When a confidential informant admits his own participation in illegal activity and where the statement tended to subject the informant to criminal liability such that a reasonable person in his position would not have admitted it unless he believed it to be true, the statement has a high indicia of reliability. In Re Forfeiture of United States Currency, 172 Mich App 200, 206-207; 431 NW2d 437 (1988); People v Gleason, 122 Mich App 482, 491; 333 NW2d 85 (1983); MRE 804(b)(3). Furthermore, a warrant may issue based upon the information provided by a confidential informant when the police conduct an independent investigation to confirm the accuracy and reliability of the information.

The Court of Appeals first observed that forfeiture actions are in rem proceedings. In re Forfeiture of $28,088 of United States Currency, 172 Mich. App. 200, 203; 431 N.W.2d 437 (1988). In rem jurisdiction over personal property within Michigan lies with courts of record in this state.

Assuming, without deciding, that the Attorney General was vulnerable to a standing challenge below, we deem appellate objections forfeited because none was raised. See In re Complaint of Mich Cable Telecom Ass'n, 241 Mich App 344, 361-362; 615 NW2d 255 (2000) (affirming a decision to reject a challenge to a party's standing on the ground that the challenge was not timely brought); In re Forfeiture of $28,088, 172 Mich App 200, 205; 431 NW2d 437 (1988) (declining to entertain the appellee's challenge to the claimant-appellant's standing where the issue was not raised below and there was no cross-appeal). For these reasons, we will consider the tree-trimming/forestry tracker as part of the claim that the PSC engaged in improper retroactive ratemaking.

We reject as unsupported by the record respondent's recent claim that petitioner is not engaged in a business enterprise, particularly in view of respondent's concession to the contrary before the tribunal. In re Forfeiture of $28,088 of United States Currency, 172 Mich. App. 200, 206; 431 N.W.2d 437 (1988). In any event, subsection 4(f) refers to business enterprises in order to distinguish production for commerce from production for personal use. Mueller, supra at 574.

Forfeiture proceedings are in rem proceedings. In re Forfeiture of $28,088, 172 Mich. App. 200, 203; 431 N.W.2d 437 (1988). A forfeiture proceeding brought under the controlled substances act requires the seizing agency to be in possession or control of the res in order to vest the court with jurisdiction to enter an order of forfeiture.

Also noteworthy is the fact that the majority of courts considering the issue have applied the rules of evidence, including the exclusionary rule, to forfeiture proceedings. See Conservation Dep't v Brown, 335 Mich. 343, 350-351; 55 N.W.2d 859 (1952) (reviewing legality of a seizure of illegally used fishing nets during a forfeiture proceeding); In re $15,232, supra, 183 Mich. App. 834-837 (hearsay not admissible); In re Forfeiture of $28,088 of United States Currency, 172 Mich. App. 200, 206; 431 N.W.2d 437 (1988) (reviewing validity of a search warrant during a forfeiture proceeding); In re Forfeiture of United States Currency, 171 Mich. App. 684, 686-687; 431 N.W.2d 42 (1988) (reviewing legality of investigative stop during a forfeiture proceeding); In re Forfeiture of United States Currency, 166 Mich. App. 81, 89, 91-92; 420 N.W.2d 131 (1988) (holding that a suppression issue decided in a criminal case could not be relitigated in a forfeiture proceeding, but that the rules of evidence should be strictly applied). We note that the ruling in In re Forfeiture of One 1985 Mercedes Benz, 174 Mich. App. 203, 205; 435 N.W.2d 426 (1988), in which a panel of this Court indicated that hearsay evidence was admissible in a forfeiture proceeding, goes against the weight of authority.

Forfeiture proceedings are in rem proceedings. In re Forfeiture of $28,088 of United States Currency, 172 Mich. App. 200, 203; 431 N.W.2d 437 (1988). In rem jurisdiction over personal property situated within this state lies with the courts of record of the state.

See MCL 333.7523; MSA 14.15(7523); In re Forfeiture of $28,088, 172 Mich. App. 200; 431 N.W.2d 437 (1988). Martin's personal interest was already subject to the tax lien under MCL 205.29(1); MSA 7.657(29)(1), which provides in pertinent part:

Forfeiture proceedings are in rem civil proceedings. People v US Currency, 158 Mich. App. 126; 404 N.W.2d 634 (1986); In re Forfeiture of $28,088, 172 Mich. App. 200; 431 N.W.2d 437 (1988). The civil in rem forfeiture proceeding is a legal anomaly that proceeds on an archaic theory that inanimate objects themselves can be guilty of wrongdoing. Winn, Seizures of private property in the war against drugs: What process is due? 41 Southwestern L J 1111 (1988).

However, our Courts have declined to adopt a good faith exception, finding greater protection afforded defendant under our own state constitution. See, e.g., People v Tanis, 153 Mich. 806, 813; 396 N.W.2d 544 (1986), lv den 426 Mich. 877 (1986); In re Forfeiture of $28,088, 172 Mich. App. 200, 206, n 1; 431 N.W.2d 437 (1988). Reversed.