## Facts

- The United States, through the National Institutes of Health (NIH), owned and operated research laboratories in Bethesda, Maryland.
- Dr. Prince Kumar Arora, an NIH research scientist, supervised junior researchers, including a postdoctoral fellow, Dr. Yoshitatsu Sei.
- Sei and colleagues developed a distinctive, stable research cell line known as “Alpha 1-4,” which was stored and used for ongoing research and intended for broader scientific sharing.
- Arora’s professional relationship with Sei deteriorated.
- Alpha 1-4 cells stored at NIH began dying unexpectedly; Sei reported suspected tampering.
- After investigation and trial evidence, the court found Arora intentionally interfered with and destroyed Alpha 1-4 cell cultures by tampering with stored flasks.
- The United States proved out-of-pocket losses consisting of destroyed materials ($176.68) and laboratory-assistant time needed to recreate cells (13 hours costing $273.52).

## Issues

1. Whether Arora’s intentional interference with the Alpha 1-4 cells constituted conversion and/or trespass to chattels under Maryland law, and whether the United States could sue as owner of the property.
2. What compensatory damages were recoverable for the destruction and interference with the Alpha 1-4 cells and related materials.
3. Whether Arora’s conduct satisfied Maryland’s standard for punitive damages in intentional tort cases, and what amount was appropriate given minimal compensatory damages.

## Decision

- The court found Arora liable for conversion and trespass to chattels based on intentional tampering, destruction, and wrongful dominion over the Alpha 1-4 cells.
- The court awarded $450.20 in compensatory damages, limited to the proven cost of materials and reasonable labor to recreate the cells.
- The court denied additional compensatory damages for delay in the research project because the asserted delay-related loss was not sufficiently quantified.
- The court awarded $5,000 in punitive damages, finding the conduct intentional and malicious and treating the impact on the research project as relevant to punishment and deterrence.

## Legal Principles

- A biological research cell line and associated laboratory materials may constitute personal property subject to conversion and trespass to chattels.
- Conversion and trespass to chattels permit recovery of proven economic loss measured by the value of damaged property and reasonable replacement or restoration costs, including labor necessary to recreate destroyed materials.
- Damages claimed for research delay or similar intangible harms require a legally supportable and reasonably certain monetary measure; otherwise, recovery is denied.
- Under Maryland law, punitive damages for intentional torts require actual malice (intent to injure or other malicious motivation) and may be awarded even when compensatory damages are small if the misconduct is egregious.

## Conclusion

The court held that an NIH scientist intentionally destroyed and wrongfully interfered with a unique research cell line, supporting liability for conversion and trespass to chattels; it limited compensatory damages to proven replacement costs but imposed punitive damages to address malicious sabotage of federally owned research property.


United States v. Arora, 860 F. Supp. 1091 (D. Md. 1994)