On remand from the US Supreme Court, the Ninth Circuit applies California’s governmental interest approach to conflicts of law questions.  It finds a true conflict between Spanish law which allows the possessor of stolen art to acquire stronger title to the art than its predecessor in interest had by reason of the passage of the prescriptive period and California law under which the possessor of stolen art does not acquire such a superior interest despite the passage of time.  It concludes that Spain’s governmental interest in stability of title would be more impaired than California’s interest in justice for art owners in this case since all the relevant acts occurred in Spain, not California.