Georgia sought civil forfeiture of Ricky Mikell’s residence and personal property after deputies found substantial marijuana, packaging materials, scales, and firearms in a bedroom used by family members. Mikell denied involvement and claimed that forfeiture of the residence would be an excessive fine under the Eighth Amendment. The trial court rejected that claim in a brief order, finding only that Mikell was not an innocent owner and that the forfeiture was not disproportionate. The Georgia Court of Appeals vacated the order and remanded. Under Howell v. State, a trial court evaluating an in-rem forfeiture must make findings addressing the forfeiture’s harshness and proportionality, the nexus between the property and criminal activity, and the claimant’s culpability. Those findings must appear on the record so an appellate court can conduct meaningful review. Because the trial court did not perform or document that analysis, its constitutional conclusion could not stand. The Court declined to consider Mikell’s additional arguments about homestead protection and lienholder notice because he had not raised them below. The trial court was directed to enter a new order with the required findings, after which either party could appeal.