Where a claimant asserts an ownership interest, does the claimant's standing at summary judgment require only some evidence of ownership, or also an explanation of how the claimant acquired ownership?

QUESTION PRESENTED In a civil forfeiture action, the government bears the burden of proving that the property it seeks to forfeit is connected to unlawful activity. See 18 U.S.C. § 983(c). Any claimant with a “colorable interest in the property” has standing to file a claim. United States v. Seventeen Thousand Nine Hundred Dollars ($17,900.00) in U.S. Currency, 859 F.3d 1085, 1090 (D.C. Cir. 2017). This standard is “very forgiving” to ensure that legitimate claimants can contest the forfeiture of their own property. Id. at 1089-90 (quotation marks omitted). The question presented is: Where a claimant asserts an ownership interest, does the claimant’s standing at summary judgment require only some evidence of ownership, as six circuits hold, or also an explanation of how the claimant acquired ownership, as three circuits hold?