Holtzman v. Kunstmuseen Krefeld — D.C. Cir. (Nov 10, 2026)
The D.C. Circuit considers a dispute over paintings by the Dutch artist Piet Mondrian. Trustees claiming through his heir say the works were lent to a museum in Krefeld, Germany, for an exhibition in 1929, but never returned. They seek the remaining paintings and compensation for others sold or exchanged after the war. The city disputes their ownership claim. Mondrian fled Nazi persecution and died in New York in 1944. The trustees say persecution prevented him from recovering the works, and that the museum later wrongfully kept or disposed of them. A federal district court dismissed their suit under the Foreign Sovereign Immunities Act. That law generally protects foreign states and their agencies from suit, subject to exceptions. Here the claimed exception concerns property taken in violation of international law. The trustees will argue that persecution and the museum's later conduct qualify. The museum will respond that these allegations do not establish a governmental taking, even if they describe an ordinary property wrong. Listen for the difference between wrongful possession and the kind of expropriation that lets a U.S. court hear the case. This appeal concerns jurisdiction, not a final ruling on who owns the paintings.
Holtzman v. Kunstmuseen Krefeld (No. 25-7173) — United States Court of Appeals for the District of Columbia Circuit, argued November 10, 2026.
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