Moradi v. Islamic Republic of Iran
2015 U.S. Dist. LEXIS 151
| D.D.C. | 2015Background
- Nik Moradi, a dual U.S.-Iranian citizen, was detained in Tehran from Oct. 31, 2007 to Apr. 15, 2008; he alleges prolonged solitary confinement, repeated violent interrogations, physical beatings, sexual assault, administration of drugs, threats of execution, and coerced false confessions.
- Nik experienced lasting physical and psychological injuries (diagnosed PTSD and major depressive disorder) and lost substantial weight; Deborah Moradi (his wife) alleges severe emotional harm and a ruined marriage.
- Plaintiffs served Iran under the FSIA §1608(a)(4); Iran defaulted by not appearing and a Clerk’s default was entered; plaintiffs moved for default judgment under FSIA §1605A and 28 U.S.C. §1608(e).
- Plaintiffs seek compensatory damages (pain and suffering, solatium, economic) and punitive damages; court must determine jurisdiction, liability under §1605A, and whether plaintiffs proved their claims by evidence satisfactory to the court.
- The court found the torture allegations met the TVPA/§1605A definition (purposeful, severe physical/mental pain to elicit confessions), establishing jurisdiction and liability; awarded compensatory and punitive damages but denied economic damages for lack of evidentiary support.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Jurisdiction under FSIA §1605A (terrorism exception) | Moradi was tortured by Iranian agents while a U.S. national and Iran was a state sponsor of terrorism; arbitration offer was made | Iran did not appear to contest service or jurisdiction | Held: Jurisdiction satisfied — Iran was designated state sponsor, plaintiffs are U.S. nationals, arbitration offer made; FSIA §1605A applies |
| Whether conduct constituted "torture" under TVPA/§1605A | Alleged extreme, deliberate physical and mental abuse (threats, beatings, sexual assault, mind‑altering drugs, death threats) to obtain confession | Defaulted; no responsive argument | Held: Conduct met TVPA definition of torture — purposeful, severe, and intended to elicit confession; court relied on Price/Simpson framework |
| Sufficiency of proof for default judgment under 28 U.S.C. §1608(e) | Submitted declarations, expert psychiatric reports, and documentary evidence sufficient to satisfy court without hearing | Iran defaulted | Held: Plaintiffs met the "satisfactory to the court" evidentiary standard for claims of torture and solatium; default judgment appropriate |
| Damages: compensatory (pain and suffering, solatium, economic) and punitive | Sought $1.68M (detention pain), $13.4M (post-release pain), $4M solatium, $2.784M economic, $300M punitive | Iran defaulted; court must assess reasonableness from record | Held: Awarded $6.168M to Nik for pain & suffering ($1.68M detention; $5M post-release), $4M solatium to Deborah; denied economic damages for lack of admissible proof; punitive damages equal to total compensatory ($10.168M) |
Key Cases Cited
- Price v. Socialist People’s Libyan Arab Jamahiriya, 294 F.3d 82 (D.C. Cir. 2002) (interpreting TVPA/§1605A "torture" definition and requiring purposeful, severe conduct)
- Simpson v. Socialist People’s Libyan Arab Jamahiriya, 326 F.3d 230 (D.C. Cir. 2003) (FSIA arbitration/§1605A procedural principles)
- Nikbin v. Islamic Republic of Iran, 517 F. Supp. 2d 416 (D.D.C. 2007) (examples of physical acts constituting torture under FSIA)
- Massie v. Government of the Democratic People’s Republic of Korea, 592 F. Supp. 2d 57 (D.D.C. 2008) (awarding post-release pain and suffering in prolonged captivity case)
- Sutherland v. Islamic Republic of Iran, 151 F. Supp. 2d 27 (D.D.C. 2001) (punitive and compensatory awards in FSIA terrorism/hostage context)