Jewish representatives seeking the return of two Renaissance paintings taken from the collection of Dutch Jewish art dealer Jacques Goudstikker during the Nazi occupation have opened a new legal challenge against the Norton Simon Museum in Pasadena, reviving a dispute that had appeared largely settled after years of federal litigation.
The Jewish Federation of Greater Los Angeles and its board chair, Daniel Gryczman, filed the lawsuit in Los Angeles Superior Court seeking possession of Lucas Cranach the Elder’s “Adam and Eve,” two life-size oil-on-panel paintings dating to 1530. The action follows Marei von Saher’s assignment of her claimed rights in the works to the federation. Von Saher is the surviving heir of Goudstikker, a prominent Amsterdam art dealer whose collection was dispersed after the German invasion of the Netherlands in 1940.
The case arrives at a potentially consequential moment for Holocaust-era art restitution. California lawmakers in 2024 enacted Assembly Bill 2867, a measure intended to strengthen the ability of California residents and heirs to pursue art and other property lost through political persecution. The legislation directs courts in covered cases to apply California substantive law and limits defenses that could otherwise allow later possessors to retain stolen property because of the passage of time, adverse possession or similar doctrines.
Congress subsequently strengthened federal law as well. President Donald Trump signed the Holocaust Expropriated Art Recovery Act of 2025 into law on April 13, 2026. The measure permanently extended federal authority for Holocaust-era recovery claims and restricted certain defenses based on delay or other non-merits grounds. Together, the state and federal changes are giving claimants new reasons to revisit disputes that previously ended without the restitution they sought.
The Norton Simon dispute has an unusually long and complicated history. Goudstikker acquired the Cranach paintings at a Berlin auction in 1931. After Nazi Germany invaded the Netherlands, Goudstikker fled with his family and died while escaping Europe. Hermann Göring, one of the most powerful figures in the Nazi regime, subsequently obtained major portions of the dealer’s collection through transactions that Goudstikker’s heirs have characterized as forced and illegitimate.
After World War II, Allied forces recovered the Cranach panels and returned them to Dutch authorities. The paintings later became the subject of a separate ownership claim involving the Stroganoff family, whose collection had been seized by the Soviet government. The Netherlands transferred the paintings in the 1960s to George Stroganoff-Scherbatoff, who later sold them to the Pasadena institution that became associated with industrialist and collector Norton Simon.

That postwar chain of ownership is central to the museum’s defense. The Norton Simon Art Foundation has long maintained that it acquired the paintings through a lawful transaction and holds valid title. Earlier federal litigation brought by von Saher ultimately ended in the museum’s favor. In 2018, the U.S. Court of Appeals for the Ninth Circuit affirmed a judgment supporting the museum’s ownership, and the U.S. Supreme Court declined to take up the dispute the following year.
The museum has said in response to the latest litigation that previous courts confirmed its proper title and that it intends to continue making the Cranach works accessible to the public. Its longstanding account emphasizes the paintings’ ownership before Goudstikker acquired them, the Dutch government’s postwar handling of the works and the later transfer to the Norton Simon collection.
The plaintiffs are relying on a different legal framework from the one governing the earlier case. California’s AB 2867 expressly contemplates some renewed actions involving property lost through political persecution, including certain cases that previously failed on procedural grounds or legal defenses the statute now restricts. That makes the new lawsuit not simply another attempt to relitigate the old record, but a test of how far lawmakers succeeded in reopening pathways for restitution.
The Jewish Federation has also connected the lawsuit to the needs of Holocaust survivors in Southern California. Federation officials have said that if the organization ultimately recovers the paintings, most net proceeds associated with them would be directed toward assistance for Holocaust survivors in the greater Los Angeles area. The organization has framed the case as both an effort to address a historic property loss and a way to support surviving members of the generation affected by Nazi persecution.
The Cranach lawsuit was filed alongside another California-based restitution action involving works created at Auschwitz. The daughters of the late Dinah Gottliebova Babbitt, a Holocaust survivor who later lived and worked in California, sued the Auschwitz-Birkenau Memorial and Museum in Poland seeking watercolors that Babbitt was forced to make while imprisoned at the camp. The museum in Poland argues that the works are essential historical documentation and should remain in its collection.

The two disputes involve different ownership histories and legal issues, but their near-simultaneous filing underscores the broader significance of the recent statutory changes. For decades, Nazi-era restitution cases have frequently turned not only on provenance but also on statutes of limitation, choice-of-law rules, sovereign immunity questions and other procedural doctrines. The new laws were intended to make it harder for those issues alone to prevent courts from considering the underlying claims.
For American museums, the renewed litigation adds pressure to examine the ownership history of works that moved through Europe during and immediately after the Nazi period. Provenance research has become an increasingly important responsibility for museums, auction houses and collectors, particularly when gaps in ownership coincide with persecution, forced sales or wartime confiscation.
The Norton Simon case may therefore resonate well beyond Pasadena. A ruling addressing how California’s new restitution statute applies to a claim that has already undergone extensive litigation could help define the practical reach of the law. It could also shape negotiations in other disputes, as museums and heirs reassess whether older judgments or transactions remain as decisive as they once appeared.
For now, “Adam and Eve” remains at the Norton Simon Museum, where the paintings have been displayed for decades. The new lawsuit does not resolve the competing historical and legal claims to the works. It does, however, ensure that one of the most persistent U.S. disputes over art displaced during the Nazi era is again before a California court, this time under laws specifically rewritten to give Holocaust-era restitution claims a broader opportunity to be heard.




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