## Facts

- The C.S.S. ALABAMA, a Confederate commerce raider operated during the Civil War, sank in 1864 after a naval engagement with the U.S.S. KEARSARGE off Cherbourg, France.
- In 1936, a British diver recovered the ALABAMA’s brass ship’s bell from the wreck and sold it in England; the bell later passed through multiple private hands.
- In 1979, Richard Steinmetz, a U.S. antiques dealer, acquired the bell in England through a barter transaction and brought it to New Jersey.
- Steinmetz later consigned the bell for auction in New York; after publicity, the U.S. Navy asserted the bell was U.S. property.
- The United States filed suit in the District of New Jersey to recover the bell; Steinmetz asserted ownership and raised defenses including abandonment, and sought equitable compensation (quantum meruit and unjust enrichment).
- The district court granted summary judgment to the United States, finding federal title based on (1) succession to Confederate public property and (2) capture; it rejected Steinmetz’s counterclaims.

## Issues

1. Whether the United States acquired title to the ALABAMA’s bell by succession to Confederate public property after the Civil War.
2. Whether the United States abandoned any property interest in the bell through long inaction, permitting a private purchaser to obtain good title.
3. Whether title could alternatively be established by right of capture under the law of war (and whether that issue needed to be decided).

## Decision

- The Third Circuit affirmed summary judgment for the United States.
- The court held the bell was U.S. property by right of succession to the public property of the Confederacy.
- The court rejected Steinmetz’s abandonment defense, concluding federal property cannot be abandoned without clear congressional authorization and that inaction did not divest title.
- The court declined to reach the capture theory because succession alone resolved ownership.
- Steinmetz’s counterclaims for declaratory relief and equitable compensation were rejected.

## Legal Principles

- Upon the Confederacy’s defeat, the United States succeeded to the Confederacy’s public property, including warships and their appurtenances.
- Federal property cannot be abandoned or disposed of absent clear congressional authorization; delay or nonassertion of control does not effect abandonment.
- A good-faith private purchaser cannot obtain superior title to federal property where the United States holds title by succession and has not lawfully transferred or abandoned it.
- Equitable restitution (e.g., quantum meruit or unjust enrichment) is unavailable where the government already owns the property and did not request or accept compensable services from the claimant.

## Conclusion

The Third Circuit held that the United States owned the C.S.S. ALABAMA’s bell through succession to Confederate public property and that no abandonment occurred without congressional authorization, requiring return of the bell and defeating the private purchaser’s ownership and equitable claims.


United States v. Steinmetz, 973 F.2d 212 (3d Cir. 1992)