Pooja Sethi


In United States of America v. Schultz, the United States Court of Appeals for the Second Circuit examined whether conspiring to take antiquities that were owned by the Government of Egypt under Egyptian Law 117 violates the National Stolen Property Act [hereinafter NSPA]. In analyzing this issue, the Second Circuit analyzed the law of Egypt- Law 117, the meaning of the term stolen, and the Fifth Circuit's definition of the NSP A. The Second Circuit found in this case that the Egyptian antiquities were stolen within the meaning of 18 U.S.C. § 2315, NSPA. To support this finding, the Second Circuit stated that property stolen from a foreign government that has ownership of the property under valid patrimony law is considered stolen under the NSPA. The Second Circuit has not properly reviewed the NSPA prior, so in analyzing this case, they applied NSPA law from other circuits.





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