The case of the day is Hulton v. Bayerische Staatsgemaldesammlungen (S.D.N.Y. 2018). Michael and Penny Hulton were the heirs of Alfred Flechtheim, a German Jew who was a prominent art collector before the war. Among other paintings, he had works by Beckmann, Gris, and Klee. When the Nazis came to power, Flechtheim fled to Paris, and as a result of Nazi persecution, he was “forced to place his property at the disposal” of Alfred Schulte, a “Nazi tax advisor.” Another Nazi, Alex Vömel, took over Flechtheim’s gallery. It is unclear whether Vömel, Schulte, or someone else disposed of the Paintings; Plaintiffs merely allege that the Paintings were sold in Germany after Flechtheim’s flight. Flechtheim apparently never returned to Germany, dying in London in 1937.

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