ATLANTA, GA – The U.S. Court of Appeals for the Eleventh Circuit upheld a lower court ruling denying Michael Prime’s request for the return of a destroyed hard drive he claimed contained cryptographic keys to access nearly 3,443 bitcoin, now valued at more than $345 million.
Prime, who was arrested in 2019 for counterfeiting and identity theft, initially told federal agents he possessed approximately 3,500 bitcoin. However, he later reported owning only $200 to $1,500 in cryptocurrency and repeatedly denied having significant bitcoin holdings during sentencing and probation interviews.
According to court records, the government destroyed several electronic devices, including the hard drive in question, after Prime failed to disclose their contents. Years later, he claimed that the drive held bitcoin keys and sought compensation from the government.
The Eleventh Circuit affirmed the district court’s finding that Prime’s claim was barred by laches, an equitable doctrine preventing recovery when a claimant unreasonably delays action and prejudices the opposing party. The court concluded that Prime’s repeated denials and years-long delay made his request untimely.
“Even if the bitcoin existed, and that’s a big if, awarding Prime an equitable remedy here would be inequitable,” wrote Circuit Judge Britt Grant.
The decision affirms that Prime is not entitled to any recovery related to the destroyed hard drive.
