Use of artwork in promotion without artist's permission

A restaurant in Santa Fe, NM had 2 sculptures on loan for a

short time from an artist in Santa Fe. Without her knowledge, the owner of the restaurant used her sculptures in his promotional material. The sculpture was removed

from the restaurant, and the artist has requested he remove

her images from his promotional material. He refuses to do so. There was no written/signed agreement between them

that he could use her work for his benefit. Does this artist have a case against this restaurant owner?

Thank you