United States of American v. Richard Steinmetz
United States Court of Appeals for the Third Circuit
973 F.2d 212 (1992)

- Written by Kelli Lanski, JD
Facts
During the United States Civil War, the Confederacy owned and used a steamship called the Alabama. The Alabama roamed the Atlantic Ocean and other seas for two years destroying or capturing American merchant ships operated by the Union Army. In 1864, a Union ship sunk the Alabama during a battle in international waters off the coast of France. In 1936, a British diver recovered the Alabama’s brass bell and sold it to a local bar. The bell changed owners over the next few decades, remaining in England. In the 1970s American antiques dealer Richard Steinmetz (defendant) flew to England and bought the bell by trading approximately $12,000 worth of antique guns and pistols for it. Steinmetz took the bell home to New Jersey and offered to sell or trade it to the United States Naval Academy. The Naval Academy declined. Around 10 years later, Steinmetz put up the bell for auction, at which time the United States (plaintiff) sued, claiming ownership over the bell. The United States argued that because the Alabama was sunk by a Union ship, it became the property of the United States either at the time of battle or after the Civil War as the successor to the property of the Confederacy. The district court granted summary judgment to the United States, and Steinmetz appealed.
Rule of Law
Issue
Holding and Reasoning (Sloviter, C.J.)
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