Editor’s Note: Jürgen Dinkel’s article, “‘The Rich Uncle from America’: Transnational Inheritance Transfers between the United States, Germany, and Russia, 1840s–1980s,” appeared in Law and History Review 43, no. 3 (August 2025). Dr. Dinkel’s second book, All Remains in the Family: Inheritance and Property in Germany, Russia, and the United States since the 19th Century was published in 2023.
The Docket [TD]: Please discuss the connection between your LHR article and your book, All Remains in the Family?
Jürgen Dinkel [JD]: My second book, All Remains in the Family: Inheritance and Property in Germany, Russia, and the United States since the 19th Century, was published in 2023. In my book, I argue that inheritance plays a crucial role in the creation, perpetuation, and transformation of wealth inequalities in modern societies. Rather than being purely meritocratic, the societies of the 20th and 21st centuries have fundamentally been shaped by inheritance and family.
To support this central thesis, the book is built on two main pillars. The first is an examination of the political and legal debates surrounding estates and inheritance taxes in three countries; the second is an analysis of over 2,300 specific inheritance cases across three cities: Baltimore in Maryland (USA), Frankfurt am Main (Germany), and Odessa (which belonged successively to the tsarist empire, the Soviet Union, and post-socialist Ukraine). These cases allowed me to gain detailed insight into everyday inheritance patterns and estate planning strategies in the cities and corresponding societies.
However, while conducting research for these three case studies, a significant pattern emerged: the deceased and their heirs did not always reside in the same place, jurisdiction, or country. Due to migration processes, forced resettlements, and changing borders after wars, testators and heirs frequently lived in different countries. As a result, inheritance transfers across political and legal borders were just as common as those within a jurisdiction or a single state. Inheritance was not confined to the nation-state; it persistently crossed its boundaries. The trope of the “rich uncle from America”—a male relative who had become wealthy enough to financially support his family back home—even became a standard character in novels and movies, as well as a common subject in international legal disputes.
Despite the prevalence of these transnational inheritance transfers, neither historical inheritance research nor transnational history has systematically addressed these phenomena. In response, I added a fourth case study to my book specifically focusing on such transfers among migrants. This perspective—examining cross-border inheritance transfers—continued to occupy me long after the book’s publication and led me to consult numerous additional archives, including, among others, the Harold J. Berman Papers at the Emory Law Archives in Atlanta and the Political Archives of the Foreign Ministry of Germany in Berlin. In a world fundamentally shaped by migration, I believe it is necessary to open up historical inheritance research to approaches derived from transnational history. My latest findings on this topic are now available in the form of the LHR article.
TD: How did you get interested in the history of transnational inheritance law and policy?
JD: It was my long-standing interest in inequalities that ultimately led me to the topic of inheritance. I have long been fascinated by the questions of how inequalities emerge, perpetuate themselves, and how they intersectionally reinforce or weaken each other. After completing my dissertation on the Non-Aligned Movement—an international organization that sought to eliminate global inequalities—I began searching for a topic that would bring me closer to individual people and the concrete, everyday manifestations of inequality.
The topic of inheritance is perfectly suited for this. When looking through probate files, wills, and court records, I suddenly had a clearer picture of the individuals and their families—revealing their sensibilities and their interpersonal relationships.
At the same time, I was fascinated by how emotions and material issues, notions of justice and family, past experiences, and future expectations are profoundly interwoven in the inheritance process. Inheritance transfers affect the relationship between the state, the family, and the individual, and depending on how an estate is distributed, this has far-reaching consequences for individual life plans, family cohesion, and, crucially, inequalities in society as a whole.
TD: Can you discuss some of the challenges of conducting multi-archive research in multiple countries?
JD: It is certainly a rewarding endeavor, but when people ask me about the three-country comparison, I sometimes reply—half-seriously, half-jokingly—that I will never attempt it again. The associated gain in knowledge is undoubtedly immense—but so are the sheer logistical and intellectual challenges it entails.
The difficulties are layered. First, you have to understand three distinct legal systems and the associated procedures for the transfer of estates. Second, the institutions responsible for documenting this transfer varied significantly across the countries (such as the Orphans Court in Baltimore, the Amtsgericht in Frankfurt, and the Notary in Odessa). In addition, these three institutions produced different types of documents, which are now stored using different methods across various city and state archives. You must therefore understand not only the historical legal context but also the modern archival logic and procedures.
Furthermore, the information documented by these institutions varied greatly, and the density of the records is uneven—particularly in Europe due to the destructive effects of war. For me, though, the most profound difficulty was not in the archives themselves. It was in the process of synthesizing: that is to say, translating three distinct local developments and one major transnational development into a single, cohesive, linear narrative within a book. Storytelling has never been so difficult for me.
TD: What’s next for your research?
JD: My current research focuses on a closer examination of how inheritance works within socialist systems. I am pursuing this through two distinct but related projects. My first project deals with the case of Zschernig v. Miller, 389 U.S. 429 (1968) before the Supreme Court of the United States, which already is mentioned in the LHR article. This case concerns heirs residing in Leipzig (German Democratic Republic, GDR) and their aunt, who died in Oregon. The case provides a unique lens through which to analyze the friction points and legal complexities of transnational property and inheritance transfers between capitalist and socialist states during the Cold War as well as the binding force of kinship networks across the Iron Curtain.
My main, larger undertaking, however, is investigating inheritance patterns in the GDR. I am examining how people in Leipzig and the surrounding rural areas dealt with inheritance from the late 1940s into the 2000s. My main hypothesis runs contrary to the common claim that inheritance played no substantial role in socialism. Instead, I propose that older concepts of family, property, and traditional inheritance patterns persisted in the GDR. Furthermore, these continued transfers of family properties may have contributed significantly to what is sometimes called the “strange stability” of the GDR. To test this empirically, I have access to a fantastic, previously unprocessed inventory of several thousand probate files held at the local Leipzig Amtsgericht, conveniently located near my university office. It is a goldmine for understanding the hidden economies of “private” property transfers among kinship networks during socialism.