## Facts

- Emily Baron, a reclusive Louisiana resident, died intestate in 1957.
- After her death, a search of her room found substantial assets, but no one inspected her mattress.
- The mattress was later sold to John and Mrs. Cleland, who sent it to a mattress works for renovation.
- During processing of the mattress contents, workers discovered $22,200 in U.S. gold certificates concealed inside.
- Federal law then barred private possession of gold certificates; the United States asserted the right to the certificates but agreed to pay their face value into court for distribution to the lawful private claimant(s).
- Rival claimants included Emily Baron’s heirs and the Clelands (as purchasers of the mattress).

## Issues

1. Under Louisiana law, did the value of the concealed gold certificates belong to Emily Baron’s estate (and thus her heirs) or to the Clelands as purchasers of the mattress in which the certificates were found?
2. Does Louisiana law recognize a “treasure trove” or finder-based doctrine that would vest ownership in the finder or subsequent possessor of the container?
3. Were the certificates properly treated as part of the decedent’s property at death despite being undiscovered until after the mattress was sold?

## Decision

- The district court awarded the face value fund to Emily Baron’s heirs.
- The court rejected the Clelands’ claim based on “treasure trove” or finder’s rights.
- The United States was entitled to the certificates themselves under federal currency restrictions, but had to pay their face value into the court for the private party legally entitled to that value.
- The Fifth Circuit affirmed per curiam.

## Legal Principles

- In Louisiana, ownership of concealed property is determined by the Civil Code’s civilian property rules and succession principles, not by common-law finder doctrines.
- The Louisiana concept of “treasure,” to the extent recognized, does not create a broad rule awarding ownership to the finder of hidden valuables.
- Property intentionally concealed and retained under an owner’s dominion remains the owner’s property and passes to heirs at death, even if discovered only later.
- A post-death sale of a container (here, a mattress) without knowledge of concealed valuables does not transfer title to the concealed valuables as against the decedent’s estate.
- Federal prohibition on private possession of certain instruments can be handled by awarding the instruments to the United States while distributing the monetary equivalent to the state-law owner.

## Conclusion

The court held that the gold certificates were part of Emily Baron’s concealed property at death and thus belonged to her heirs under Louisiana succession law; the United States took the certificates under federal law but paid their face value to the heirs, and the judgment was affirmed on appeal.


United States v. Peter, 178 F. Supp. 854 (E.D. La. 1959)