Columbus-America Disc. Grp. v. At. Mut. Ins. Co.
United States Court of Appeals for the Fourth Circuit
974 F.2d 450 (4th Cir. 1992)
In 1857, the ship Central America sank. It was carrying several million dollars’ worth of gold. The gold was insured, and the policyholders were paid. The gold then became the property of the insurance underwriters, who never retrieved it from the shipwreck. In 1988, Columbus-America Discovery Group (defendant), which is not affiliated with any of the underwriters, located the wreck and was granted exclusive salvage rights by a federal district court sitting in admiralty jurisdiction. As Columbus-America retrieved the gold from the ship, the underwriters (plaintiffs) filed claims asserting that they were entitled to the gold. After a trial, the district court held that the underwriters had abandoned the gold, based on evidence that the underwriters had destroyed all original documentation of the insurance policies for the gold. Applying the law of finds, the district court held that Columbus-America was the finder and sole owner of the gold. The underwriters appealed.
Rule of Law
Holding and Reasoning (Russell, J.)
Dissent (Widener, J.)
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