Zuckerman v. The Metropolitan Museum of Art
United States District Court for the Southern District of New York
307 F. Supp. 3d 304 (2018)
In the early 1900s, the Leffmans were Jewish citizens of Germany who owned several valuable assets, including a painting by Pablo Picasso. In 1935, the German Nazi government forced the Leffmans to sell most of their assets to parties of the government’s choosing for virtually no compensation. However, the Leffmans had sent the Picasso painting to a non-Jewish friend in Switzerland for safekeeping, and it was not confiscated. The Leffmans then fled to Italy. In 1936, the Leffmans began efforts to sell the Picasso painting to raise funds, rejecting at least one unfavorable offer. As time went by, the Leffmans realized that they needed to flee Italy or risk possible death, but it would take significant funds. The Leffmans liquidated some Italian properties. The Leffmans also stepped up their efforts to sell the Picasso painting, entertaining discussions with at least two different art dealers. In 1938, the Leffmans sold the Picasso painting to a dealer named Kate Perls for $13,200, less a commission, for a net sum of $12,000. The Leffmans then used the money to flee to Brazil. The Picasso painting exchanged hands and, in 1941, was sold for $22,500 to a buyer who donated it to The Metropolitan Museum of Art (defendant) in 1952. Later, Laurel Zuckerman sued the museum on behalf of the estate of an heir of the Leffmans (plaintiff). Zuckerman argued that the Leffmans had sold the painting to Perls in 1938 due to severe economic distress and not of their own free will. Therefore, the sale contract was void, and the painting still belonged to the Leffmans.
Rule of Law
Holding and Reasoning (Preska, J.)
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