In United States v. $8,850 (1983) 461 U.S. 555, the court characterized Lovasco as requiring "a deliberate attempt to gain an unfair tactical advantage over the defendant" or "reckless disregard of the delay's probable prejudicial impact" in assessing due process challenges based on delay in instituting criminal prosecutions. (Id. at p. 563.) However, it did so for the purpose of summarizing the government's position that the standard applicable to pre-accusation delay provided the appropriate test for determining the consequences of governmental delay in filing a civil forfeiture proceeding--a proposition the court rejected. (Ibid.)