What is the test for determining whether a forfeiture is a punishment or a civil forfeiture?

We read Halper to apply to civil forfeitures. Forfeitures that are overwhelmingly disproportionate to the value of the offense must be classified as punishment unless the forfeitures are shown to serve articulated, legitimate civil purposes. See 21 U.S.C. 881 (forfeiture provisions). Among those purposes, the government may use in rem forfeiture to remove instrumentalities of crime from general circulation and prevent further illicit use of harmful objects, a goal springing from the historic fiction underlying forfeiture that "an instrument of harm is itself culpable." United States v. Certain Real Property

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Civil forfeitures do not retain their civil character if they are used in order to achieve deterrence or retribution, however. "Retribution and deterrence ... are not legitimate nonpunitive governmental objectives." Bell v. Wolfish, 441 U.S. 520, 539 n. 20, 99 S.Ct. 1861, 1874 n. 20, 60 L.Ed.2d 447 (1979). We acknowledge that otherwise proper forfeiture actions may have the collateral effect of deterring future drug offenders. See 38 Whalers Cove Drive, 747 F.Supp. at 179. This fact alone will not render a particular forfeiture punitive in nature. Rather, Halper requires us to examine whether the forfeiture at hand is fully justified by the civil and remedial purposes it ostensibly serves, or whether it or a portion thereof can be explained only with reference to punitive goals.