Fritz v. Islamic Republic of Iran
324 F. Supp. 3d 54
| D.C. Cir. | 2018Background
- Four U.S. servicemembers (Fritz, Chism, Falter, and Al‑Taie) were abducted and murdered; plaintiffs are their estates and family members suing Iran and the IRGC under the FSIA state‑sponsored‑terrorism exception.
- The Court previously found Iran provided material support to Asaib Ahl al‑Haq (AAH) and granted default judgment as to liability for the U.S‑national plaintiffs under 28 U.S.C. § 1605A(a)–(c).
- The case was referred to a special master to calculate damages; the special master submitted detailed economic and non‑economic damage recommendations based on expert reports and testimony.
- The Court adopted the special master’s economic damages and most non‑economic awards, adjusted certain amounts (e.g., baseline pain and suffering, Al‑Taie’s captivity days), and approved prejudgment interest.
- The Court awarded punitive damages only for Al‑Taie’s estate and U.S.‑national family members because punitive damages under §1605A(c) apply only to post‑2008 conduct; it computed punitive damages using a 2× multiplier on compensatory damages attributable to post‑enactment conduct.
- The Court ordered partial final judgment under Fed. R. Civ. P. 54(b) for the U.S‑national plaintiffs so they can pursue recovery (including access to the federal victims’ fund), while non‑U.S. national claims remain pending.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Availability and amount of economic damages | CFES expert reports establish reasonable economic loss calculations for each decedent | Iran defaulted; no contrary economic proof | Court adopted CFES economic awards for estates |
| Award of pain and suffering to estates | Estates entitled to significant pain and suffering awards based on brutality and duration | (No opposition due to default) | Court awarded $5M each to Karbala victims; $10,640,000 to Al‑Taie estate (discounted 10 days) |
| Solatium to family members (including half/step relatives) | Close relationships and household/functional‑equivalent status justify solatium awards to listed relatives | (No opposition due to default) | Court adopted special master’s individualized solatium awards, including certain half/step relatives who proved functional equivalence |
| Punitive damages under §1605A(c) | Seek punitive damages for all victims | Punitive damages limited to post‑2008 conduct by Owens decision | Punitive damages awarded only for Al‑Taie’s post‑2008 injuries; set at 2× compensatory (total $55,903,936) |
| Prejudgment interest on economic and non‑economic awards | Plaintiffs seek prejudgment interest to fully compensate for delay | (No opposition due to default) | Court awarded prejudgment interest (prime‑rate method) on past economic and non‑economic awards |
| Entry of partial final judgment (Rule 54(b)) | Entry needed to allow U.S‑national plaintiffs access to federal victims’ fund and to avoid delay | (No opposition) | Court certified partial final judgment for U.S‑national plaintiffs; non‑U.S. claims remain pending |
Key Cases Cited
- Thuneibat v. Syrian Arab Republic, 167 F. Supp. 3d 22 (D.D.C. 2016) (FSIA §1605A provides liability for economic losses)
- Roth v. Islamic Republic of Iran, 78 F. Supp. 3d 379 (D.D.C. 2015) (forensic economist standards and evaluation)
- Valore v. Islamic Republic of Iran, 700 F. Supp. 2d 52 (D.D.C. 2010) (solatium and punitive damages guidance)
- Wultz v. Islamic Republic of Iran, 864 F. Supp. 2d 24 (D.D.C. 2012) (baseline compensatory assumptions for terror victims)
- Cohen v. Islamic Republic of Iran, 268 F. Supp. 3d 19 (D.D.C. 2017) (use of multiplier for punitive damages and apportionment)
- Owens v. Republic of Sudan, 864 F.3d 751 (D.C. Cir. 2017) (punitive damages under §1605A only for post‑enactment conduct)
- Landgraf v. USI Film Prods., 511 U.S. 244 (1994) (retroactivity principles governing new causes of action)
- Heiser v. Islamic Republic of Iran, 466 F. Supp. 2d 229 (D.D.C. 2006) (benchmarks for solatium awards)