Baker v. Islamic Republic of Iran

CourtDistrict Court, District of Columbia
DecidedAugust 28, 2025
DocketCivil Action No. 2022-2765
StatusPublished

This text of Baker v. Islamic Republic of Iran (Baker v. Islamic Republic of Iran) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Baker v. Islamic Republic of Iran, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

NAMIG BAKER, et al.,

Plaintiffs, Civil Action No. 22-2765 (BAH) v. Judge Beryl A. Howell ISLAMIC REPUBLIC OF IRAN,

Defendant.

MEMORANDUM OPINION

This action, brought by sixty-one plaintiffs, arises out of sixteen separate terrorist attacks

targeting U.S. military personnel that were carried out in Afghanistan between 2008 and 2012.

See Compl. ¶ 1, ECF No. 1; Pls.’ Mot. for Default J. (“Pls.’ Mot.”), ECF No. 31, Ex. 1, Pls.’

Proposed Findings of Fact & Conclusions of Law (“Pls.’ Mem.”) at 1, 16, ECF No. 31-1. Each of

these attacks injured one of the plaintiffs, who were members of the U.S. Armed Forces at the time

of the attacks. Compl. ¶ 1. The remaining forty-five plaintiffs are immediate family members of

these sixteen injured servicemembers. Id. Plaintiffs allege that defendant, the Islamic Republic

of Iran (“Iran”), provided “material support and resources” to a “syndicate” of terrorist

organizations responsible for these attacks, id. ¶¶ 2, 4, and plaintiffs seek damages for their injuries

suffered as a result of the attacks, under the Foreign Sovereign Immunities Act’s (“FSIA”) state-

sponsored terrorism exception, 28 U.S.C. § 1605A(c). Plaintiffs have complied with the FSIA’s

requirements for effectuating service on a defendant, see id. § 1608(a)(4), but Iran has failed to

enter an appearance or otherwise defend against this action, see Return of Service/Aff. of

Summons & Complaint Executed, ECF No. 13; Clerk’s Entry of Default, ECF No. 15. Plaintiffs

now seek the entry of default judgment against Iran as to liability and damages. Pls.’ Mot. For

1 the reasons detailed below, plaintiffs’ motion for default judgment is granted in part and denied in

part.

I. LEGAL STANDARD

“Rule 55(a) [of the Federal Rules of Civil Procedure] requires the Clerk to enter a default

when a defendant ‘has failed to plead or otherwise defend, and that failure is shown by affidavit

or otherwise,’” and, “[o]nce the Clerk does so, the plaintiff may ‘apply to the court for a default

judgment’ under Rule 55(b).” Shatsky v. Palestine Liberation Org., 955 F.3d 1016, 1023 (D.C.

Cir. 2020) (quoting FED. R. CIV. P. 55(a), (b)(2)). Federal Rule of Civil Procedure 55(b)(2) thus

permits a court to consider entering a default judgment when a party applies for that relief. See

FED. R. CIV. P. 55(b)(2). At the same time, since “strong policies favor resolution of disputes on

their merits[] ‘[t]he default judgment must normally be viewed as available only when the

adversary process has been halted because of an essentially unresponsive party.’” Jackson v.

Beech, 636 F.2d 831, 836 (D.C. Cir. 1980) (quoting H.F. Livermore Corp. v. Aktiengesellschaft

Gebruder Loepfe, 432 F.2d 689, 691 (D.C. Cir. 1970) (second bracket in original)). Moreover,

the procedural posture of a default does not relieve a federal court of its typical obligations,

including its “affirmative obligation” to determine whether the court has subject-matter

jurisdiction over the action. James Madison Ltd. by Hecht v. Ludwig, 82 F.3d 1085, 1092 (D.C.

Cir. 1996). Additionally, “a court should satisfy itself that it has personal jurisdiction before

entering judgment against an absent defendant.” Mwani v. bin Laden, 417 F.3d 1, 6 (D.C. Cir.

2005). Consequently, “entry of a default judgment is not automatic.” Id. at 6 (footnote omitted).

When default judgment is sought under the FSIA, a movant must also “establish[] his claim

or right to relief by evidence satisfactory to the court.” 28 U.S.C. § 1608(e). This requirement

“provides foreign sovereigns a special protection akin to that assured the federal government by

2 Fed. R. Civ. P. 55([d]).” Jerez v. Republic of Cuba, 775 F.3d 419, 423 (D.C. Cir. 2014); see also

H.R. Rep. No. 94-1487, at 26 (1976) (stating that § 1608(e) establishes “the same requirement

applicable to default judgments against the U.S. Government under rule 55([d])”); Klapprott v.

United States, 335 U.S. 601, 611 (1949) (noting that Rule 55(d) “expressly bars all judgments

against the United States without proof”).

While the “FSIA leaves it to the court to determine precisely how much and what kinds of

evidence the plaintiff must provide,” courts must be mindful that Congress enacted § 1605A, the

FSIA’s state-sponsored terrorism exception, and § 1608(e) with the “aim[] to prevent state

sponsors of terrorism—entities particularly unlikely to submit to this country’s laws—from

escaping liability for their sins.” Han Kim v. Democratic People’s Republic of Korea, 774 F.3d

1044, 1047-48 (D.C. Cir. 2014); see also Maalouf v. Islamic Republic of Iran, 923 F.3d 1095, 1114

(D.C. Cir. 2019). To this end, the D.C. Circuit has instructed that “courts have the authority—

indeed, we think, the obligation—to ‘adjust evidentiary requirements to . . . differing situations.’”

Han Kim, 774 F.3d at 1048 (alterations accepted) (quoting Bundy v. Jackson, 641 F.2d 934, 951

(D.C. Cir. 1981)); see also Klapprott, 335 U.S. at 611 (observing that “statutes and rules have

largely left for judicial determination the type of cases in which hearings and proof should precede

default judgments”).

Generally, courts in FSIA default actions must draw their “findings of fact and conclusions

of law from admissible testimony in accordance with the Federal Rules of Evidence.” Han Kim,

774 F.3d at 1049 (quoting Daliberti v. Republic of Iraq, 146 F. Supp. 2d 19, 21 n.1 (D.D.C. 2001)).

Uncontroverted factual allegations that are supported by admissible evidence are taken as true.

Roth v. Islamic Republic of Iran, 78 F. Supp. 3d 379, 386 (D.D.C. 2015) (“Courts may rely on

uncontroverted factual allegations that are supported by affidavits.” (citing Rimkus v. Islamic

3 Republic of Iran, 750 F. Supp. 2d 163, 171 (D.D.C. 2010))); accord FED. R. CIV. P. 56(e)(2)

(authorizing court to “consider the fact undisputed for purposes of the motion” when the adverse

party “fails to properly address another party’s assertion of fact”).

The D.C. Circuit’s “review of findings underlying a default judgment in a FSIA case of

this sort is ‘lenient.’” Fraenkel v. Islamic Republic of Iran, 892 F.3d 348, 356 (D.C.

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