Can a district court order forfeiture of substitute assets far in excess of the personal money judgment balance owed?

QUESTION(S) PRESENTED Question 1: Can a district court order forfeiture of substitute assets far in excess of the personal money judgment balance owed? 21 U.S.C. § 853(p) authorizes forfeiture of substitute assets only "up to the value of" the unavailable offense proceeds. Until now, every district and circuit court had found that the forfeiture of substitute assets exceeding the value of the personal money judgment was not authorized by the statute. The District Court for the Western District of Tennessee entered a forfeiture order against Petitioner which vested in the government title to three parcels of real property worth a combined total of three times the money judgment amount Petitioner owes. The Sixth Circuit currently stands alone when it affirmed this forfeiture order as lawful. Thus, this decision has created a circuit split with the Second, Fourth, Seventh and Eleventh Circuit Courts of Appeal.