Karcher v. Islamic Republic of Iran

District Court, District of Columbia·Decided June 3, 2026·No. Civil Action No. 2016-0232·Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

TIMOTHY KARCHER, et al., Plaintiffs, Civil Action No. 16-232 (CKK) v. ISLAMIC REPUBLIC OF IRAN, Defendant.

MEMORANDUM OPINION (June 3, 2026)

Pursuant to the Foreign Sovereign Immunities Act (“FSIA”), on February 12, 2016, over

300 Plaintiffs filed this lawsuit against Defendant Islamic Republic of Iran (“Iran”). The three-

count Amended Complaint in this action seeks relief with reference to United States nationals

and/or United States servicemembers who were injured or killed by Iran and/or its agents in Iraq,

during the period of 2004 through 2011. Such relief is sought on behalf of surviving victims, the

estates of victims who were killed, and the family members of both. See Am. Compl., ECF No.

8, ¶¶ 1161–74.

The Court previously held a bench trial addressing Iran’s liability for some of Plaintiffs’

claims derived from seven “bellwether” attacks involving Iran, where six such attacks involved

Iranian-manufactured explosively formed penetrators (“EFPs”). Following that bench trial, on

August 26, 2019, this Court made findings of fact and conclusions of law pertaining to Iran’s

liability arising out of these bellwether attacks, which included a template for the future assessment

of Plaintiffs’ remaining claims, including those attacks involving EFPs. Karcher v. Islamic

Republic of Iran, 396 F. Supp. 3d 12 (D.D.C. 2019). Then, on September 9, 2019, the Court

appointed Special Master Alan Balaran to administer damages proceedings for the bellwether

Plaintiffs. Order and Administrative Plan, ECF No. 102.

1 On January 14, 2021, this Court found Iran responsible for an additional 73 EFP attacks,

which implicated the claims of: (1) eight Plaintiffs who were personally injured in one of the

attacks, (2) thirty-four Plaintiffs representing the estates of individuals killed in one of the attacks,

and (3) two-hundred and twenty-seven (227) Plaintiffs seeking solatium damages as a family

member of a victim of one of the attacks. Karcher v. Islamic Republic of Iran, Civil Action No.

16-232, 2021 WL 133507 (D.D.C. Jan. 14, 2021). The Court granted default judgment on liability

against Iran on the claims of the eight Plaintiffs personally injured in one of the non-bellwether

attacks, and the thirty-four Plaintiffs representing the estates of individuals killed by one of those

attacks but did not – at that time – make any ruling regarding the damage claims of the 227 “family-

member” Plaintiffs, which arose out of the seventy-three non-bellwether attacks. On January 14,

2021, the Court issued an Order broadening the scope of Special Master Balaran’s appointment to

include recommended findings of fact and conclusions of law regarding non-economic damages

for the eight Plaintiffs injured in the non-bellwether EFP attacks. Order, ECF No. 125.

Special Master Balaran’s recommended damages were largely adopted by this Court in its

December 7, 2023 Memorandum Opinion, which incorporated the Plaintiff’s amendments and

corrections to the Special Master’s Report and Recommendation. Those damages related to four

Plaintiffs who were injured in attacks not involving EFPs, as well as damages for conscious pain

and suffering for three estate Plaintiffs, economic damages, and solatium damages. Memorandum

Opinion, ECF No. 159; Order and Judgment, ECF No. 160. Separately thereafter, Special Master

Balaran developed – and this Court approved – a modified template for the award of damages in

cases in which EFPs were utilized. See generally June 7, 2024 Memorandum Opinion, ECF No.

171 (addressing the damages in the modified Report and Recommendation, to which Plaintiffs did

2 not object, and adopting the analysis and damage calculation for the five Plaintiffs addressed

therein); Order and Judgment, ECF No. 172.

Subsequently, the Court referred the remaining claims by Plaintiffs – for whom a liability

determination had been made and the Borochov “standard” was met – and by Plaintiff family

members – who were claiming a loss of solatium – for determination of damages by four additional

Special Masters. See Order and Administrative Plan Governing Four Additional Special Masters,

ECF No. 179 (indicating that the Special Master would also address Plaintiffs’ statutory standing

under 28 U.S.C. § 1605A(c)). The Borochov “standard” refers to a March 2024 decision by the

United States Court of Appeals for the District of Columbia Circuit (the “D.C. Circuit”), in an

FSIA case, whereby the D.C. Circuit concluded that there was no subject matter jurisdiction,

pursuant to Section 1605A, where “the perpetrator did not kill anyone in the attack that injured the

[Plaintiffs], [and therefore] no extrajudicial killing occurred.” Borochov v. Islamic Republic of

Iran, 94 F.4th 1053, 1060 (D.C. Cir. 2024). Furthermore, the D.C. Circuit opined that “Section

1605A’s test does not support expanding the material-support provision to cover attempted but

uncompleted extrajudicial killings,” id. at 1063.1

Following rolling receipt and review by the Court of multiple Reports and

Recommendations submitted by those four Special Masters, this Court adopted those Reports and

Recommendations in a multitude of opinions and issued Orders and Judgments on damages. See

generally ECF Nos. 197, 205, 225, 237, 242, 245, 254, and 281 (Orders and Judgments).

Now pending before this Court is Plaintiffs’ [142] Submission of Eleven Attacks Not Yet

Adjudicated (“Submission”). Plaintiffs request that this Court find Iran responsible for an

additional ten attacks, which implicate the claims of: (1) two Plaintiffs who were personally injured

1 This ruling contrasted with the approach taken previously by judges from this District. 3 in one of the attacks (2) two Plaintiffs representing the estates of individuals killed in one of the

attacks, and (3) thirty-five Plaintiffs seeking solatium damages as a family member of a victim of

one of the attacks. See Status Report, ECF No. 141; see also List of the 41 Plaintiffs in Response

to the Court’s February 21, 2025 Minute Order (“List”), ECF No. 202.2 Plaintiffs’ Submission

initially addressed eleven attacks and forty-one Plaintiffs; however, after filing it, Plaintiffs

requested that this Court hold in abeyance a liability ruling regarding the March 30, 2008 attack

[which implicates claims by two Plaintiffs]. . . until further legal and factual issues resulting from

the Borochov decision are resolved.” See Plaintiffs’ Notice of New Authority, ECF No. 165, at 5.

Accordingly, this Memorandum Opinion addresses Iran’s liability for ten attacks, which

implicates claims by thirty-nine Plaintiffs. Consistent with prior procedures in this case, once

liability is established, the damage determinations for these Plaintiffs shall be handled by the

appointed Special Masters.

I. BACKGROUND

This Court incorporates by reference its prior opinions on liability. In summarizing

proceedings leading up to the present decision, the Court will reiterate extensively from those

2 The two Plaintiffs who were injured are George D. White and John McCulley. The estate claims relate to Plaintiff Estate of Steven Vincent and Plaintiff Estate of Jeffery Hartley.

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