Anderson v. Islamic Republic of Iran

Citations: 839 F. Supp. 2d 263; 2012 U.S. Dist. LEXIS 37085; 2012 WL 928256Docket: Civil Action No. 2008-0535

Court: District Court, District of Columbia; March 20, 2012; Federal District Court

Original Court Document: View Document

SummaryOriginalCytator Case TreatmentBackward CitatorAnalysis

EnglishEspañolSimplified EnglishEspañol Fácil

This legal memorandum addresses a case involving the 1983 bombing of the U.S. Marine barracks in Beirut, resulting in the deaths of 241 servicemen and numerous injuries, including to servicemen Dennis Jack Anderson, Jr. and Willie George Thompson. The plaintiffs, family members of the victims, are suing the Islamic Republic of Iran and the Iranian Ministry of Information and Security (MOIS) under the state-sponsored terrorism exception of the Foreign Sovereign Immunities Act (FSIA), specifically 28 U.S.C. 1605A, which allows federal lawsuits against foreign states that sponsor terrorism.

The court previously established liability against Iran in a related case (Peterson v. Islamic Republic of Iran) and has referred this case to a special master to assess damages. Under the FSIA, damages can include economic losses, solatium for emotional distress, pain and suffering, and punitive damages. The plaintiffs are required to demonstrate that the harm caused by the defendants was likely to occur and to provide reasonable estimates of damages.

The court adopts the special master's findings on damages, consistent with prior cases including Peterson, Valore, and Bland, affirming that the defendants' actions were intended to inflict injury, thereby justifying the awarded damages.

If the special master’s recommendations for damages differ from the established court framework, they will be adjusted to align with previous awards. The final damages for each plaintiff are detailed in a separate Order and Judgment, with this Court focusing on solatium and punitive damages due to the remaining plaintiffs being family members of injured servicemen. The Court's standardized approach for solatium claims, derived from *Heiser v. Islamic Republic of Iran*, indicates that spouses typically receive about $8 million, parents $5 million, and siblings $2.5 million, based on historical averages. For cases involving injury rather than death, the awards are half of these amounts, with spouses receiving $4 million, parents $2.5 million, and siblings $1.25 million. Children of deceased victims typically receive $3 million, while those of injured victims receive $1.5 million. Courts may adjust these figures based on factors such as the closeness of the plaintiff's relationship with the victim, medical evidence of suffering, or the nature of the attack. In this case, the special master did not suggest any deviations from the framework. The special master recommended that the parents of serviceman Dennis Anderson, Jr. receive $2.5 million each, noting the severe psychological impact the bombing had on the family following Anderson Jr.'s injuries.

Melvin Oley Thompson is awarded $2.5 million for the severe injuries his son, Willie George Thompson, sustained from a bombing, which included a broken hip, wrist, groin injuries, and facial lacerations. The court acknowledges the emotional distress experienced by Melvin Oley Thompson and the significant impact on his family. The court adopts the special master's recommendations for solatium awards after reviewing the evidence. 

In determining punitive damages, the court emphasizes the need to balance the risk of excessive financial burden on defendants against the necessity of deterring terrorist activities. The court follows the Supreme Court’s guidance to link punitive damages in related cases to previously established ratios, specifically applying a $3.44 ratio from past cases related to the Beirut bombing. This results in a punitive damages award of $25,800,000. 

In conclusion, the court holds Iran and MOIS accountable for their support of terrorism, awarding a total of $33,300,000, which includes $7,500,000 in compensatory solatium damages. A separate Order and Judgment will be issued reflecting these findings, signed by Chief Judge Royce C. Lamberth on March 20, 2012.