William Lee, et al. v. Islamic Republic of Iran

Summary

The United States District Court for the District of Columbia adopts a Special Master's recommendation awarding Petra Spialek $2.5 million in compensatory solatium damages and $5 million in punitive damages arising from injuries suffered by her son, Second Lieutenant Terrance Peterson III, in an attack in Iraq. The court finds that Spialek satisfies the Foreign Sovereign Immunities Act's nationality and immediate-family requirements and retains subject matter jurisdiction over her claim.

Holdings

1. Spialek satisfied the FSIA's nationality and immediate-family requirements because she established that she was a United States national and the mother of the injured victim.
2. The court retained subject matter jurisdiction over claims arising from nonlethal injuries sustained during an act of extrajudicial killing.
3. Spialek was entitled to $2.5 million in compensatory solatium damages for the injuries suffered by her surviving son.
4. Spialek was entitled to $5 million in punitive damages, calculated as twice her compensatory damages award.

Questions Presented

1. Whether Petra Spialek satisfied the Foreign Sovereign Immunities Act's nationality and immediate-family requirements for a solatium claim.
2. Whether the court retained subject matter jurisdiction over claims arising from nonlethal injuries inflicted by an act of extrajudicial killing.
3. Whether Petra Spialek should receive $2.5 million in compensatory solatium damages and $5 million in punitive damages.

Disposition

approved