On June 27, 2011, the Supreme Court denied the petition of Marei von Saher, daughter-in-law and only surviving heir of Dutch art dealer Jacques Goudstikker, to review the Ninth Circuit’s decision in Von Saher v. Norton Simon Museum of Art at Pasadena, 578 F.3d 1016 (9th Cir. 2003). That well-publicized case involved the