New U.S. Laws Revive Two Nazi-Looted Art Claims
Two lawsuits filed in California seek return of paintings that claimants describe as looted by the Nazis, held by museums in Los Angeles County and in Poland. The Guardian
They are the first cases filed after California and the U.S. Congress passed laws changing U.S.-based claims for artwork forcibly taken from Jewish families during World War II. At the federal level, Senate Bill S.1884, the Holocaust Expropriated Art Recovery Act of 2025, establishes procedures for civil claims to recover artwork and other property lost between 1933 and 1945 because of Nazi actions.
The first suit was filed in Los Angeles Superior Court on Monday by the Jewish Federation of Greater Los Angeles and its board chair Daniel Gryczman against the Norton Simon Museum in Pasadena. It seeks return of Adam and Eve, two lifesize oil-on-panel works created by Lucas Cranach the Elder in 1530. Rabbi Noah Farkas is president and CEO of the Jewish Federation of Los Angeles.
The ownership history, called provenance, traces the Cranachs through Dutch Jewish art dealer Jacques Goudstikker. The panels belonged to the Stroganoff family and were put up for sale in 1931 by the Soviet Union at a Berlin auction, where Goudstikker bought them. They were later seized from his collection by Hermann Göring, Adolf Hitler's second-in-command. Goudstikker's dealership was looted by the Nazis in 1940. Marei von Saher, sole heir of Goudstikker, signed over her rights to the Jewish Federation of Los Angeles. The Federation plans to use most of the net proceeds from recovered art to help about 2,500 Holocaust survivors living in the Los Angeles area.
This is not the first litigation over the Cranachs. Goudstikker's heirs tried before without success to recover the works from the Norton Simon Museum. Pasadena Star-News The museum states that a federal court in 2018 unanimously determined the museum had proper title to the paintings. The U.S. Supreme Court declined in May 2019 to hear the case, leaving lower court rulings in place. The paintings were sold in the 1960s to the Pasadena Museum of Modern Art, which was renamed the Norton Simon Museum in honor of its benefactor.
The second suit was filed in federal court in Los Angeles on the same day by the daughters of the late Dina Gottliebova Babbitt. It seeks return of watercolors held by the Auschwitz-Birkenau museum in Poland. Babbitt was a Holocaust survivor and California-based animator who was held in Auschwitz. The watercolors depict fellow prisoners and were works she was forced to paint for Josef Mengele, a Nazi physician nicknamed the Angel of Death.
Spokespersons for both museums say the museums legally hold title to the works and intend to continue displaying them to the public. The lawsuits do not specify the monetary value of the paintings. Between 1933 and 1945, the Nazi regime seized more than 600,000 works of art across Europe from Jewish families, collectors and museums.
The broader context here is whether revised time-limit and choice-of-law rules can reopen title disputes thought to be settled. The questions include res judicata, the rule against relitigating a decided case, after the 2018 federal judgment and 2019 denial of certiorari, whether California law can apply to a Polish state museum, and the distinction between private restitution and public memorial display. The Babbitt claim sharpens that last tension, with heirship on one side and a memorial institution's claim to preserve prisoner-created evidence where it was made on the other. How courts construe the new federal and state procedures will shape cases far beyond these two sets of paintings.
