Hoelzer v. City of Stamford
United States Court of Appeals for the Second Circuit
972 F.2d 495 (1992)

- Written by Kelli Lanski, JD
Facts
In 1934, the Works Progress Administration commissioned a nationally known artist to paint six large murals on canvas affixed to the walls of Stamford High School in Connecticut. In 1970, the murals were removed during school renovations, and a school alum took them home, eventually giving them to Karel Yasko, who worked for the United States General Services Administration (GSA). The murals were wet, dirty, and damaged from the construction, and Yaskel transferred them to Hiram Hoelzer (plaintiff), an art restorer. Throughout the 1970s and 1980s, Hoelzer spent a significant amount of time restoring the murals, updating Yaskel and periodically requesting compensation. Yaskel did not respond and did not pay Hoelzer. During the 1980s, representatives from the City of Stamford (Stamford) (defendant) visited Hoelzer’s studio and were aware of the restoration work he was performing. Also during the 1980s, Stamford asked Hoelzer to return the murals so they could be displayed at the high school again. At that time, the murals were appraised at $1,250,000. Hoelzer refused and sued Stamford, seeking a declaratory judgment awarding him the title for the murals or compensation for his services in restoring and safeguarding them. The trial court found that Stamford owned the murals and Hoelzer was owed $557,200 for his restoration work. That amount was multiples of the compensation Hoelzer had sought from Yaskel over the years but was supported by evidence presented in the case, including comparisons to fees paid for art-restoration projects by other restorers. Stamford appealed, arguing that Hoelzer did not perform the work with the good-faith belief that he had title to the murals and the trial court erred by awarding him damages. Stamford also complained that it would never have agreed to pay Hoelzer over $500,000 for the restoration and it was unfair to require Stamford to do so now.
Rule of Law
Issue
Holding and Reasoning (Lumbard, J.)
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