French Supreme Court Denies Bauer Heirs Restitution of Pissarro's 'La Tricoteuse'

On 23 September 2026, the Cour de cassation rejected the final appeal by heirs of collector Simon Bauer to recover a Camille Pissarro painting they claimed was looted in 1944, ruling that the 21 April 1945 ordinance annulling the sale of Bauer's collection does not shift the burden of proof onto current holders. The heirs had identified a Pissarro titled 'Une fileuse, intérieur breton' consigned to auction in 2017 as their lost 'La tricoteuse', obtained its sequestration in 2019, and sued the holders for revendication. The court upheld the appellate finding that source comparisons revealed contradictions and gaps, and that the heirs failed to establish the legal and material identity between the two works. The ruling, issued ten months after the court's Armand Dorville decision on spoliation sales, stresses that while proof may be adduced by any means, including circumstantial evidence, claimants must still convince judges that the work sought is the one whose sale was annulled. The decision contrasts with the court's 1 July 2020 approval of the restitution of Pissarro's 'La Cueillette des pois' to the same heirs.