Muna Al-Suyid, et al. v. Khalifa Hifter

CourtDistrict Court, E.D. Virginia
DecidedApril 9, 2026
Docket1:20-cv-00170
StatusUnknown

This text of Muna Al-Suyid, et al. v. Khalifa Hifter (Muna Al-Suyid, et al. v. Khalifa Hifter) is published on Counsel Stack Legal Research, covering District Court, E.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Muna Al-Suyid, et al. v. Khalifa Hifter, (E.D. Va. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division MUNA AL-SUYID, et al., ) Plaintiffs, v. 1:20-cv-170 (LMB/JFA) KHALIFA HIFTER, Defendant. MEMORANDUM OPINION This civil action arose from a period of armed conflict in Libya in which warring militia groups attempted to gain control of the country’s central government. Plaintiffs Ibrahim al- Krshiny (“Ibrahim”), Abdalla al-Krshiny (“Abdalla”), Ahmad al-Krshiny (“Ahmad”), and Mahmud al-Krshiny (“Mahmud”) are citizens and residents of Libya who have asserted claims pursuant to the Torture Victim Protection Act (“TVPA”) against defendant Khalifa Hifter (“Hifter”), the Field Marshal of the Libyan National Army (“LNA”). Specifically, plaintiffs allege that Hifter used his leadership role within the LNA to authorize the torture of plaintiffs and the indiscriminate killings of their family members in the fall of 2014. Hifter has filed a Motion for Summary Judgment (“Motion”), which the Court granted after oral argument. This Memorandum Opinion expands upon the oral ruling that granted Hifter’s Motion. I. The TVPA was added to the Alien Tort Statute in 1991 “to authorize a federal statutory cause of action on behalf of victims or their representatives for acts of torture or extrajudicial killings.”' Fisher v. Great Socialist People’s Libyan Arab Jamahiriya, 541 F. Supp. 2d 46, 54

! The Torture Victim Protection Act of 1991, Pub. L. No. 102-256, 106 Stat. 73, is codified at the note following the Alien Tort Statute, 28 U.S.C. § 1350.

(D.D.C. 2008). “The purpose of the statute, as stated by both the House and Senate reports, is to unambiguously provide a federal cause of action against the perpetrators of such abuse, as well

as to extend a civil remedy to U.S. citizens who may have been tortured abroad.” Doe v. Qi, 349 F. Supp. 2d 1258, 1279 (N.D. Cal. 2004). Section 2(a) provides: (a) Liability. An individual who, under actual or apparent authority, or color of law, of any foreign nation— (1) subjects an individual to torture shall, in a civil action, be liable for damages to that individual; or (2) subjects an individual to extrajudicial killing shall, in a civil action, be liable for damages to the individual’s legal representative, or to any person who may be a claimant in an action for wrongful death. This provision creates two categories of claims. Section 2(a)(1) creates a cause of action for individuals who themselves are subjected to torture. Section 2(a)(2) creates a cause of action for the legal representatives of individuals who have been subjected to an extrajudicial killing, or for any person who may be the claimant in a wrongful death action on behalf of a victim of an extrajudicial killing. Il. On February 18, 2020, plaintiffs Ibrahim, Abdalla, Ahmad, and Mahmud—along with plaintiff Muna al-Suyid (“Muna”), whose claims have since been dismissed—filed this civil action against defendant Hifter.? [Dkt. No. 1]. Each plaintiff asserted a claim under TVPA § 2(a)(1), alleging that Hifter’s forces subjected them to torture. Id. {J 9-11. Plaintiffs Muna and Ibrahim also asserted claims under TVPA § 2(a)(2), which were premised on the alleged extrajudicial killings of their family members. Id. {Jj 9-10. Relevant here, the Complaint alleges that on October 17, 2014, Hifter’s forces “attacked

2 The original Complaint also named defendants Khalid Hifter and Saddam Hifter, but they were dismissed from this civil action on September 29, 2020. [Dkt. No. 52].

the al-Krshiny family home in Benghazi,” at which time the “home was taken under fire by the LNA, and a gunfight ensued.” Id, 36. Ibrahim was subsequently taken prisoner by Hifter’s forces; falsely accused of being a member of the Islamic State; detained at the LNA’s barracks; and subjected to multiple forms of torture, including being stripped, bound, and beaten with fists, pipes, cables, a broom handle, and a plastic hose. Id. {] 37-40. The Complaint also claims that Ibrahim was “forced to stand in water and be painfully electrocuted, for five minutes at a time, for approximately seven and a half hours” and that he was “blindfolded, driven into a forest, and told to walk forward and not look back until he reached a road in the distance.” Id. {9 41-42. As for plaintiffs Abdalla, Ahmad, and Mahmud, the Complaint alleges that they were detained, brought in a truck to an LNA camp, and wounded after LNA forces opened fire on the truck. Id. 4 45. On April 12, 2024, the Court entered an Order granting in part defendant’s original Motion for Summary Judgment, finding a lack of personal jurisdiction over Hifter. [Dkt. No. 296] at 2. The Fourth Circuit reversed, holding that “the district court erred in granting summary judgment to Hifter based on lack of personal jurisdiction because Hifter waived any such defense by failing to raise it in his pre-answer motions to dismiss.” al-Suyid v. Hifter, 139 F.4th 368, 373 (4th Cir. 2025). The Fourth Circuit remanded the action “without considering the alternative grounds for affirmance that Hifter offer[ed].” Id. at 374-75. On September 5, 2025, this Court held a status conference to set deadlines for summary judgment briefing. [Dkt. No. 320]. On November 4, 2025, Hifter timely filed a renewed Motion for Summary Judgment, which contained several arguments, including that plaintiffs lacked sufficient evidence to demonstrate that Hifter was acting under color of law; that Hifter was not properly served; that he was entitled to head-of-state immunity; that plaintiffs failed to exhaust the remedies available to them in Libya; and that there was insufficient evidence of command responsibility to support

liability. [Dkt. No. 329] at 13-30. On November 7, 2025, the Court scheduled oral argument on Hifter’s Motion for January 9, 2026. [Dkt. No. 327]. Plaintiffs subsequently filed an opposition to the Motion, [Dkt. No. 331], and Hifter filed a reply, [Dkt. No. 332]. Importantly, in Section F of his reply brief, Hifter argued for the first time that there was no evidence in the record showing that plaintiffs were subjected to torture within the meaning of the TVPA. Id. at 17-18. Although a claim under § 2(a)(1) cannot proceed without evidence of torture, plaintiffs did not seek leave to file a surreply to respond to Hifter’s contention. On January 8, 2026, one day before the January 9, 2026 oral argument, the Court entered an Order dismissing without prejudice Muna’s § 2(a)(1) and § 2(a)(2) claims and Ibrahim’s § 2(a)(2) claim. [Dkt. No. 333] at 8. The Order explained that both Muna and Ibrahim lacked standing to sue under § 2(a)(2) because there was insufficient evidence in the record to establish that they were the legal representatives of their deceased family members or that they could have qualified as claimants in a wrongful death action under Virginia state law. Id. at 5. The Order also explained that there was absolutely no evidence in the record—or allegations in the Complaint—indicating that Muna had been subjected to torture. Id. at 4. Finally, the Order made clear that the Court would hear oral argument as scheduled on January 9, 2026 “on defendant’s Motion for Summary Judgment as it relates to the claims and plaintiffs remaining in this civil action—namely, the individual claims under TVPA § 2(a)(1) brought by Ibrahim al- Krshiny, Abdalla al-Krshiny, Ahmad al-Krshiny, and Mahmud al-Krshiny.” Id. at 8. On January 9, 2026, the Court held oral argument, but plaintiffs’ counsel did not appear. [Dkt. No. 334].

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Bluebook (online)
Muna Al-Suyid, et al. v. Khalifa Hifter, Counsel Stack Legal Research, https://law.counselstack.com/opinion/muna-al-suyid-et-al-v-khalifa-hifter-vaed-2026.