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O'Keeffe v. Snyder

Supreme Court of New Jersey
416 A.2d 862 (N.J. 1980)


In 1976, artist Georgia O’Keeffe (plaintiff) brought suit seeking the return of three of her paintings, which she alleged were stolen from an art gallery in 1946. Barry Snyder (defendant), purchased the paintings in 1975 from a third party. In court, Snyder asserted: (1) he was a purchaser for value, (2) he had title by adverse possession, and (3) O’Keeffe’s action was barred by the applicable six-year statute of limitations. The trial court put the burden on O’Keefe. It found O’Keeffe’s action was barred, because she had not commenced it within six years of the alleged theft. The appellate court found the opposite. It put the burden on the subsequent purchaser to prove the elements of adverse possession. The appellate court then found Snyder had not proved adverse possession. Thus, O’Keeffe could still enforce her right to possession of the paintings. Snyder appealed.

Rule of Law


Holding and Reasoning (Pollock, J.)

Dissent (Handler, J.)

Dissent (Sullivan, J.)

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