In Sugalski v. Commonwealth, 131 Pa. Commw. 173, 569 A.2d 1017 (Pa. Cmwlth. 1990), an owner and representatives of estates of deceased owners of seized cash that was ultimately returned brought an action against the Commonwealth alleging failure to invest the money in an interest-bearing account while it was in state custody and failure to surrender funds to the Internal Revenue Service upon notice, resulting in $ 60,000 in fines and penalties. The Court held that "the personal property exception may only be applied to those cases where the property itself is alleged to have caused the injury." Sugalski, 569 A.2d at 1019.