Keith Stansell v. Mercurio International S.A., 2013 U.S. App. LEXIS 572

This case interprets what qualifies as a 'blocked asset' under Terrorism Risk Insurance Act § 201.
FARC has been designated and funds under US jurisdiction were frozen under various sanctions regimes.
Mercurio International was designated as a Specially Designated Narcotics Trafficker under the Kingpin Act, freezing its US assets.
Appellees sought a writ of garnishment against Mercurio’s Kingpin Act frozen assets to satisfy a default judgment against FARC.
The district court granted the garnishment, holding Mercurio’s assets were 'blocked assets' under § 201(a).
The court of appeals reversed, holding Kingpin Act frozen assets are not 'blocked assets' under § 201(d)(2)(A).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does Kingpin Act freezing qualify as blocked assets?	Mercurio’s assets are effectively blocked as a FARC instrumentality.	Kingpin Act assets are not listed in § 201(d)(2)(A) and thus not blocked.	Kingpin Act assets are not blocked assets under § 201(d)(2)(A).
Can § 201(d)(2)(B) or history alter the definition to include Kingpin Act?	Legislative history supports broad interpretation to aid victims.	Plain text is exclusive; history cannot create ambiguity; Kingpin Act not included.	Plain text controls; § 201(d)(2)(B) exemptions and history do not expand to Kingpin Act.

Rush v. United States, 874 F.2d 1513 (11th Cir. 1989) (plain-language interpretation of statutory 'means' vs. 'includes')
Colautti v. Franklin, 439 U.S. 379 (U.S. 1979) ("means" denotes exhaustive definition)
Burgess v. United States, 553 U.S. 124 (U.S. 2008) (plain-language controls when unambiguous)
Probel v. United States, 214 F.3d 1285 (11th Cir. 2000) (statutory definitions govern meaning of terms)
Harris v. Garner, 216 F.3d 970 (11th Cir. 2000) (statutory definitions control unless inescapably ambiguous)
Weinstein v. Islamic Republic of Iran, 609 F.3d 43 (2d Cir. 2010) (distinguishes context where blocked assets arise under enumerated Act)