SPENCER v. ISLAMIC REPUBLIC OF IRAN
1:12-cv-00042
D.D.C.Oct 14, 2014Background
- The Beirut Marine barracks bombing in 1983 caused 241 U.S. military deaths and many injuries; plaintiffs, U.S. citizens or estates, sue Iran under FSIA’s state-sponsored terrorism exception, 28 U.S.C. § 1605A.
- The Court previously found Iran liable under § 1605A and referred damages to a special master.
- Damages provisions include economic loss, solatium, pain and suffering, and punitive damages under § 1605A(c).
- Court adopts the special master’s damages framework and awards, with specified deviations to align with prior Beirut cases.
- Key issues concern calculating and adjusting pain and suffering, solatium, and punitive damages, including adjustments for specific plaintiffs and proximate-cause implications.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Damages framework applied under §1605A | Peterson framework should govern awards | Framework should guide damages consistently | Court adopts the established framework with required adjustments |
| Solatium versus pain and suffering limits | Solatium should reflect close relationships and losses | Awards must align with established caps and proportionality | Court adopts most solatium awards but adjusts for certain relationships and caps to avoid excessive excess over pain and suffering |
| Proximate cause for Mirbal and Baez enhancement | Enhancement justified by misreport leading to acute distress | Enhancement not warranted beyond standard framework | Court adopts enhancement based on proximate-cause analysis and foreseeability of misreport |
| Treatment of Willard Howell damages | Potential emotional distress award warranted | No substantial relationship or proof of distress | Court denies solatium award for Howell |
| Punitive damages ratio | Maintain deterrence with substantial punitive ratio | Limit punitive to reasonable amount | Court applies $3.44 to $1 ratio from prior Beirut cases, yielding $351,435,133.44 in punitive damages. |
Key Cases Cited
- Valore v. Islamic Republic of Iran, 700 F. Supp. 2d 52 (D.D.C. 2010) (framework for solatium and damages in Beirut FSIA cases; baseline and departures)
- Peterson v. Islamic Republic of Iran (Peterson II), 515 F. Supp. 2d 25 (D.D.C. 2007) (damages framework and prior awards guiding current rulings)
- Estate of Bland v. Islamic Republic of Iran, 831 F. Supp. 2d 150 (D.D.C. 2011) (solatium framework; balance with injured serviceman’s pain and suffering)
- Heiser v. Islamic Republic of Iran, 466 F. Supp. 2d 229 (D.D.C. 2006) (foundation for solatium award hierarchy among relatives)
- Oveissi v. Islamic Republic of Iran, 768 F. Supp. 2d 16 (D.D.C. 2011) (solatium framework; close-relations presumptions; deviation guidance)
- Davis v. Islamic Republic of Iran, 882 F. Supp. 2d 7 (D.D.C. 2012) (precedent for calibrating family awards relative to serviceman’s pain and suffering)