Boothe v. Islamic Republic of Iran

CourtDistrict Court, District of Columbia
DecidedMarch 24, 2026
DocketCivil Action No. 2022-1747
StatusPublished

This text of Boothe v. Islamic Republic of Iran (Boothe 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
Boothe v. Islamic Republic of Iran, (D.D.C. 2026).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

SHASTRI BOOTHE, et al.,

Plaintiffs,

v. No. 22-cv-1747 (TSC)

ISLAMIC REPUBLIC OF IRAN,

Defendant.

MEMORANDUM OPINION

Plaintiffs are six U.S. service members, each of whom was injured in terrorist attacks while

deployed to Afghanistan, and thirteen members of their immediate families. 1 They sued the

Islamic Republic of Iran under the Foreign Sovereign Immunities Act (“FSIA”), alleging that Iran

provided material support to a syndicate of terrorist groups which enabled those groups to carry

out the attacks which injured Plaintiffs. Compl. ¶¶ 1, 2, 10–33, 162–66, 176, ECF No. 1. After

Iran failed to respond to service of process, the Clerk of the Court entered default. See Entry of

Default, ECF No. 15. Plaintiffs now move for a default judgment and ask the court to find Iran

liable for their injuries. See Pls.’ Mot. for Default J., ECF No. 20. For the reasons below, the court

will GRANT in part and DENY in part Plaintiffs’ Motion.

1 The Service Member Plaintiffs are Shastri Boothe, Jared Bland, Joshua Chambers, John Mitchell III, Alex Murtha, and Brian Worbington. The Family Member Plaintiffs are M.B. (Shastri Boothe’s family); G.B. and J.B. (Jared Bland’s family); Erin, Kevin, and Nancy Chambers (Joshua Chambers’ family); John Mitchell Jr., Diane Mitchell, Stacey Atkins, and Sally Mitchell (John Mitchell III’s family); Kelley McHenry (Alex Murtha’s family); and Wendy and Constance Worbington (Brian Worbington’s family). Page 1 of 37 I. LEGAL BACKGROUND

Under the FSIA, foreign nations are generally immune from the reach of American courts.

See 28 U.S.C. § 1604. The FSIA established, however, several exceptions to foreign sovereign

immunity, including the “terrorism exception,” which is codified at 28 U.S.C. § 1605A(a)(1). The

terrorism exception withdraws immunity “from a state sponsor of terrorism that has engaged in an

‘act of torture, extrajudicial killing, aircraft sabotage, hostage taking, or the provision of material

support or resources for such an act.” Borochov v. Islamic Republic of Iran, 94 F.4th 1053, 1057

(D.C. Cir. 2024) (quoting Antiterrorism and Effective Death Penalty Act of 1996, Pub. L. No. 104-

132, § 221, 110 Stat. 1214, 1241) (cleaned up). The FSIA also contains “a cause of action for U.S.

citizens, members of the U.S. armed forces, and U.S. government employees who have been

injured by foreign states’ acts or sponsorship of terrorism.” Id. (citing 28 U.S.C. § 1605A(c)).

Foreign states accused of sponsoring terrorism often do not appear to defend suits brought

against them. See Borochov, 94 F.4th at 1058. When that happens, the Clerk of the Court is

required to enter default against them. See Fed. R. Civ. Pro. 55(a). But generally, the plaintiff

“must [then] apply to the court for a default judgment.” See id. 55(b). The “entry of a default

judgment is not automatic.” Mwani v. Bin Laden, 417 F.3d 1, 6 (D.C. Cir. 2005). Before a default

judgment can be entered in an FSIA case, three prerequisites must be met.

First, the court must have subject matter jurisdiction. Borochov, 94 F.4th at 1060. “Here,

subject-matter jurisdiction exists only if [Plaintiffs’] claims fall within one of the FSIA’s

exceptions to foreign sovereign immunity,” as “these exceptions are the ‘sole bases for obtaining

jurisdiction over a foreign state in federal court.’” Id. (quoting Permanent Mission of India to the

Page 2 of 37 U.N. v. City of New York, 551 U.S. 193, 197 (2007)) (cleaned up). Second, Plaintiffs must show

that the court has personal jurisdiction over Iran. See Mwani, 417 F.3d at 6.

Finally, the FSIA requires “each plaintiff” seeking a default judgment to “establish his

claim or right to relief by evidence satisfactory to the court.” Borochov, 94 F.4th at 1058 (quoting

28 U.S.C. § 1608(e)) (cleaned up). This requirement grants “foreign sovereigns a special

protection akin to that assured by the federal government” by [Federal Rule of Civil Procedure]

55(e) and seeks to guard against “claims that are unfounded.” Jerez v. Republic of Cuba, 775 F.3d

419, 423 (D.C. Cir. 2014). In assessing whether a plaintiff has put forth satisfactory evidence, the

court “must draw [its] findings of fact . . . from admissible testimony in accordance with the

Federal Rules of Evidence.” Han Kim v. Dem. People’s Republic of Korea, 774 F.3d 1044, 1049

(D.C. Cir. 2014) (cleaned up). Nevertheless, the FSIA gives courts the flexibility—and “indeed,

. . . the obligation—to adjust evidentiary requirements to differing situations” so that state sponsors

of terrorism cannot “effectively immunize themselves” by refusing to appear in court and subject

themselves to discovery. Id. at 1048 (cleaned up). Accordingly, “the quantum and quality of

evidence that might satisfy a court can be less than that normally required.” Owens v. Republic of

Sudan, 864 F.3d 751, 785 (D.C. Cir. 2017).

II. ISSUES OF EVIDENCE

Before this court can make its findings of fact, it must resolve Plaintiffs’ evidentiary

requests. The first is that the court take judicial notice of and “adopt the key findings of fact and

conclusions of law” made by another district court in Cabrera v. Islamic Republic of Iran, No. 19-

cv-3835, 2022 WL 2817730 (D.D.C. July 19, 2022). Pls.’ Mem. Supp. Default J. at 10, ECF No.

20-1 (“Pls.’ Br.”). Federal Rule of Evidence 201 permits a court to “judicially notice a fact that is

not subject to reasonable dispute because it . . . is generally known within the trial court’s territorial

Page 3 of 37 jurisdiction; or . . . can be accurately and readily determined from sources whose accuracy cannot

reasonably be questioned.” But “the consensus” among courts in this District is that we “typically

cannot take judicial notice of prior proceedings ‘for the purpose of accepting the truth of the earlier

court’s findings and conclusions.’” Sibley v. Islamic Republic of Iran, No. 23-cv-600, 2025 WL

1928036, at *15 (D.D.C. July 14, 2025) (quoting Rimkus v. Islamic Republic of Iran, 750 F. Supp.

2d 163, 171 (D.D.C. 2010)). That is especially so with respect to Cabrera’s findings of fact

because those findings were made on a motion for default judgment without “the full benefits of

adversarial litigation” and “thus lack the absolute certainty with which they might otherwise be

afforded.” Valore v. Islamic Republic of Iran, 700 F. Supp. 2d 52, 59 (D.D.C. 2010). Accordingly,

the court will not adopt Cabrera’s findings of fact.

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