Bakalian v. Central Bank of the Republic of Turkey, No. 13-55664 (9th Cir. 2019)
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The Ninth Circuit affirmed the district court's dismissal of claims brought in 2010 against the Republic of Turkey and two Turkish national banks, seeking compensation for property taken from plaintiffs' ancestors during the Armenian Genocide.
The panel affirmed the judgment of the district court, because plaintiffs' claims, filed almost a century after the Armenian Genocide, were time-barred. California previously adopted a statute in 2006 to provide that any limitations period for suits arising out of the Armenian Genocide would not expire until December 31, 2016. Under this statute, plaintiffs' claims were timely filed. However, the panel subsequently held that the California law was unconstitutional. Therefore, plaintiffs' claims were facially time-barred in the absence of the statute.
Court Description: Foreign Sovereign Immunities Act / Statute of. Limitations The panel affirmed the district court’s dismissal as time- barred of claims brought in 2010 against the Republic of Turkey and two Turkish national banks, seeking compensation for property taken from plaintiffs’ ancestors during the Armenian Genocide, which took place from 1915 to 1923. The court previously held unconstitutional a California statute providing that any limitations period for suits arising out of the Armenian Genocide would not expire until December 31, 2016. Applying California law, the panel held that, in the absence of the invalidated extension statute, plaintiffs’ claims, brought under the Foreign Sovereign Immunities Act, were barred by the statute of limitations for 4 BAKALIAN V. CENTRAL BANK OF TURKEY claims of genocide, war crimes, and crimes against humanity. The panel explained that, because plaintiffs’ claims were plainly time-barred, it did not address the substantial legal questions the case posed concerning FSIA jurisdiction.
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