Today, the Ninth Circuit held that actress Elizabeth Taylor needn’t part with a Vincent Van Gogh painting that she acquired at a Sotheby’s auction in 1963. The court held that ancestors of Margarete Mauthner, a Jewish collector who fled Nazi Germany in 1939, could not prevail on their claims against Ms. Taylor because the Holocaust Victims Redress Act didn’t create a private cause of action and because limitations expired no later than 1993 on their state law claims. Orkin v. Taylor, No. 05-55364 (9th Cir. May 18, 2007).