The D.C. Circuit Court of Appeals issued a decision January 23, 2026, in *David L. De Csepel v. Republic of Hungary*, marking the fourth time the appeals court has considered a family's decades-long legal battle to recover artwork seized during the Holocaust. The consolidated appeals, numbered 24-7045 and 24-7148, stem from a lawsuit originally filed in 2010 in the U.S. District Court for the District of Columbia.
Circuit Judge Cornelia Pillard wrote the opinion for the three-judge panel, which also included Circuit Judge Justin Pan and Senior Circuit Judge Judith Rogers. The case was argued September 8, 2025, with Alycia Regan Benenati representing the De Csepel family appellants, alongside attorneys Sheron Korpus and David E. Mills. The Republic of Hungary was represented by Aaron M. Brian, with Thaddeus J. Stauber and Zachary C. Osinski.
The legal dispute centers on artwork that Hungarian government authorities and Nazi collaborators seized from the De Csepel family during and following World War II. Judge Pillard's opinion notes the historical context of the case: the campaign of annihilation unleashed on Hungary's Jewish population following Nazi Germany's occupation of Hungary in 1944, just months before the war's end in Europe.
According to the court's opinion, more than two-thirds of Hungary's prewar Jewish population was murdered within less than a year, most at Auschwitz concentration camp. Winston Churchill described these events as "one of the greatest and most horrible crimes ever committed." During this period, Jewish property was systematically seized by Hungarian and German authorities and redistributed across Europe.
The case represents one of numerous post-war restitution efforts by Holocaust survivors and their descendants seeking to recover artwork and other property stolen during the Nazi era. Such cases often involve complex questions of international law, sovereign immunity, and statutes of limitations spanning decades.
The fact that this marks the fourth time the D.C. Circuit has considered this particular dispute indicates the complex and protracted nature of Holocaust restitution litigation. Many such cases involve multiple appeals as courts grapple with novel legal questions regarding foreign sovereign immunity, the discovery rule for statutes of limitations, and the application of various international agreements governing art restitution.
The D.C. Circuit has jurisdiction over this case because it involves claims against a foreign government, with the District of Columbia federal courts frequently handling such international disputes. The original lawsuit was filed as case number 1:10-cv-01261, indicating it has been pending for more than 15 years.
Holocaust-era art restitution cases have become increasingly prominent in recent decades as survivors and their families have pursued legal remedies to recover stolen cultural property. These cases often involve valuable artworks that have ended up in museums, private collections, or government holdings around the world.
The legal framework for such cases includes various statutes and international agreements designed to facilitate the return of Nazi-looted art. However, defendants often raise defenses based on sovereign immunity, statutes of limitations, and procedural barriers that can make recovery challenging for claimants.
The Republic of Hungary, as a sovereign nation, likely raised arguments concerning the Foreign Sovereign Immunities Act, which generally protects foreign governments from lawsuits in U.S. courts unless specific exceptions apply. One such exception involves commercial activity, while another covers cases involving property taken in violation of international law.
The case also raises questions about the application of various statutes of limitations. Given that the alleged seizure occurred more than 80 years ago, the timing of when claims accrue and when the statute of limitations begins to run becomes crucial. Courts have grappled with whether the discovery rule applies, meaning the statute begins when claimants knew or should have known about their claims.
The De Csepel family's persistence in pursuing this case through multiple appeals demonstrates the ongoing importance families place on recovering cultural property stolen during the Holocaust. For many survivors and their descendants, such property represents not just financial value but also family heritage and memory of lives destroyed during the Nazi era.
The decision comes at a time when various European countries and institutions continue to grapple with questions of Nazi-looted art in their collections. Museums, auction houses, and private collectors increasingly conduct provenance research to identify potentially stolen works and facilitate restitution to rightful owners or their heirs.
While the full text of the court's decision was not immediately available, the case will likely have implications for other Holocaust restitution litigation pending in federal courts. The D.C. Circuit's repeated consideration of this case suggests the complex legal and factual issues involved in proving ownership and establishing liability for wartime seizures of Jewish property.
The outcome of this long-running litigation will be closely watched by attorneys representing other Holocaust survivors and their families pursuing similar claims against foreign governments and institutions that may hold Nazi-looted art and cultural property.