This case arises from the civil forfeiture of ancient Cypriot and Chinese coins under the Cultural Property Implementation Act (“CPIA”), 19 U.S.C. §§ 2601-2613. The coins are of types that appear on “designated lists” subject to import restrictions. Congress limited the reach of such import restrictions to archaeological objects “first discovered within” and “subject to export control by” a specific State Party to the 1970 UNESCO Convention, and further placed the burden of proof on the Government to establish that such designated material was listed in accordance with these criteria. 19 U.S.C. §§ 2601, 2604, 2610. Congress also ensured such import restrictions are entirely prospective. They only apply to designated archaeological material illicitly exported from the State Party after the effective date of the implementing regulations. Id. § 2606. The questions presented are: ...  Read full document here: 18-__PetitionForAWritOfCertiorari.pdf

On Petition for Writ of Certiorari to the United States Court of Appeals for the Fourth Circuit.

This case arises from the civil forfeiture of ancient Cypriot and Chinese coins under the Cultural Property Implementation Act (“CPIA”), 19 U.S.C. §§ 2601-2613. The coins are of types that appear on “designated lists” subject to import restrictions. Congress limited the reach of such import restrictions to archaeological objects “first discovered within” and “subject to export control by” a specific State Party to the 1970 UNESCO Convention, and further placed the burden of proof on the Government to establish that such designated material was listed in accordance with these criteria.   Read the full details here:  Proof of Petition and Appendix for Filing.pdf