## Facts

- In November 1979, militants seized the U.S. Embassy in Tehran and held American diplomats and others hostage for 444 days, releasing them in January 1981.
- The United States and Iran resolved the crisis through executive agreements known as the Algiers Accords.
- Under the Accords, the United States committed to terminate and bar U.S.-court claims by U.S. nationals against Iran arising from the hostage crisis.
- Earlier hostage-related civil suits against Iran were dismissed because Iran retained sovereign immunity under the Foreign Sovereign Immunities Act (FSIA) absent a statutory exception.
- In 1996, Congress enacted the Antiterrorism and Effective Death Penalty Act and the FSIA terrorism exception (then codified at § 1605(a)(7)), along with the Flatow Amendment, which plaintiffs argued supplied substantive liability for terrorism-related harms.
- Former hostages and their family members filed a class action seeking roughly $33 billion in damages against Iran and its Ministry of Foreign Affairs.
- While the case was pending, Congress enacted a narrowly targeted 2002 appropriations provision referencing the lawsuit; plaintiffs argued it removed immunity and permitted their claims despite the Accords.

## Issues

1. Whether later terrorism-related legislation, including a provision directed at the pending suit, displaced the Algiers Accords’ bar on hostage-crisis claims and permitted the action to proceed.
2. Whether legislative history (including a conference report) can abrogate or modify U.S. obligations under an international executive agreement when the enacted statutory text does not expressly do so.
3. Whether, absent a clear statutory statement, courts should treat Congress as having overridden the Executive’s foreign-affairs commitments embodied in the Algiers Accords.

## Decision

- The D.C. Circuit affirmed the district court’s dismissal for failure to state a claim.
- The court held the Algiers Accords remained binding and required the United States to bar the prosecution of hostage-crisis claims against Iran in U.S. courts.
- The court concluded the later terrorism-related enactments did not clearly abrogate the Accords’ claim-barring provisions.
- The court rejected reliance on a conference report to override the Accords because it was not enacted into law and could not substitute for operative statutory text.

## Legal Principles

- An international executive agreement remains enforceable in U.S. courts unless Congress clearly overrides it through enacted statutory text.
- Legislative history, standing alone, cannot abrogate an international agreement or supply the clear statement needed to displace U.S. international commitments.
- General statutory expansions of jurisdiction or liability for terrorism claims do not automatically reopen claims barred by a specific prior international settlement; displacement requires clear, targeted statutory language.

## Conclusion

The court held that former U.S. hostages could not sue Iran for damages arising from the 1979–1981 hostage crisis because the Algiers Accords continued to bar such claims, and later terrorism-related statutes and legislative history did not clearly override the United States’ commitments in the Accords.


Roeder v. Islamic Republic of Iran, 333 F.3d 228 (D.C. Cir. 2003)