Pryor Cashman's Art Law Group successfully defended our client's ownership of two paintings by renowned artist Louis Comfort Tiffany, Marketplace at Nuremberg and In the Fields at Irvington.
The client, Tiffany collector and auction house owner Allen Michaan, purchased the two paintings in 2011 from one of Tiffany's great-grandsons, Henry Platt, who was the former president of Tiffany & Co.
In 2019, two of Platt's nephews sued Michaan for the paintings, alleging that Platt had violated an "anti-alienation restriction" within the family that supposedly perpetually barred the transfer of certain Tiffany artworks outside of the family of Tiffany's blood relatives, and that no individual member of the family could ever own any such art. There is no writing that confirms such an alleged restriction, but the nephews alleged that the restriction had been orally understood and passed down for generations.
In a 43-page decision, Judge Edgardo Ramos of the U.S. District Court for the Southern District of New York awarded summary judgment to our client and dismissed the case. The court agreed with Pryor Cashman's arguments that the nephews' claims were barred by the doctrines of estoppel and laches.
In particular, the nephews and other family members had repeatedly represented to other judicial and taxing authorities that the paintings were "owned" by various family members, which was inconsistent with the claimed restriction.
The court also found that the nephews and their preceding family members had unduly delayed in seeking to enforce the claimed restriction, despite having reason to know that Platt had asserted his individual ownership of the paintings, and that such delay unduly prejudiced our client because essential evidence to prove the claimed restriction was not available: i.e., the deceased family members who supposedly imposed and agreed upon the restriction, including, allegedly, Platt.
The team representing Michaan was led by Partner William (Bill) Charron, co-chair of the Art Law Group, with assistance from Partner Matthew Barkan (Litigation) and Associate Haley Sylvester (Trusts and Estates).
Bill credits the ruling as an "important vindication of the rights of good faith owners of art against dubious claims that are incapable of being reasonably proved or disproved. Our client did nothing wrong, and divesting him of these paintings under these claims would have been highly unfair."
Read the full opinion using the link below.
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