Rusnak v. United States of America

District Court, District of Columbia·Decided August 14, 2026·No. Civil Action No. 2025-0292·Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

ELVIS RUSNAK, et al.,

Plaintiffs,

Civil Action No. 25 - 292 (LLA)

v.

UNITED STATES OF AMERICA, et al., Defendants.

GLENN TYLER CHRISTIE, et al.,

Plaintiffs,

Civil Action No. 25 - 932 (LLA)

v.

UNITED STATES OF AMERICA, et al., Defendants.

MEMORANDUM OPINION AND ORDER Plaintiffs in the above-captioned cases brought suit against the United States of America, the U.S. Department of Justice (“DOJ”), Acting Comptroller General Orice Williams Brown in her official capacity, and U.S. Victims of State Sponsored Terrorism Fund (“USVSSTF” or the “Fund”) Special Master Mary Patrice Brown in her official capacity, alleging that Defendants unlawfully withheld payments owed to them from the USVSSTF in violation of the Administrative Procedure Act (“APA”), 5 U.S.C. § 551 et seq., the Declaratory Judgment Act, 28 U.S.C. § 2201, and the Mandamus Act, 28 U.S.C. § 1361. Rusnak, ECF No. 1; Christie, ECF No. 1. In March 2026, this court granted Defendants’ consolidated motion to dismiss Plaintiffs’ complaints

and dismissed the cases. Rusnak, ECF Nos. 31, 32; Christie, ECF Nos. 26, 27. Plaintiffs have moved to alter or amend the court’s judgment and for leave to file an amended complaint. Rusnak, ECF No. 33; Christie, ECF No. 28. For the reasons explained below, the court denies Plaintiffs’ Rule 59(e) motions.

I. FACTUAL BACKGROUND AND PROCEDURAL HISTORY The court recounts the facts as described in its previous memorandum opinion. Rusnak, ECF No. 31; Christie, ECF No. 26 (“Mem. Op.”). The USVSSTF compensates those who have obtained judgments against foreign state sponsors of terrorism. See Justice for U.S. Victims of State Sponsored Terrorism Act, Pub. L. No. 114-113, § 404(b)(2)(B), (c), (j), 129 Stat. 3007, 3008-09, 3016-17 (2015) (codified at 34 U.S.C. § 20144). The Fund is administered by a Special Master, 34 U.S.C. § 20144(b)(1)(A), who is tasked with “specifying the procedures necessary for United States persons to apply and establish eligibility for payment,” id. § 20144(b)(2)(A). “All decisions made by the Special Master with regard to compensation from the Fund [are] . . . not subject to . . . judicial review.” Id. § 20144(b)(3)(B).

On December 29, 2022, Congress enacted the Fairness for 9/11 Families Act (the “Fairness Act”), which, as relevant here, authorized lump sum catch-up payments for victims of the 1983 Beirut barracks and 1996 Khobar Towers bombings to ensure that these victims would receive an equal share of payments as other non-9/11 victims. See Fairness for 9/11 Families Act, Pub. L. No. 117-328, § 101(b)(3)(B), 136 Stat. 6106, 6108-09 (2022). Congress established a reserve fund within the USVSSTF for the allocation of these lump sum catch-up payments and directed the Comptroller General to calculate the amount of payments for Beirut barracks and Khobar Towers bombing victims. See id. Specifically, Congress required the Comptroller General to “conduct an audit and publish in the Federal Register a notice of proposed lump sum catch-up payments to the

1983 Beirut barracks bombing victims and the 1996 Khobar Towers bombing victims who have submitted applications [for payment from the Fund] on or after [the December 29, 2022] date of enactment.” Id. § 101(b)(3)(B)(iii), 136 Stat. at 6108. Following a public comment period, the Comptroller General was required to submit “a report that includes [her] determination . . . [on] the amount of the proposed lump sum catch-up payment for each 1983 Beirut barracks bombing victim” and “each 1996 Khobar Towers bombing victim.” Id. Congress then directed the Special Master to “authorize lump sum catch-up payments from the reserve fund . . . in amounts equal to the amounts described in [the Comptroller General’s report].” Id. (providing that the Special Master “shall authorize” such payments “[n]ot earlier than 90 days after the date on which the Comptroller General submits the report” but “not later than 1 year after such date”). The Fairness Act also changed the application period for victims of the Beirut barracks and Khobar Towers bombings to submit applications for payment from the Fund, setting a deadline of “180 days from the [December 29, 2022] date of enactment”—June 27, 2023. Id. § 101(b)(2), 136 Stat. at 6106-07. It further provided that, within thirty days after the date of enactment, “the Special Master shall update, as necessary as a result of the enactment of such Act, such procedures and other guidance previously issued by the Special Master.” Id. § 101(b)(1)(B), 136 Stat. at 6106.

The USVSSTF permits individuals to submit one application for each claim. Rusnak, ECF No. 1 ¶ 45; Christie, ECF No. 1 ¶ 47; see Justice for United States Victims of State Sponsored Terrorism Act, 81 Fed. Reg. 45535, 45537 (July 14, 2016) (“Only one application may be submitted for each claim.”). The Special Master did not change the procedures for applying to the Fund following the enactment of the Fairness Act. Rusnak, ECF No. 1 ¶ 46; Christie, ECF No. 1 ¶ 48; see Rusnak, ECF No. 25-3, at 13. In December 2023, the Government Accountability Office (“GAO”) published its first notice in the Federal Register proposing its methodology for

calculating lump sum catch-up payments for victims of the Beirut barracks and Khobar Towers bombings. Rusnak, ECF No. 1-7, at 3; Christie, ECF No. 1 ¶ 25; see Notice of Planned Methodology for Estimating Lump Sum Catch-Up Payments to Eligible 1983 Beirut Barracks Bombing Victims and 1996 Khobar Towers Bombing Victims, 88 Fed. Reg. 89693 (Dec. 28, 2023). GAO published a second notice in July 2024, which interpreted the Fairness Act as directing the Comptroller General to calculate lump sum catch-up payments for only those victims who had “submitted an application during the 180-day period from the date of enactment of the Fairness Act.” Notice of Estimated Lump Sum Catch-Up Payments to Eligible 1983 Beirut Barracks Bombing Victims and 1996 Khobar Towers Bombing Victims and Planned Methodology, 89 Fed. Reg. 56376, 56379 n.33 (July 9, 2024). GAO’s second notice also stated that, in February 2023, the Special Master had added guidance to the Fund website’s “Frequently Asked Questions” section stating that claimants who had previously been found eligible for the Fund were not eligible to receive lump sum catch-up payments. Id. at 56378 n.29. GAO subsequently provided a draft report of its catch-up payment calculations to DOJ, which disagreed with GAO’s approach. Rusnak, ECF No. 1 ¶ 5; Christie, ECF No. 1 ¶¶ 35-36; see Rusnak, ECF No. 25-2.1 Specifically, DOJ objected to GAO’s position that claimants who had already been deemed eligible for the Fund were required to submit a duplicate, or successive, application during the Fairness Act’s 180-day application window. See Rusnak, ECF No. 25-2, at 6-7.

In November 2024, GAO submitted its final report to Congress and the Special Master, maintaining the positions outlined in its draft report. Rusnak, ECF No. 25-3; see generally U.S. Gov’t Accountability Off., GAO-25-107564, U.S. Victims of State Sponsored Terrorism Fund:

1 When citing Rusnak, ECF No. 25-2, the court refers to the CM/ECF-generated page numbers at the top of each page rather than any internal pagination.

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