Taylor v. Islamic Republic of Iran
2011 U.S. Dist. LEXIS 96238
| D.D.C. | 2011Background
- Beirut 1983 bombing killed 241 U.S. servicemen; eight family plaintiffs sue Iran under FSIA state-sponsored terrorism exception §1605A.
- Plaintiffs allege Iran created and supported Hezbollah and directed attacks, causing emotional distress and death of family members.
- NDAA 2008 §1083 creates a federal right of action against foreign states and authorizes retroactive application to related suits.
- This action is related to prior FSIA Beirut cases (Peterson, Valore) establishing Iranian responsibility and Hezbollah linkage.
- Plaintiffs served Iran by mail; default entered after no responsive pleading; court uses special master evidence to support findings of fact.
- Court must determine liability and authorize damages framework, including potential special-master damages assessment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether FSIA §1605A provides jurisdiction. | Taylor argues §1605A applies, providing money damages for extrajudicial killing. | Iran argues immunity and lack of sufficient connection to act. | Yes; jurisdiction established under §1605A. |
| Whether sovereign immunity is waived under §1605A. | Estates and heirs seek damages for family injuries from the bombing. | Waiver requires designation as sponsor and lack of arbitration requirement. | Waiver satisfied; Iran liable. |
| Retroactive application of NDAA §1083 to related cases. | NDAA §1083 allows treating related actions under §1605A retroactively. | Retroactivity limited by statutory conditions. | Retroactive application permitted for related claims. |
| Estate standing to pursue damages for injuries to decedents. | Estates may bring claims for injuries suffered by decedents under state law. | Standards vary by state law and may bar recovery for pain and suffering. | Estate plaintiffs have standing when state law allows survival of claims. |
| Scope of recoverable damages (emotional distress and punitive damages). | Eight Counts for IIED; seeks punitive damages; punitive damages may be allowed as remedy. | Punitive damages must be tied to an independent federal claim; free-standing punitive claim improper. | Eligible remedies: IIED damages; punitive damages allowed as part of IIED claim; Count IV dismissed as standalone. |
Key Cases Cited
- Betlis v. Islamic Republic of Iran, 315 F.3d 325 (D.C. Cir. 2003) (establishes general FSIA immunities and exceptions)
- Bettis v. Islamic Republic of Iran, 315 F.3d 325 (D.C. Cir. 2003) (extents of FSIA immunity and state-sponsored terrorism exception)
- Peterson v. Islamic Republic of Iran, 264 F. Supp. 2d 46 (D.D.C. 2003) (found Hezbollah under Iranian influence; Iran participation in attack)
- Rimkus v. Islamic Republic of Iran, 750 F. Supp. 2d 163 (D.D.C. 2010) (framework for liability, causation, and punitive damages under §1605A)
- Valore v. Islamic Republic of Iran, 700 F. Supp. 2d 52 (D.D.C. 2010) (evidence and theories of recovery under §1605A; use of prior findings)
- Murphy v. Islamic Republic of Iran, 740 F. Supp. 2d 51 (D.D.C. 2010) (explain liability and agency principles for foreign-state defendants)