Stolen Art from the Holocaust to the PresentAmerican troops find stolen artworks stored in a church in Germany, 1945. National Archives and Records Administration #111-SC-204899

The Steps of Writing an Essay

The Garfinkel Essay Scholarship is all about creating an essay that answers one of the questions below, using evidence and good writing to support your argument. There are many different ways to write a good essay, from drawing on your personal experiences to researching a specific examples, but they are all tied in together by an emphasis on using evidence to support everything you say.

There are no shortcuts to this, good research, good writing and support from your professors and fellow students are the only ways to craft a strong essay, but there are approaches and tools that will make this process easier.

Here, you can find a some resources and tools that you can use to help write your essay. To write a great one you will have to branch out from these resources to answer questions in your own unique way, but this should provide a starting point. Just select the stage of the writing process you are currently at and get to work!

1. Suggested Topics

Stolen Art: from the Holocaust to the Present — Role of the Courts in Restoring Cultural Objects to Their Rightful Owners

Picking a topic might seem like the easiest part of this process, but that doesn't mean it should be taken lightly. You shouldn't just look at what seems interesting to you, but also at what you have to say on a topic and what you already know about the subject. In general, think about the questions on the right when picking a topic.


Throughout history, and particularly during World War II, cultural objects have been looted from museums and private families. In the name of justice, a global effort is underway to restore art objects to their rightful owners. We ask you to explore the role of the courts, and especially the role our NYS courts play, in reuniting families and institutions with possessions wrongly taken from them. Below are a series of questions to help guide your research into this important and ongoing topic.

  • Does this interest me?

    Writing about something that you want to write about will make the project engaging.
  • Do I have an argument about this?

    A good essay will make a strong argument, do you have strong feelings about the question one way or another?
  • What do I already know about this?

    Do you have any experience or knowledge of the topic? If you don't, don't be afraid to do some early research to see if you're actually interested in the topic!



    Here is a fact pattern from an actual case that reached the highest court in NYS, the Court of Appeals. It is followed by a series of questions to help guide you in learning about the role of the NY Courts in the quest to reunite Lea’s precious painting with her heirs.

    Lea Bondi Jaray, a Jewish woman, was forced to flee her home in Austria with nothing more than she could carry. She left behind one of her most precious assets, a painting entitled, “Portrait of Wally” by Egon Shiele. Her painting was taken from her by the Nazi regime. Prior to her death, she attempted to recover the painting, but to no avail. Her nephew, Henry Bondi, attempted to recover the painting in 1997 while it was on exhibit in New York on loan, from the Leopold Foundation, at the Museum of Modern Art. The museum did not return the painting and on January 7, 1998, the Manhattan District Attorney served MoMA with a subpoena demanding the return of the paintings. The Museum refused and filed suit to invalidate the subpoena.

    •  Why did the lower court decide against a return of the painting? Do you think the Court was correct? Why?
    •  Why did the NYS Appellate Division, the Court that heard the first appeal of this decision, reverse the decision of the lower court? Do you think the Court was correct? Why?
    •  The case was then appealed to the Court of Appeals. What was the reasoning of the Court's decision? Do you think the Court was correct and just in its decision? Why?

    View the summaries of these cases on our Resources page!

    Image: “Portrait of Wally” by Egon Shiele


    What role has the New York State Courts played in protecting those individuals who unknowingly purchase stolen art? What obligations do the courts have in upholding the reputation of New York State as the cultural capital of the world? In the case of The Guggenheim Foundation v. Lubell, do you believe the Court was more concerned with perception than the law? Do you agree or disagree with this statement and why?

    View the summary of this case on our Resources page!

    Image: “Seated Man with a Cane” by Amadeo Modigliani


    It has taken decades for the victims of stolen cultural art objects to recover their belongings. In the Matter of Stettiner, the heirs sought to act on behalf of their relative and recover stolen artwork. Does the role of the New York State Courts cease upon the death of the rightful owner, or do the Courts have an obligation to protect the interests of the heirs as well? Do you agree or disagree with the role of the Courts in extending ownership to the heirs?

    View the summary of this case on our Resources page!

    Image: “Le marchand de bestiaux” (“The Merchand of Cattle”) by Marc Chagall


    If you have another idea for a topic about Stolen Art, go for it! Consider if you think that victims of stolen objects have been treated fairly over the years in obtaining restitution of their precious possessions. The resources provided on the website will help you answer this question. Provide specific examples and cases that support and illustrate your argument.

2. Research

There are many ways to research a question: starting broadly and narrowing down to look at specific questions; following the course of one argument before exploring another; or starting with a specific idea and studying the other ideas that come from that. Overall it's up to you to pursue what makes the most sense.

What we want to encourage you is to take advantage of all of the resources available. Our Resources page offers a great deal of information that can be of use to anyone writing an essay, but there is so much more out there. Use the resources below as a starting point, but don't forget to look elsewhere!

Society The Society

This site has everything you need to start writing your essay. Check our Rules page to see what you need to do, read this guide and check out our Resources to get started!

Fellow Our Fellow

The Historical Society's Fellow is a resource for you and your professor! Email us at to ask questions and schedule campus visits to learn more.

Professor Your Professor

Your professors, whether you are writing your essay for their class or not, are also great resources. Ask them for general ideas or to review the work you've done so far and offer advice.

Library Library

The library at your college is a great resource, both for the books there and the help the librarians can provide! Don't be afraid to ask them for help with research, helping students is the best part of their jobs!

Journal Articles

Academic journals have a huge number of articles on these topics. Ask your librarian what databases your school has and how you can access them. We always recommend JSTOR as a starting point.

Newspapers Newspapers

Newspapers don't just report today's news. Their archives can go back decades and provide a look at what people were writing and thinking in the past.

Cases Cases & Laws

Opinions by judges and new laws relate to many of these concepts. Looking at these writings can give insight into exactly why these laws were changed.

You You

And don't forget about yourself! If you have personal experience you want to share, don't be afraid to use it to inform your other sources.

3. Write Your Essay

Tips & Tricks

Watch Society staff and Trustees discuss how to make your essay stand out to contest judges!

Prof. Scruggs's student, 2017 SUNY 2nd prize winner Anna Lewis, at Law Day

Read Prof. Charles Scruggs's blog post about the importance of the Scholarship and his role as a mentor for students! Click here!

Writing an essay for the Garfinkel Essay Scholarship is much like any other essay you've written before. Relying on solid evidence, writing clearly to make your point and citing your sources are all important factors. But this is a legal essay, and that entails a slightly different approach than you might be used to. So here are some tips on how to write a great essay for the contest!

  • Be Concise

    The people who review these essays are all attorneys, and legal writing emphasizes being able to make an argument quickly and effectively. So give your evidence, say why it is imporant and what you think and move on. Remember, the max length of the essay is 5,500 words. That might seem long but it can run out quickly when you're discussing a lot of sources!
  • Be Clear

    Don't forget to include a strong introduction and conclusion in your essay. These sections will help frame your essay and make what you're saying that much more clear to our reviewers.
  • Use Your Sources

    It is one thing to read a source and use that knowledge to support your argument. It is another to cite that source directly to prove that you are using it. Our reviewers look for evidence that supports your argument so be sure to make that clear!
  • Cite Your Sources

    As you use your sources be sure to keep track them and reference as you write, so that you can include them on a "works cited" page or add them as references to your text. This is key to showing your understanding of the topic. (NOTE: We do not require any specific format for references & citations)
  • Stick to Your Style

    Everyone has their own writing style, and don't be afraid to use it. Some of the best essays we've received have been very personal. (See this 2011 essay written by a NYFD member for a great example.)
  • Use Quotes

    Sometimes using a quote is far more effective than paraphrasing ideas in your essay. Just make sure to cite the quotation and clearly indicate that it is one!
  • Stick to Your Argument

    With broad topics it can be easy to try to discuss many different things in your essay. Stay focused on answering the question you have selected. This will be easier to do and result in a more convincing essay.
  • Don't Plagarize!

    We probably don't have to tell you, but don't copy or borrow from any of your sources without citing them! Plagiarism is strictly forbidden and will result in the immediate removal of your essay from consideration for any prizes without notification. Plagiarism can be intentional or unintentional, so check with us, your professor or a librarian if you are unsure. Better safe than sorry!

4. Submit Your Essay

When you're done writing just come back here to submit your essay! Be sure to review the rules listed below to be sure your essay meets our standards before submitting and you're all set! Please check to be sure you receive a confirmation email as this will let you know we have received your essay.

Please be sure that your essay:

  • Contains no identifying information (Name, School, Professor, Etc.)
  • Is either in DOC or PDF format
  • Is between 1,500 and 5,500 words
  • Contains a works cited page or other references

When you submit your essay we will assign it a code to ensure that it is read anonymously and fairly. We cannot divulge too many details about our judging process, but can say that in the three week judging period roughly a dozen judges participate in the process of selecting the top essays. At the end of that period we will notify the winners!

The David A. Garfinkel Essay Scholarship is generously supported by Gloria & Barry Garfinkel in memory of their son David. Their support has enabled the Society to offer this contest since 2008.

The Historical Society of the New York Courts was founded in 2002 with the mission of preserving New York's rich legal history and educating the public about it through programs, publications and other projects. Visit the Society's main site.

Icons: Document by Samuel Q. Green, Library by David Swanson, Book by iconoci, professor by, pointing by Cédric Villain, website by Wilson Joseph & Newspaper by John Caserta from the Noun Project