“Treasure hid in the earth, not upon the earth, nor in the sea, and coin though not hidden, being found is the king’s; we call it treasure trove.” Sir Henry Finch, Law, or a Discourse Thereof 177 (1759).
“Treasure trove consists essentially of articles of gold and silver, intentionally hidden for safety in the earth or in some secret place, the owner being unknown, although it is probable that the category might include articles made from the required metals buried in the ground for other purposes, for example in connection with an ancient sepulture. In the United States, the state has never claimed title to lost property by virtue of its character as treasure trove, and it has been stated that the law relating thereto is merged with that of lost goods generally, although there is authority for the proposition that while treasure trove in the United States belongs to the finder, found goods not of that character go to the owner of the locus in quo.” Ray Andrews Brown, The Law of Personal Property§ 13, at 27–28 (2d ed. 1955).
