Chandran filed this interlocutory appeal of the Pretrial Orders. -2-  II. Chandran bears the burden of establishing that we have jurisdiction to review his appeal, an issue that we review de novo. See United States v. Afremov, 611 F.3d 970, 975 (8th Cir. 2010). “The first Judiciary Act of 1789 . . . established the general principle that only final decisions of the federal district courts would be reviewable on appeal.” Carson v. Am. Brands, Inc., 450 U.S. 79, 83 (1981) (citing 28 U.S.C. § 1291). In criminal cases,