Davis v. Islamic Republic of Iran
2012 U.S. Dist. LEXIS 44296
| D.D.C. | 2012Background
- Beirut 1983 Marine barracks bombing killed 241 U.S. servicemen; plaintiffs sue Iran and MOIS under FSIA 1605A (state-sponsored terrorism exception).
- Court previously adjudicated liability against Iran and MOIS in related actions, adopting findings in Peterson v. Iran and Bland/O’Brien lines.
- Damages framework drawn from Peterson II and related rulings: compensatory, solatium, punitive, and economic loss eligible under 28 U.S.C. § 1605A.
- Court adopted special master’s damages recommendations with specific reductions where warranted by this Court’s prior framework (pain and suffering, solatium, and economic loss).
- Court rejected expansive after-born solatium claims, holding only those alive at time of attack may recover; dismissed after-born plaintiffs accordingly.
- Final judgment awards $486,918,005 in compensatory damages and $1,674,997,937 in punitive damages (total $2,161,915,942), with joint and several liability against defendants; certain claims dismissed for lack of prosecutorial diligence or as non-immediate-family at time of attack.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether after-born children may recover solatium under 1605A(c) | After-borns are within continuing impact of attack; should recover. | Solatium requires ‘immediate family’ present and alive at attack under Restatement §46; unborns not covered. | After-born solatium claims are DISMISSED; must be alive at time of attack to recover. |
| Whether solatium awards may exceed pain and suffering awards | Family solatium should reflect the emotional injury from attack. | Solatium should be proportionally limited to pain and suffering awards. | Solatium awards are reduced to align with the Court’s framework; no exceedance relative to pain and suffering. |
| How punitive damages are calculated relative to compensatory damages | Apply broad punitive awards within deterrence framework. | Limit punitive via ratio to compensatory damages. | Apply the established ratio (approximately $3.44 to $1) from prior Beirut cases; total punitive damages set at $1,674,997,937. |
| Whether to adopt the special master’s damages recommendations or modify to fit the framework | Adopt master’s awards as framework-directed. | Adjust inconsistent awards to fit the standard damages framework. | ADOPTS the master’s damages framework but corrects certain awards to conform with prior decisions. |
Key Cases Cited
- Valore v. Islamic Republic of Iran, 700 F.Supp.2d 52 (D.D.C.2010) (damages framework for compensatory and punitive awards in FSIA cases; cites 3.44 ratio)
- Bland v. Islamic Republic of Iran, 831 F.Supp.2d 150 (D.D.C.2011) (reduction of family solatium relative to serviceman pain and suffering)
- O’Brien v. Islamic Republic of Iran, 853 F.Supp.2d 44 (D.D.C.2012) (applied proportional reductions to family solatium awards)
- Heiser v. Islamic Republic of Iran, 466 F.Supp.2d 229 (D.D.C.2006) (framework for family solatium awards in deceased-victim contexts)
- Heiser II v. Islamic Republic of Iran, 659 F.Supp.2d 20 (D.D.C.2009) (standards for standing to recover solatium; immediate family presence guidance)
- Peterson v. Islamic Republic of Iran, 515 F.Supp.2d 25 (D.D.C.2007) (foundations for damages framework and liability in related Beirut cases)
- Peterson II, 515 F.Supp.2d 25 (D.D.C.2007) (damages and framework adopted by Court in this action)
- Murphy v. Islamic Republic of Iran, 740 F.Supp.2d 51 (D.D.C.2010) (punitive damages ratio tied to earlier Beirut cases)
- Oveissi v. Islamic Republic of Iran, 768 F.Supp.2d 16 (D.D.C.2011) (solatium framework; caution against expansive interpretations)