The grandson of a woman whose valuable painting was confiscated by the Nazis can sue an arm of the government of Spain to recover it, the Ninth Circuit en banc held today in Cassirer v. Spain. There is exception to the Foreign Sovereign Immunities Act for property taken in violation of international law when the instrumentality of the state involved is engaged in commercial activity in the U.S. The court held that the exception does not require that the violation have been committed by the same government that now has the property.