L. Eden Burgess

703.965.5380 direct

Eden’s practice focuses on art, cultural heritage, museum and intellectual property law. She has represented foreign states, museums, auction houses, major collectors, nonprofits, and other entities in a wide variety of matters. She has litigated and settled complex claims involving Nazi seizures, wartime looting, forced sales, and thefts. Eden assists clients with the maintenance and management of their collections and provides advice on art and antiquity transactions, such as auctions, purchases, and sales. Eden also works with clients to navigate the National Historic Preservation Act’s Section 106 process, supports historic preservation efforts on the state and federal levels, and provides advice and representation in Indian tribe-related disputes. In addition, Eden writes and speaks about a broad range of art, cultural heritage, and museum issues, including museum governance, immunity from seizure, and Nazi-looted art. Her intellectual property experience includes trial and appellate litigation in copyright, trademark, and patent. Eden has also been active in alternative dispute resolution in many types of matters.

Eden obtained her Bachelor’s Degree with Distinction from the University of Virginia, where she was an Echols Scholar, and her Juris Doctor with honors from George Washington University Law School. She is admitted to practice in Virginia, Maryland, and the District of Columbia.



  • Represent consulting party in Section 106 process on advocacy efforts to preserve historic bridges impacted by transportation development.
  • Advise tribal government on obtaining compensation for destruction of a cultural and religious site.
  • Represent tribal government in litigation related to state recognition process.
  • Represent city government’s board in litigation over permitting of a new development in an historic district.
  • Advise and provide government affairs counsel to cultural resource management firms on government contracting issues, including 8(a) certification and federal agency disputes.
  • Assist non-profit clients with start-up, management, and governance.
  • Advise foreign government on efforts to protect cultural heritage sites at risk of looting.
  • Coordinate Preservation50, the national celebration of the 50th anniversary of the National Historic Preservation Act.
  • Provide government affairs counsel to the American Cultural Resources Association and the Society for Historical Archaeology.


  • Vineberg v. Bissonnette, 529 F. Supp. 2d 300 (D.R.I. 2007), aff’d, 548 F.3d 50 (1st Cir. 2008). Assisted estate in recovering Franz Xaver Winterhalter’s painting Madchen aus den Sabiner Bergen from a private collector. The case is a landmark ruling in Holocaust-era art restitution law, being the first in the United States to find that a forced sale is a theft and therefore title does not pass to the buyer.
  • State of Baden-Württemburg v. Shene, 04-cv-10067-TPG, 2009 WL 762697 (S.D.N.Y. March 23, 2009). Represented German state and museum in its successful recovery of a 16th century volume of prints and drawings from a St. Louis book dealer. The decision – a rare grant of summary judgment in favor of a claimant – highlights the rule that military engaged in overseas combat should be safeguarding and not stealing cultural objects they encounter.
  • Malewicz v. City of Amsterdam, 362 F. Supp. 2d 298 (D.D.C. 2005), 2006 U.S. App. LEXIS 615 (D.C. Cir. 2006), and 517 F. Supp. 2d 322 (D.D.C. 2007). Served as local counsel, helping pursue recovery of fourteen works of Kazimir Malewicz on loan from the Stedelijk Museum to museums in the United States. The heirs and the City eventually settled the case.
  • Doss, Inc. v. Christie’s Inc., 08-cv-10577-LAP, 2009 WL 3053713 (S.D.N.Y. Sept. 23, 2009). Defended against negligence and breach of contract claims brought by a collector related to a purchase of a painting, and successfully obtained dismissal due to the expiration of applicable statutes of limitations.
  • Marchig v. Christie’s Inc., 762 F. Supp. 2d 667 (S.D.N.Y. 2011), aff’d, 2011 WL 2685608 (2d Cir. July 12, 2011). Defended against breach of fiduciary duty, breach of warranty, negligence, and replevin and conversion claims brought by a consignor, arising from 1998 sale of a drawing alleged by some experts to be the work of Leonardo da Vinci and worth over $100M. The firm successfully obtained dismissal of the case due to expiration of the statutes of limitations and unreasonable delay.
  • Bakalar v. Vavra, 619 F.3d 136 (2d Cir. 2010). On behalf of a group of non-profit organizations as amici, submitted a brief seeking to reverse the lower court’s ruling based upon its incorrect interpretation and application of Swiss law. The Second Circuit vacated the district court judgment on other grounds and remanded the case.



  • National Trust for Historic Preservation, PastForward, “Kick Off Preservation50,” Washington, DC, 2015.
  • American Association for State and Local History‘s Annual Meeting, “Preservation50: Celebrating the 50th Anniversary of the National Historic Preservation Act,” Louisville, KY, 2015 (scheduled)
  • American Architectural Foundation’s Thought Leadership Forum, “Storytelling, Design and Cultural Heritage in the 21st Century,” Washington, DC, 2015.
  • Journey Through Hallowed Ground‘s 10th Annual Conference, “LandScope Chesapeake: Combining Mapping with Storytelling,” Waterford, VA, 2015.
  • National Historic Preservation Advocacy Week, “Planning for Preservation50,” Washington, DC, 2015.
  • National Trust for Historic Preservation’s National Preservation Law Conference,” Legal Framework for Protecting Traditional Cultural Properties,” Washington, DC, 2015.
  • American University International Law Review’s Annual Symposium, Preserving Art and Cultural Heritage Through International Law, “The Looting Problems and Mechanisms for its Prevention,” Washington, DC, 2015.
  • “Cultural Heritage Protection and National Security,” Vermont Law School’s Latin American Law Student Association, South Royalton, VT, 2014.
  • Environmental Resources Management’s Perspectives Discussion Series, “Managing Cultural Heritage Risks for Major Capital Projects,” Washington, DC, 2014.
  • American Cultural Resources Association’s 20th Annual Conference, “Government Affairs Update,” St. Pete’s Beach, FL, 2014.
  • “The Real Monuments Men: Holocaust Restitution Yesterday and Today,” Washington DC Jewish Community Center, Washington, DC, 2014.
  • “Culture, Interrupted: Art Theft in the Third Reich,” Georgia State University School of Law, Atlanta, GA, 2014.
  • “Art from Abroad: Thefts and Loans from Foreign Countries,” DC Bar, co-presented by Cultural Heritage Partners and Berliner, Corcoran & Rowe, Washington, DC, 2014.



  • Author, “What’s a Museum to Do? The Global Trade in Illegal Antiquities,” in Cultural Relevance and Application of Heritage in the Modern World (scheduled for publication 2017)
  • Co-Author, “The National Historic Preservation Act and 36 CFR 800,” in The National Historic Preservation Act: Past, Present, and Future (2016)
  • Contributing Editor, Yearbook of Cultural Property Law
  • “Museum Governance Developments: Trustees Taking Greater Responsibility,” Yearbook of Cultural Property Law (2007)
  • Co-Author, “Art Market” Chapter in Yearbook of Cultural Property Law (2009 and 2010)
  • Contributor/Assistant, “Art Market” Chapter in Yearbook of Cultural Property Law (2006, 2007 and 2008)


  • Adjunct Professor, George Washington University Law School’s Advanced Field Placement Program, 2013 to present.
  • Professorial Lecturer in Law, George Washington University Law School, “Art, Cultural Heritage, and the Law,” 2012-2013.



Board Member, Foundation of the American Institute for Conservation of Historic and Artistic Works (FAIC)