nationals on board.”).
Iraq, 97 F. Supp. 2d 38 (D.D.C. 2000), the court exercised
jurisdiction over Iraq (then designated a state sponsor of
terrorism) for conduct within the Terrorism Exception.
court reasoned that the abuse of the American plaintiffs
“had a direct effect in the United States and was
consciously designed to affect United States policy.
the circumstances, Iraq cannot now claim surprise at the
assertion of jurisdiction by this Court over claims brought
Finally, in Daliberti v. Republic of
in response to its actions.”
Id. at 54.
The plaintiffs do not allege that the Four Princes
directed the September 11 attacks or commanded an agent (or
authorized al Qaeda) to commit them.
at 790 (affirming that court could exercise personal over
“primary participants in an alleged wrongdoing intentionally
directed at a California resident” (emphasis added)).
Rather, the plaintiffs rely on a causal chain to argue a
concerted action theory of liability: the Princes supported
Muslim charities knowing that their money would be diverted
to al Qaeda, which then used the money to finance the
September 11 attacks.
472, 478 (D.C. Cir. 1983) (distinguishing between civil
Cf. Calder, 465 U.S.
Cf. Halberstam v. Welch, 705 F.2d
United States Court of Appeals for the Second Circuit: In Re Terrorist Attacks