Saltany v. Reagan case brief

Saltany v. Reagan case brief summary
886 F.2d 438 (D.C. Cir. 1989)

CASE SYNOPSIS

Appellants, Libyan citizens and residents, challenged a judgment of the United States District Court for the District of Columbia dismissing appellants' claims against appellees seeking damages for injuries, death, and property loss sustained in an air strike against their country. Appellees moved for summary affirmance. Appellee United Kingdom (U.K.) cross-appealed from decision denying sanctions and sought attorney fees and costs.

CASE FACTS
Appellants sought damages from appellees, the U.S., the President of the U.S., senior civilian and military officials, the U.K., and the U.K. Prime Minister, for injuries, death, and property loss sustained in a U.S. air strike on Libya. The court of appeals affirmed the district court's decision dismissing appellants' claims.

DISCUSSION

• The appellate court reversed and remanded the district court's decision denying Rule 11 sanctions and granted appellee U.K.'s motion for attorney fees and costs on the frivolous appeal. 
• The court did not see how filing a complaint that appellants' attorneys surely knew had no hope whatsoever of success could be anything but a Rule 11 violation. 
• It was not a federal court's proper function to serve as a forum for "protests," to the detriment of parties with serious disputes. 
• Appellants failed to identify any international agreement that "expressly conflicted" with the Foreign Sovereign Immunities Act, thus failing to establish any basis for jurisdiction in U.S. courts.

CONCLUSION
The decision dismissing appellants' claims was affirmed, the decision denying Rule 11 sanctions was reversed, and appellee's motion for attorney fees and costs on frivolous appeal was granted.


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