Ministry of Defense and Support for Armed Forces of Islamic Republic of Iran v. Elahi, 546 U.S. 450 (2006)
Primary Holding
The Foreign Sovereign Immunities Act does not provide an exception for the attachment of property owned by a foreign state itself based on engagement in commercial activity; such an exception applies only to the property of an "agency or instrumentality" of a foreign state.
In the case of *Ministry of Defense and Support for Armed Forces of Islamic Republic of Iran v. Elahi*, a private citizen tried to claim money from Iran's Ministry of Defense to satisfy a judgment for damages related to his brother's murder. The Supreme Court ruled that the law protecting foreign governments from being sued does not allow for seizing property owned directly by the government, even if they are involved in commercial activities. This case is important for consumers because it clarifies that individuals cannot easily go after a foreign government's property to collect debts, which affects how people can seek justice and compensation in international disputes. If someone is in a situation where they want to claim damages from a foreign government, this case shows that it may be difficult to access their assets directly.
AI-generated plain-language summary to help you understand this case
In the case of *Ministry of Defense and Support for Armed Forces of Islamic Republic of Iran v. Elahi*, the underlying dispute arose from a default judgment obtained by private citizen Dariush Elahi against the Islamic Republic of Iran for approximately $300 million. This judgment was based on claims that the Iranian government was responsible for the murder of Elahi's brother. To satisfy this judgment, Elahi sought to attach an asset belonging to Iran’s Ministry of Defense, specifically an arbitration award that the Ministry had secured in Switzerland against a third party. The procedural history began when the Ministry of Defense petitioned the Federal District Court for the Southern District of California to confirm the arbitration award. Elahi intervened in this case, aiming to impose a lien on the award to satisfy his judgment. The Ministry contended that the Foreign Sovereign Immunities Act (FSIA) provided it immunity from such attachment. The District Court initially rejected this immunity claim, ruling that the Ministry had waived its immunity by seeking to enforce the award. However, the Ninth Circuit Court of Appeals disagreed regarding the waiver but ultimately ruled against the Ministry on different grounds, concluding that the Ministry was engaged in commercial activity in the United States, which negated its immunity under the FSIA. The case reached the Supreme Court after the Ministry filed a petition for certiorari, which the Solicitor General supported, focusing on whether the property of a foreign state is immune from attachment under the FSIA. The Supreme Court's review was limited to the question of whether the Ministry should be classified as a "foreign state" or as an "agency or instrumentality" of a foreign state, which would affect the applicability of the FSIA's provisions regarding immunity from attachment.
Whether the property of a foreign state situated in the United States is immune from attachment under the Foreign Sovereign Immunities Act.
The judgment of the Ninth Circuit is vacated, and the case is remanded for further proceedings consistent with this opinion.
- Court
- Supreme Court
- Decision Date
- February 21, 2006
- Jurisdiction
- federal
- Case Type
- landmark
- Damages Awarded
- N/A
- Data Quality
- high
Will v. Hallock, 546 U.S. 345 (2006)
Consumer LostThe refusal to apply the judgment bar of the Federal Tort Claims Act is not subject to collateral appeal, as it does not constitute a final decision under 28 U.S.C. §1291.
United States v. Olson, 546 U.S. 43 (2005)
Mixed OutcomeThe Federal Tort Claims Act (FTCA) waives sovereign immunity only in circumstances where the United States would be liable as a "private person" under local law, not based on the liability of state or municipal entities.
San Remo Hotel, L. P. v. City and County of San Francisco, 545 U.S. 323 (2005)
Consumer LostFederal courts cannot create an exception to the full faith and credit statute, 28 U.S.C. §1738, for claims brought under the Takings Clause of the Fifth Amendment, thereby affirming that state court decisions on takings claims must be respected in federal court.
Medellín v. Dretke, 544 U.S. 660 (2005)
Consumer LostA federal court is not bound by the International Court of Justice's ruling regarding the reconsideration of claims under the Vienna Convention on Consular Relations, and procedural default doctrines may apply to such claims in U.S. courts.