Roeder v. Islamic Republic of Iran

For 444 days following the 1979 Iranian revolution, the newly declared Islamic Republic of Iran (Islamic Republic) (defendant) held a large group of Americans hostage. The Islamic Republic released the hostages only in 1981, after the president signed an executive agreement resolving several issues of concern to the Islamic Republic. The executive agreement immunized the Islamic Republic against any claims arising from the hostage crisis. After his release, David Roeder (plaintiff) filed a class-action federal lawsuit against the Islamic Republic, seeking damages on behalf of himself and other former hostages. The federal government intervened in the case, arguing that both the Foreign Sovereign Immunities Act (FSIA) and the 1981 executive agreement gave the Islamic Republic sovereign immunity against Roeder’s suit. Congress responded by amending the FSIA to the limited extent necessary to remove the FSIA as an obstacle to Roeder’s suit. Roeder cited a House and Senate conference report accompanying the FSIA amendment as proof that Congress also intended to abrogate the 1981 executive agreement so that Roeder’s suit could proceed. The district court ruled that although the conference report was part of the FSIA amendment’s legislative history, Congress never enacted the report into law, and therefore the report was insufficient to abrogate the executive agreement. Consequently, the district court ruled that the executive agreement’s sovereign-immunity clause barred Roeder from suing the Islamic Republic. Roeder appealed the district court’s dismissal of his suit to the District of Columbia Circuit.