Columbus-America Discovery Group v. Atlantic Mutual Insurance Co.

Brief Fact Summary.

Atlantic Mutual Insurance Company (Atlantic) appealed the judgment of the district court that denied their claims to gold after Atlantic lost documentation regarding ownership of the treasure.

Synopsis of Rule of Law.

A party is not considered to have abandoned property if documentation regarding ownership is no longer available.

Facts.

Columbus-America Discovery Group (Columbus) recovered gold from a shipwreck and moved to declare itself the owner of the gold in district court. Atlantic Mutual Insurance Company (Atlantic) sought to quash Columbus’ claim to the gold because they had already underwritten the gold. However, Atlantic lost their documentation regarding the gold. The district court granted judgment in favor of Columbus.

Issue.

Whether a party is considered to have abandoned a property if documentation regarding ownership is no longer available?

Held.

No. There is no evidence that Atlantic Mutual intentionally destroyed the property. The judgment of the district court is reversed.

Concurrence.

(Widener, J.) The court should not make a decision based on which factual inferences they want to choose. The court should stand behind factual inferences that are backed by evidence. The facts in this case confirm the judgment made by the district court.

Discussion.

The finders-keepers doctrine requires an affirmative step, such as intentionally destroying the property, to prove that abandonment occurred.