Overview
- A three-judge Eleventh Circuit panel affirmed a district court’s refusal to grant Michael Prime relief under Rule 41(g) over a destroyed external hard drive he later claimed held keys to roughly 3,443 bitcoin.
- The court applied the doctrine of laches, calling Prime’s delay inexcusable and prejudicial because the government cannot return the destroyed device or procure replacement bitcoin.
- Judges noted Prime repeatedly minimized his cryptocurrency holdings to investigators, probation officers, and the sentencing court before later asserting he controlled thousands of bitcoins.
- Federal agents executed multiple searches that found no tokens, private keys, or recovery seeds, and the Secret Service later issued notices offering to wipe and return devices before ultimately destroying them when Prime failed to cooperate.
- The ruling leaves Prime without return or compensation for what media have estimated as $345–$354 million in bitcoin, with the panel expressing doubts the stash ever existed.