Hammons v. Islamic Republic of Iran

CourtDistrict Court, District of Columbia
DecidedSeptember 25, 2023
DocketCivil Action No. 2019-2518
StatusPublished

This text of Hammons v. Islamic Republic of Iran (Hammons 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
Hammons v. Islamic Republic of Iran, (D.D.C. 2023).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

RYAN HAMMONS, et al.,

Plaintiffs,

v. Civil Action No. 1:19-cv-02518 (ACR)

ISLAMIC REPUBLIC OF IRAN,

Defendant.

NOREE KAMKONGKAEO, et al.,

v. Civil Action No. 1:20-cv-01058 (ACR)

MEMORANDUM OPINION AND ORDER

Plaintiffs in these consolidated cases are thirteen individuals injured in a 2016 terrorist

bombing at Camp Sullivan in Kabul, Afghanistan (“Camp Sullivan Resident Plaintiffs”), as well

as thirty-three of their immediate relatives (“Immediate Family Plaintiffs”). Plaintiffs sued the

Islamic Republic of Iran (“Iran”) under the Foreign Sovereign Immunities Act (“FSIA” or

“Act”), 28 U.S.C. §§ 1330, 1602-1611. They allege that Iran is liable for damages Plaintiffs

suffered because of the bombing because it provided explosive materials, financial support, safe

1 harbor, and training to the Taliban, the terrorist organization that carried out the attack. Dkt. 1 at

6-7;1 Case No. 1:20-cv-01058 (ACR), Dkt. 1 at 2-3.

After Iran failed to answer Plaintiffs’ Complaints or otherwise appear in these actions,

Plaintiffs moved for default judgment as to liability. Dkts. 18 and 23. The Court referred the

motions to Magistrate Judge Robin M. Meriweather for a Report and Recommendation. Minute

Order of July 16, 2020; Case No. 1:20-cv-01058 (ACR), Dkt. 16. On July 24, 2023, Judge

Meriweather recommended that the Court grant the motions with respect to twelve of the Camp

Sullivan Resident Plaintiffs and nine of the Immediate Family Plaintiffs. Dkt. 28 at 58-59

(Report and Recommendation). She recommended that the Court deny the motions without

prejudice with respect to one Camp Sullivan Resident Plaintiff and twenty-four Immediate

Family Plaintiffs who, Judge Meriweather concluded, had not provided adequate briefing or

evidence to establish their entitlement to relief. Id. at 39, 49-50, 58-59. Plaintiffs2 have objected

to the recommended denial of the motions with respect to twenty-three of the Immediate Family

Plaintiffs. Dkt. 30 (Objection). Iran has filed no objections and has not otherwise appeared in

these actions.

Upon consideration of the Report and Recommendation, the Objection, the applicable

law, and the entire record, the Court overrules the Objection and adopts the Report and

Recommendation in its entirety. Plaintiffs’ default judgment motions are GRANTED IN PART

1 Unless otherwise noted, citations to docket entries refer to filings in case number 1:19-cv- 02518 (ACR). 2 While the default judgment motions were pending, Plaintiffs’ counsel lost contact with and withdrew from representing Plaintiffs Jennifer and Robert Hernandez. Dkt. 21; Minute Order of June 22, 2022. As a result, the Hernandezes have not participated in filings made after the default judgment motions, including Plaintiffs’ Objection. See, e.g., Dkt. 30 at 1 n.1. References to actions taken by “Plaintiffs” after that time do not include the Hernandezes. 2 and DENIED IN PART without prejudice. The Court will appoint a special master to determine

the appropriate damages awards for those Plaintiffs with respect to whom the motions are

granted.

I. BACKGROUND

A. The FSIA

The FSIA is “the sole basis for obtaining jurisdiction over a foreign state in [U.S.]

courts.” Argentine Republic v. Amerada Hess Shipping Corp., 488 U.S. 428, 434 (1989). The

Act provides that foreign states ordinarily enjoy sovereign immunity from suits in U.S. courts,

see 28 U.S.C. § 1604, but also establishes several exceptions to that rule, see, e.g., id. §§ 1605-

1605B. One of these—the “state-sponsored terrorism exception”—strips foreign states of

sovereign immunity against, and grants federal courts subject matter jurisdiction to hear, certain

claims “against countries who have . . . supported specified acts of terrorism and who are

designated by the State Department as state sponsors of terror.” Opati v. Republic of Sudan, 140

S. Ct. 1601, 1605 (2020); see 28 U.S.C. §§ 1330(a), 1605A(a)(1). The Act also creates a federal

cause of action allowing certain categories of plaintiffs, including U.S. nationals, to seek money

damages from foreign states for “personal injury or death” arising from acts of terrorism covered

by the Act’s jurisdictional provisions. 28 U.S.C. § 1605A(c); see Opati, 140 S. Ct. at 1606.

Plaintiffs who are not eligible to pursue this cause of action—such as most non-U.S. nationals—

can still invoke the FSIA’s waiver of sovereign immunity and grant of subject matter jurisdiction

but must rely on state-law causes of action. See Owens v. Republic of Sudan, 924 F.3d 1256,

1258 (D.C. Cir. 2019).

3 B. The Camp Sullivan Attack

Camp Sullivan was a residential complex near Kabul International Airport in Afghanistan

that, as of January 2016, housed U.S. embassy personnel and private civilian contractors. Dkt.

28 at 7. On January 4, 2016, a truck carrying more than three thousand pounds of explosives

exploded outside Camp Sullivan, damaging the compound. Dkt. 19-6 at 3; Dkt. 28 at 7. Among

those injured in the blast were the Camp Sullivan Resident Plaintiffs—Andrew Babbitt; Bradley

Busby; Ryan Buytenhuys; Allen Cox; David Evans; Ryan Hammons; William Harris; Robert

Hernandez; Brandon Jones; Aaron Money; Robert Nadeau II; Derek Pleiman; and Dale Smith,

Jr.—who, at the time of the bombing, lived in Camp Sullivan or a neighboring residential

complex while working as private contractors for the U.S. government. Dkt. 28 at 7-8; see, e.g.,

Dkt. 22-2 at 1. The explosion also killed at least two Afghan civilians. Dkt. 26-1 at 1. The

Taliban claimed responsibility for the attack. Dkt. 19-1 at 4-5.

C. Plaintiffs’ Lawsuits

The Camp Sullivan Resident Plaintiffs and thirty-one of the Immediate Family Plaintiffs

(collectively, the “Hammons Plaintiffs”) filed the first Complaint in these consolidated cases on

August 20, 2019.3 Dkt. 1. The Camp Sullivan Resident Plaintiffs seek damages for both

physical and emotional injuries resulting from the bombing; the Immediate Family Plaintiffs

claim damages for “severe mental anguish and harm caused by the loss of [their loved ones’]

3 The Hammons Immediate Family Plaintiffs are Ashley Babbitt; Christi Babbitt; Lee Babbitt III; M.A.B.; M.L.B.; O.R.B.; Sylvia Babbitt; Adele Buytenhuys; Cameron Buytenhuys; Clinton Buytenhuys; Darroll Buytenhuys; E.B.; Sheldon Buytenhuys; Nicola Cubie; Tashia Evans; Andria Harris; Jennifer Hernandez; Rhett Money; A.L.N.; Miranda Nadeau; Robert Nadeau, Sr.; Erica Pleiman; Haley Schweickert; Jenna Schweickert; Taylor-Rae Simon; Alysandra Smith; Annie Smith; Bianca Smith; Dale Smith, Sr.; Gabrielle Smith; and I.M.S. Dkt. 1. The Complaint also lists two other plaintiffs who later voluntarily dismissed their claims. See Dkts. 15 and 20. 4 society and comfort” as a result of the attack. Id. at 17-33. The Hammons Plaintiffs seek to

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Related

Argentine Republic v. Amerada Hess Shipping Corp.
488 U.S. 428 (Supreme Court, 1989)
Aikens v. Shalala
956 F. Supp. 14 (District of Columbia, 1997)
Worley v. the Islamic Republic of Iran
75 F. Supp. 3d 311 (District of Columbia, 2014)
Republic of Sudan, Ministry of External Affairs v. James Owens
194 A.3d 38 (District of Columbia Court of Appeals, 2018)
James Owens v. Republic of Sudan
924 F.3d 1256 (D.C. Circuit, 2019)
Opati v. Republic of Sudan
590 U.S. 418 (Supreme Court, 2020)
Estate of Hirshfeld v. Islamic Republic of Iran
330 F. Supp. 3d 107 (D.C. Circuit, 2018)
Reed v. Islamic Republic of Iran
845 F. Supp. 2d 204 (District of Columbia, 2012)

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