While the U.S. Supreme Court has held that a "punitive" forfeiture order may constitute a constitutionally excessive fine "if it is grossly disproportional to the gravity of a defendant's offense," United States v. Bajakajian, 524 U.S. 321, 334 (1998)—and while the Second Circuit has since articulated various factors for courts to consider in evaluating whether an order of forfeiture is "grossly disproportional," United States v. Viloski, 814 F.3d 104 (2d Cir. 2016)—defendants have not historically been successful in challenging an otherwise properly calculated forfeiture order as constitutionally excessive.