Sabbithi v. Al Saleh

CourtDistrict Court, District of Columbia
DecidedMarch 20, 2009
DocketCivil Action No. 2007-0115
StatusPublished

This text of Sabbithi v. Al Saleh (Sabbithi v. Al Saleh) 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
Sabbithi v. Al Saleh, (D.D.C. 2009).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

) MANI KUMARI SABBITHI, et al., ) ) Plaintiffs, ) ) Civil Action No. 07-115 (EGS) v. ) ) MAJOR WALEED KH N.S. AL SALEH, ) et al., ) ) Defendants. ) )

MEMORANDUM OPINION

Plaintiffs Mani Kumari Sabbithi, Joaquina Quadros, and Gila

Sixtina Fernandes, domestic workers from India, bring this action

against their former employers Major Waleed KH N.S. Al Saleh, his

wife, Maysaa KH A.O.A. Al Omar, (together “defendants”), and the

State of Kuwait.1 Plaintiffs bring suit under the Trafficking

Victims Protection Act of 2000 (“TVPA”), 18 U.S.C. § 1581, et

seq., the Fair Labor Standards Act, 29 U.S.C. §§ 201, et seq.,

and assert various contract and tort claims.2 Before this Court

1 Kuwait is a foreign state as defined in 28 U.S.C. § 1602, et seq. (the Foreign Sovereign Immunities Act of 1976). Compl. ¶ 11. Plaintiffs assert that Kuwait is liable for materially and practically assisting the defendants in the alleged offenses. Plaintiffs also seek to hold Kuwait liable under an agency theory for the actions of its employee, Defendant Al Saleh, and his wife, Defendant Al Omar. Id. ¶ 3. Kuwait is not a party to defendants’ motion to dismiss. See Mot. to Dismiss at 1. 2 Plaintiffs claim breach of contract; quantum merit; unjust enrichment; fraud and constructive fraud; false imprisonment; intentional infliction of emotional distress; negligent infliction of emotional distress; assault; battery; and civil is the defendants’ motion to dismiss the complaint and quash

service of process based on diplomatic immunity. Upon

consideration of the motion, the responses and replies thereto,

the amici curiae brief and response thereto, the Statement of the

United States and responses thereto, and the applicable law, the

Court GRANTS defendants Al Saleh and Al Omar’s motion to dismiss

and quashes service of process as to those defendants.

I. BACKGROUND

Defendant Major Waleed KH N.S. Al Saleh is a Kuwaiti

diplomat. Al Saleh and his wife, defendant Maysaa KH A.O.A. Al

Omar, lived in the United States from 2005 to 2007, while Al

Saleh served as Attaché to the Embassy of Kuwait. See Compl. ¶

9; see also Pls.’ Sur-rep. 2. Prior to moving to the United

States, the defendants employed plaintiffs as domestic workers in

the defendants’ home in Kuwait. The individual plaintiffs worked

for the defendants in Kuwait for a period ranging from five and a

half years to eight and a half months. See Compl. ¶¶ 16-46. In

Kuwait, plaintiffs allegedly worked seven days a week, for long

hours each day, and were paid between 35 Kuwaiti Dinar (KD)

(approximately $121 U.S. dollars) and 40 KD (approximately $138

U.S. dollars) per month. Id. According to plaintiffs, however,

before coming to the United States the defendants signed an

conspiracy.

2 employment contract promising to pay plaintiffs $1,314 U.S.

dollars per month and agreeing to comply with United States labor

laws in exchange for plaintiffs’ domestic work in the defendants’

home in the United States. Id. Plaintiffs assert that these

employment contracts were presented to the United States Embassy

in Kuwait for the purpose of obtaining plaintiffs’ A-3 visas,

which authorized plaintiffs to work as live-in domestic servants

in defendants’ home in McLean, Virginia. Id.

Plaintiffs claim that once in the United States, the

defendants did not comply with the terms of the employment

contracts. Allegedly, plaintiffs worked sixteen to nineteen

hours per day, seven days a week, and were not paid directly, but

instead defendants sent wages of 70 KD (approximately $242 U.S.

dollars) to 100 KD (approximately $346 U.S. dollars) per month to

plaintiffs’ families overseas. See id. ¶¶ 47-93. Plaintiffs

allege that the defendants deprived them of their passports,

threatened plaintiffs with physical harm, and physically abused

Sabbithi. Id.

Plaintiffs eventually escaped the defendants’ home, and, on

January 18, 2007, plaintiffs filed this complaint against

defendants and the State of Kuwait. In addition to this civil

action, plaintiffs pursued criminal charges against the

defendants through the U.S. Department of Justice (“DOJ”).

Pursuant to the DOJ’s request, the U.S. Department of State

3 (“State Department”) asked the State of Kuwait to waive the

defendants’ diplomatic immunity. Pls.’ Sur-rep. Ex. A.

According to the State Department, Kuwait declined to waive the

defendants’ immunity. Id. As a result, the DOJ closed its

investigation into defendants’ alleged illegal conduct. Id.

On July 18, 2007, the Court granted Break the Chain

Campaign, Casa of Maryland, Inc., Asian American Legal Defense

and Education Fund, Global Rights, and Boat People SOS, Inc.

leave to file as amici curiae a memorandum of law in support of

plaintiffs' opposition to the defendants' Motion to Dismiss and

Quash Service of Process. On March 20, 2008, this Court invited

the State Department to submit its views regarding this case.

The State Department responded on July 22, 2008.

II. DISCUSSION

A. Diplomatic Immunity

This Court has subject matter jurisdiction over this action

pursuant to 28 U.S.C. § 1351, which states that district courts

“have original jurisdiction, exclusive of the courts of the

States, of all civil actions and proceedings against . . .

members of a mission or members of their families (as such terms

are defined in section 2 of the Diplomatic Relations Act).” 28

U.S.C. § 1351(2); see also Gonzalez Paredes v. Vila, 479 F. Supp.

2d 187, 191 (D.D.C. 2007).

4 Defendants argue that they have diplomatic immunity, and

that their immunity deprives this Court of jurisdiction in this

case, pursuant to the Vienna Convention on Diplomatic Relations

(“the Vienna Convention,” “Convention” or “VCDR”), to which both

Kuwait and the United States are parties. The Vienna Convention

provides that a “diplomatic agent shall . . . enjoy immunity from

[the receiving state's] civil and administrative jurisdiction. .

. .” VCDR, Article 31(1). The Convention further provides that

the “members of the family of a diplomatic agent forming part of

his household shall, if they are not nationals of the receiving

State, enjoy the privileges and immunities specified in Articles

29 to 36.” VCDR, Article 37. The Vienna Convention also

provides that a diplomatic agent “shall not in the receiving

State practice for personal profit any professional or commercial

activity.” VCDR, Article 42. Diplomatic immunity can be

forfeited “in the case of . . . an action relating to any

professional or commercial activity exercised by the diplomatic

agent in the receiving State outside his official functions.”

Id.; see also Article 32(3).

In accordance with the Vienna Convention, Congress enacted

22 U.S.C. § 254d

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