United States v. An Antique Platter of Gold

WINTER, Chief Judge:

Michael H. Steinhardt appeals from Judge Jones’s ordering of the forfeiture of a “Phiale,” an antique gold platter. The district court held that false statements on the customs entry forms and the Phiale’s status as stolen property under Italian law *133rendered its importation illegal. As such, the Phiale was subject to forfeiture.

Steinhardt contends that: (i) the false statements on the customs forms were not material under 18 U.S.C. § 542, (ii) stolen property under the National Stolen Property Act (“NSPA”) does not encompass property presumed to belong to the state under…