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Hahn v. Duveen
New York Supreme Court
234 N.Y.S. 185 (1929)
Andree Hahn (plaintiff) claimed to own an original painting by Leonardo da Vinci. Hahn sought to sell the painting to the Kansas City Art Museum. However, during negotiations, Joseph Duveen (defendant) told a reporter that Hahn’s painting was not a genuine da Vinci despite the fact he had not seen Hahn’s painting. Duveen asserted that the genuine version of the painting was in the Louvre. After these assertions by Duveen, the Kansas City Art Museum called off negotiations. Hahn brought an action against Duveen for slander of title. At trial, Duveen testified as to his expert opinion, stating that the painting in the Louvre was the original painting by da Vinci. Hahn submitted evidence of expert x-ray analysis of her painting. Hahn claimed that x-rays showed that her painting, which had been cut and partially painted over, matched the description from a catalogue that described the painting in 1709. One of Hahn’s experts opined that the da Vinci painting in the Louvre was by Lucretia Crivelli. In response, Duveen put forth his own experts to offer testimony on the two paintings. Duveen moved to dismiss the case, but the case went to the jury for deliberation. After 14 hours, the jury determined that it was impossible to reach a unanimous verdict. Duveen renewed his motion to dismiss.
Rule of Law
Holding and Reasoning (Black, J.)
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