Fraenkel v. Islamic Republic of Iran, No. 17-7100 (D.C. Cir. 2018)Annotate this Case
After sixteen-year-old Yaakov Naftali Fraenkel and two of his classmates were taken hostage and killed by members of Hamas, his family filed suit in district court against Iran and Syria under the terrorism exception to the Foreign Sovereign Immunities Act (FSIA), 28 U.S.C. 1605A. Plaintiffs alleged that defendants provided material support to Hamas. The district court eventually entered a default judgment for plaintiffs and plaintiffs challenged the amount of damages awarded to them. The DC Circuit rejected plaintiffs' claim that the district court erred in failing to determine the solatium damages awards in conformity with the remedial scheme established in Estate of Heiser v. Islamic Republic of Iran, 466 F. Supp. 2d 229 (D.D.C. 2006). The court held that Heiser was a useful reference point, but not binding precedent. The court further held that the district court abused its discretion in awarding solatium damages because its judgment was based on impermissible considerations and clearly erroneous findings of fact. Accordingly, the court reversed in part and remanded. The court affirmed the punitive damages and pain-and-suffering awards because the judgments with respect to those awards were consistent with the applicable law, adequately reasoned, and supported by the evidence.