Léone Meyer filed a complaint in federal court seeking the return of a Camille Pissarro painting titled "La Bergère" from the University of Oklahoma. The painting was seized from Léone Meyer's family by the Nazis in 1941 in France and ended up in the university's art collection in 2000. Léone Meyer and her family spent decades searching for the missing painting. In 2012, they discovered it was at the University of Oklahoma's art museum. The university sought to have the case dismissed, arguing lack of jurisdiction and statute of limitations among other defenses.

1. L. Meyer v. Bd. of Regents of
the U. of Oklahoma
Historical Background

2. SHEPHERDESS BRINGING IN SHEEP
• Shepherdess Bringing In
Sheep (“Bergère rentrant
des moutons”) (1886)
• [herein referred to as “La
Bergère”]
• An Oil on canvas, by Camille
Pissarro, France, 1830 – 1903
• Aaron M. and Clara
Weitzenhoffer Bequest, 2000
• [Source: Fred Jones Museum]

3. THE WEITZENHOFFER BEQUEST
(2000)
• 33 impressionist paintings
• Important masterpieces such as Monet,
Corot, Renoir, Bonnard, Gauguin
• Some examples:
 Sara in a Dark Bonnet Tied under her
Chin, c. 1901, By Mary Cassatt (1844-
1926) Pastel on paper, 22 x 17 1/2 in.
 Personnages sur la plage, Trouville
(People on the Beach, Trouville), 1866,
By Eugène Boudin (1824-1898)
Watercolor and graphite on paper, 5 1/2
x 10 in.
 Coast Scene, 1893, By Paul Signac 1863-
1935) Oil on canvas, 18 1/2 x 22 in.

4. LÉONE MEYER
• Following the murder of her entire
family at Auschwitz during World
War II, Léone Meyer was adopted
by Raoul Meyer (1892-1970) and
Yvonne Bader (1897-1971) in
December 1946.
• Upon Yvonne Bader’s death in
1971, Léone Meyer became the
sole heir to both Raoul Meyer and
Yvonne Bader family’s assets,
including their art collection,
which included the Pissarro
painting.

5. Einsatzstab Reichsleiter Rosenberg (ERR)
German soldiers posing with painting taken from
the National Museum of Naples Picture Gallery
Source: Wikipedia
The ERR was one of several
Nazi agencies engaged in the
plunder of cultural property in
Nazi-occupied countries during
World War II.
The Meyer family appeared on
special listings drawn up by the
ERR of Jewish collections
targeted for seizure in German-
occupied France.

6. JEU DE PAUME
• The ERR had a depot at the Louvre Museum and one at a
museum known as “The Jeu de Paume.” The Jeu de Paume
served as the main processing, sorting, and distribution
station for art and cultural object confiscated by the ERR all
over France.
• Artwork that was categorized as “undesirable” was set aside
to either be sold to dealers and collectors to obtain foreign
exchange, or to be exchanged for more acceptable works of
art, such as European Old Masters, that could be repatriated
to the Third Reich and incorporated into Nazi collections.

7. SEIZURE OF La Bergère
• In March 1940, the Meyer family placed their art collection
in a bank safe at Crédit Commercial de France, located in
Mont-de-Marsan, France, for safe keeping.
• On or around February 22, 1941, Nazi forces obtained
access to the bank and seized a collection of artworks
registered under the name of Mrs. Raoul Meyer.
• The seized Meyer collection was sent to Jeu de Paume. La
Bergère was set aside for possible exchange. The painting
ended up in Switzerland between 1944 and 1946.

8. REGISTRATION OF STOLEN
ARTWORK
• Following the liberation of Paris in August 1944 a special
commission, “Commission de Récupération Artistique” (CRA) was
created to document, research the thefts of and restitute cultural
assets. Unsatisfied claims were transferred to “Office des biens et
intérêts privés” (OBIP).
• Raoul Meyer sent an inventory of artwork taken by Nazis to the CRA.
Some artwork was recovered, but not La Bergère. Raoul Meyer sent
an inventory of unsatisfied claims to the OBIP.
• Raoul Meyer’s artwork that was still missing was incorporated into a
report titled “Répertoire des Biens Spoliés en France Durant la
Guerre de 1939-1945.” This report was widely disseminated to
embassies, museums and art galleries throughout Europe and the
Americas.

9. Tripartite Agreement
• The United States, France, and
Great Britain signed the
“Tripartite Agreement” on July
8, 1946. As past of its obligation
under the Agreement, the U.S.
State Department distributed
registries of art losses, such as
the “Répertoire des Biens Spoliés
en France Durant la Guerre de
1939-1945” to museums,
galleries, colleges and
universities.
• La Bergère, Raoul Meyer’s
Pissarro painting was listed in
one of the distributed registries.
“Répertoire des Biens Spoliés en France
Durant la Guerre de 1939-1945” was one of
the registries distributed in by the U.S. State
Department.

10. THE SWISS LITIGATION
• When Raoul Meyer brought a civil case in a Swiss court in 1953,
he had to prove that Christoph Bernoulli acquired the Pissarro
painting with knowledge it was stolen (bad faith). The Swiss
Court held that Raoul Meyer failed to prove Bernoulli acquired
the Pissarro painting in bad faith.
• In the US, a theft cannot convey good title. The original owner
retains title to the stolen object. It does not matter if a subsequent
purchaser did not know the object was previously stolen.

11. THE CRIVELLI REPORT
• On December 16, 1996, the Federal Council of Switzerland
created the Bergier Commission, also known as the
Independent Commission of Experts (ICE). The ICE’s
mandate was to investigate the volume and fate of assets
moved to Switzerland before, during, and immediately after
World War II.
• On March 3, 1998, Pablo Crivelli, an ICE member,
submitted a report titled “Internal Report-The Issue of
Looted Assets (Works of Art) in the Swiss Federal Archives,
1943-1950.”

12. CRIVELLI’S CONCLUSIONS
• The Swiss Government’s policies enabled the permissive
importation of looted artwork into Switzerland.
• The Swiss Federal agencies involved in the investigational and
restitution of artwork exercised censorship over information
about looted artwork that illicitly entered Switzerland.
• The private sector failed to properly cooperate with
governmental investigations, which further impeded the
resolution of looted artwork claims.
• Citing Meyer v. Bernoulli, the civil code rule in the Swiss legal
system was almost unassailable in the context of works of art
looted from Nazi-occupied territories and imported into
Switzerland.

13. PISSARRO PAINTING ENTERS U.S.
• In 1956, unbeknownst to Raoul
Meyer or his family, the Pissarro
painting entered the United
Stated through the David Findlay
Galleries, Inc. in New York from
E. J. van Wisselingh & Co., an
art dealer in Amsterdam,
Holland.
• In late 1956, Clara Weitzenhoffer
acquired the Pissarro painting
from David Findlay Galleries,
Inc.

14. UNIVERSITY OKLAHOMA
• After purchasing La Bergère
from Findlay, Clara
Weitzenhoffer brings it to
Oklahoma.
• In 2000, Clara
Weitzenhoffer’s estate
bequests 33 French
Impressionist painting,
including La Bergère to the
University of Oklahoma’s
Fred Jones Jr. Museum of
Art.

15. SEARCH FOR La Bergère
• From 1945 up until their deaths, Léone Meyer’s parents
made numerous attempts to research the whereabouts of all
the missing paintings from the Meyer family art collection.
• Léone Meyer was equally determined to recover the missing
paintings and performed an exceptional level of due
diligence in her search.

16. EXAMPLES OF LÉONE MEYER’S EFFORTS
• Léone Meyer retrieved documents from the French Government
and numerous listings of artwork owned by private collectors.
• Léone Meyer filed claims with a French special task force
(“Matteoli Commission”, then “CIVS”) and filed a claims letter
with the Art Loss Register in London, the worlds largest private
database of lost and stolen art, antiques, and collectibles.
• Léone Meyer met several times and exchanged letters with
Sandrine and Lionel Pissarro, heirs to the Pissarro Estate and art
dealers.
• Léone Meyer hired an art expert, trustee of the “Société des Amis
du Louvre” Foundation, to perform an exhaustive research on
the whereabouts of La Bergère. The research produced no lead.

17. DISCOVERY OF La Bergère
• On March 26, 2012, Léone Meyer’s family discovered a blog
entry on the Holocaust Art Restitution Project website that
indicated that La Bergère’s records at Jeu de Paume matched
the Pissarro painting on display at the University of
Oklahoma’s Fred Jones Jr. Museum of Art.
• On December 12, 2012, Léone Meyer, through her attorney,
demanded the return of the Pissarro painting from the
University of Oklahoma. David Boren responded on January
18, 2013 claiming the painting was in the custody of the
University of Oklahoma Foundation, not the University
Oklahoma.

18. COMPLAINT
• A complaint for the return of La Bergère was filed on May 9,
2013 in the Southern District of New York.
• On January 10, 2014, the complaint was amended.
• On February 7, 2014, the University of Oklahoma filed a motion
to dismiss, most notably on the following grounds:
- Lack of jurisdiction of the court
- State Immunity from suits
- Res judicata
- Statute of limitations
- Laches

19. TIMELINE OF EVENTS
1940
•Mar. – The Meyer family places their art collection in a bank safe at Crédit Commercial de France
•May – Nazis invade France
1941
•Feb. – Nazi forces seize La Bergère from Crédit Commercial de France and transport it to Jeu de Paume
1942
•Jul. – La Bergère is inventoried at Jeu de Paume and set aside for possible exchange
1944-46
•Sometime between 1944 and 1946, La Bergère ends up in Switzerland
1944
•Aug. – Paris is liberated from Nazi occupation
1945
•Apr. - Raoul Meyer registers La Bergère as looted artwork
1946
•Christoph Bernoulli acquires La Bergère and sells it to Audré Maus
1951
•Raoul Meyer discovers Maus is in possession of La Bergère in Switzerland
•Bernoulli regains custody and control over the Pissarro painting from Maus

20. TIMELINE OF EVENTS CONT.
1952
•Raoul Meyer files a lawsuit against Bernoulli in Switzerland
1953
•The Swiss Court holds Raoul Meyer failed to prove Bernoulli’s bad faith in acquiring La Bergère
1956
•La Bergère is exhibited at David Findlay Galleries, Inc. in New York
•Aaron and Clara Weitzenhoffer purchase La Bergère from David Findlay Galleries, Inc.
2000
•Clara Weitzenhoffer’s estate bequests La Bergère to University of Oklahoma’s Fred Jones Jr. Museum
of Art
2009
•Mar. – Dr. Annette Schlagenhauff researches La Bergère, discovers documents regarding Bernoulli,
and provides the documents to the Fred Jones Jr. Museum of Art
2012
•Mar. – Léone Meyer’s family discovers the location of La Bergère
•Dec. – Léone Meyer demands the return of La Bergère from the University of Oklahoma
2013
•Jan. – David Boren claims La Bergère is owned by the University of Oklahoma Foundation, not the University
•May – Léone Meyer files her complaint