United States v. Eight (8) Rhodesian Stone Statues

449 F. Supp. 193, 1978 U.S. Dist. LEXIS 19370
CourtDistrict Court, C.D. California
DecidedFebruary 24, 1978
DocketCV 77-643-IH
StatusPublished
Cited by20 cases

This text of 449 F. Supp. 193 (United States v. Eight (8) Rhodesian Stone Statues) is published on Counsel Stack Legal Research, covering District Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Eight (8) Rhodesian Stone Statues, 449 F. Supp. 193, 1978 U.S. Dist. LEXIS 19370 (C.D. Cal. 1978).

Opinion

OPINION

IRVING HILL, District Judge.

In this case, the government seized 8 small stone statues imported from Rhodesia on account of alleged violations of certain customs laws (19 U.S.C. § 1592) and economic sanctions (22 U.S.C. § 287c). Thereafter, the government commenced the instant in rem action to secure a decree of forfeiture. 1 The owner of the statues contests the action as a claimant. A separate motion for summary judgment was filed by each party. The government’s motion argues on the merits that the government is entitled to a decree of forfeiture and full title to the statues. The claimant’s motion argues that the government has now lost its right to obtain title, regardless of the merits of the forfeiture action it might once have had, because of procedural defects and time delays. The claimant’s motion seeks a judgment ordering immediate return of the statues.

The Court grants the claimant’s motion and denies the government’s motion. The government is held to be barred from obtaining a decree of forfeiture on due process grounds — because of procedural deficiencies in connection with the seizure and because of substantial time delays between the seizure and the institution of the district court action. The grant of the claimant’s motion on due process grounds renders moot the government’s motion on the merits. So the Court makes no factual or legal determination as to whether the government could have obtained a decree of forfeiture if the said due process violations had not occurred.

I. FACTS

It is necessary to recite the facts of the case at considerable length. The claimant, *196 David W. Brokensha, is a professor of anthropology at the University of California at Santa Barbara. He apparently specializes in African culture. The professor bought the statues about August 5,1968, in Rhodesia while on an African trip. He bought them from the National Gallery of Rhodesia at Salisbury, paying $200 for the lot of eight. Photographs of the statues are in evidence; but there is in the record no detailed verbal description of them. The undersigned is himself a desultory collector of primitive folk art and sculpture, including items from Africa, and I will attempt to describe them. These statues are stone carvings, apparently of soapstone or some other soft stone, simple and quite primitive. The record indicates they were made by black native Rhodesians. The professor believes the statues to be modern, estimating that they were only 5 to 10 years old when he bought them. He believes that these statues are significantly different from pri- or native sculpture produced in the same area and that they evidence a kind of new movement in the native art of the region. Apparently other scholars agree with him because the statues have been exhibited by at least two important American museums since 1968, on loan from the professor.

There is no claim that these statues are Rhodesian national treasures or were illegally exported from Rhodesia. They were seized because they are Rhodesian in origin and because at the time of their importation (and apparently down to the present time), importation of Rhodesian goods was not permitted under American law. 2

Under U.N. auspices, various nations of the world have for some years imposed various economic sanctions on Rhodesia to protest Rhodesia’s treatment of its black majority. The United States took its first steps in that movement by Executive Order No. 11322 (found at 22 U.S.C. § 287c), issued on January 5, 1967, which does not apply to the instant case because it does not include art objects within its prohibition.

On July 29, 1968 (a week before these statues were purchased), Executive Order 11419 (found at 22 U.S.C. § 287c) was issued which greatly broadened the prior restrictions on importation of Rhodesian goods. E.O. 11419 became immediately effective and is phrased as a total prohibition on importation of any commodity or product originating in Rhodesia. Art objects are not exempted. The various cabinet secretaries charged with the enforcement of the prohibitions are each given authority in the Executive Order to “issue such regulations, licenses or other authorizations as he considers necessary to carry out the purposes of this Order . . ”. 3

The regulations issued pursuant to Executive Order 11419 authorize the Secretary of the Treasury to grant general import licenses involving certain specified Rhodesian commodities and transactions. In addition, the regulations allow for the issuance of specific import licenses on an ad hoc basis. 4

When the statues reached this country on November 22, 1968, at Los Angeles, the professor was on hand personally. He did not apply for any import license. He sought to have the statues enter as original works of art, duty-free, and they were so recognized. There is a printed claim form issued by the Bureau of Customs intended for use in claiming that an item is an original work of art. The form is entitled “Declaration for Free Entry of Works of Art, Artistic Antiquities, Original Paintings, Statuary, etc.” Professor Brokensha filled in one of these forms and stated on it that the place of origin of the statues was Mo *197 zambique. This erroneous statement, the government contends, constitutes a violation of 19 U.S.C. § 1592 and provides a separate basis for forfeiture of the statues, in addition to the apparent violation of the Executive Order 11419. The professor has offered a colorably persuasive explanation of the misstatement. 5

The evidence before the Court is clear and uncontradicted that for seven years after the importation of the statues, the professor made no attempt to hide their existence and no attempt to confuse anyone as to their country of origin. On the contrary, he has continually referred to the statues as Rhodesian works in his academic lectures and writings, and on loan from him, they were exhibited in at least two museums as Rhodesian works. Professor Brokensha retained ownership of the statues and the right to their possession from the time of importation to and including the date of seizure. In August of 1975, almost 7 years after the statues entered the country, they were seized while on exhibit at the American Museum of Natural History in New York City 6 by customs agents attached to the New York office of the Customs Service.

Apparently there had been some governmental inquiry about the importation of the statues because Professor Brokensha had employed a firm of Los Angeles attorneys specializing in customs law to represent him in connection with the statues even before their seizure.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Ford Motor Credit Co. v. New York City Police Department
394 F. Supp. 2d 600 (S.D. New York, 2005)
Conkey v. Reno
885 F. Supp. 1389 (D. Nevada, 1995)
Garcia-Rubio v. Immigration & Naturalization Service
703 F. Supp. 859 (S.D. California, 1989)
United States v. Tabor
608 F. Supp. 658 (Court of International Trade, 1985)
No. 83-1564
739 F.2d 354 (Eighth Circuit, 1984)
State v. Norton
646 P.2d 53 (Court of Appeals of Oregon, 1982)
United States v. $62,972 in United States Currency
539 F. Supp. 586 (D. Nevada, 1982)
Von Neumann v. United States
660 F.2d 1319 (Ninth Circuit, 1981)
United States v. One 1971 BMW 4-Door Sedan
652 F.2d 817 (Ninth Circuit, 1981)
No. 79-3310
652 F.2d 817 (Ninth Circuit, 1981)
Commonwealth v. One 1976 Cadillac DeVille Automobile
403 N.E.2d 935 (Massachusetts Supreme Judicial Court, 1980)

Cite This Page — Counsel Stack

Bluebook (online)
449 F. Supp. 193, 1978 U.S. Dist. LEXIS 19370, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-eight-8-rhodesian-stone-statues-cacd-1978.