Lawrence v. United States Department of the Treasury, 34 F. Supp. 3d 1140

Plaintiffs Randall Lawrence and Michael McConnell own a 1974-D Aluminum Cent; Lawrence says he inherited it from his father, a long‑time Denver Mint official.
The U.S. Mint circulated hundreds of 1974 aluminum cents as samples; most were melted or recovered after Congress declined to adopt aluminum cents. The precise number remaining is unknown.
The Mint's Chief Counsel sent Plaintiffs a letter demanding return, asserting unissued Mint items remain government property regardless of private possession.
Plaintiffs filed a declaratory-judgment action seeking a declaration that the Government’s claim to the coin is invalid and to stop interference with an auction sale.
Defendants (U.S., Treasury, U.S. Mint) moved to dismiss under Fed. R. Civ. P. 12(b)(6), arguing the complaint lacks facts plausibly establishing lawful private ownership and that unissued Mint items remain government property.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Complaint states a plausible claim of ownership and right to sell the coin	Lawrence claims inherited ownership from his father and alleges the coin was struck at Denver Mint	Government says mere possession is insufficient; unissued/unlawfully removed Mint items remain U.S. property and plaintiffs alleged no lawful transfer	Dismissed for failure to state a claim; plaintiffs did not plead sufficient facts to plausibly establish lawful ownership or right to sell
Whether factual disputes preclude dismissal	Plaintiffs argue factual issues (customary private ownership of nonissued coins) require more development	Government contends plaintiffs offered no factual basis for lawful possession or exception to government title	Court found plaintiffs’ allegations conclusory and insufficient under Twombly/Iqbal; dismissal appropriate
Whether judicial notice of Mint letters/regulations affects pleading	Plaintiffs opposed judicial notice	Defendants requested judicial notice of letters and historical Mint materials	Court denied request for judicial notice as moot after granting dismissal
Whether dismissal should be with prejudice	Plaintiffs sought to proceed	Defendants sought dismissal	Complaint dismissed without prejudice as to amendment; plaintiffs may move to amend within 30 days

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (establishes plausibility pleading standard)
Ashcroft v. Iqbal, 556 U.S. 662 (applies plausibility standard; legal conclusions not assumed true)
Balistreri v. Pacifica Police Dep’t, 901 F.2d 696 (9th Cir. 1988) (12(b)(6) dismissal for lack of cognizable legal theory)
Kern Copters, Inc. v. Allied Helicopter Serv., Inc., 277 F.2d 308 (9th Cir. 1960) (government’s authority over disposition of its property)
Langbord v. U.S. Dep’t of the Treasury, 888 F. Supp. 2d 606 (E.D. Pa. 2012) (unlawfully removed Mint coins remain U.S. property)