O'Keeffe v. Snyder
Supreme Court of New Jersey
416 A.2d 862 (N.J. 1980)
Georgia O'Keeffe (plaintiff) noticed three of her paintings missing from a gallery in 1946 but did not report the theft until 1972, and after learning in 1975 the paintings were with a New York gallery, she sued purchaser Snyder (defendant) in replevin in 1976; Snyder argued he was a good-faith purchaser with adverse-possession title and that the six-year statute of limitations had already run since the theft. The trial court applied the statute from the theft date and ruled for Snyder, the appellate court reversed on adverse-possession grounds instead, and Snyder appealed to the state supreme court.
Whether the discovery rule tolls the statute of limitations for recovering stolen personal property if the true owner acted with due diligence to pursue the property.