Institutional and private collectors have for many years played a major role in the continuing effort to collect and preserve valuable historical documents. A sizable number of these documents, estimated at 20-25%, are of public origin. The decision of the North Carolina Supreme Court in State v. West may well have a significant, if not inhibiting, effect upon the activities of these collectors. In West, the State of North Carolina successfully sued to recover two bills of indictment issued over two centuries ago from the possession of an individual collector. This note will review the court's decision in West and attempt to assess its impact.
Samuel R. Clawson, Property - Public Documents in the Hands of Private Collectors, 1 Campbell L. Rev. 179 (1979).