## Facts

- Kenneth P. Yeager, a U.S. national, worked in Tehran for Bell Helicopter International beginning in January 1978 and brought household goods to Iran.
- During the Iranian Revolution, conditions for U.S. nationals deteriorated amid harassment and insecurity.
- In early 1979, men identifying themselves as Revolutionary Guards, acting for the “new government,” forced Yeager and his wife from their apartment to a hotel, where they were held for several days under coercive conditions.
- Yeager was told he had to leave Iran and was not given a reasonable opportunity to wind up his affairs; he ultimately departed Iran under circumstances treated as involuntary.
- Yeager claimed losses from distressed disposal or abandonment of property, costs tied to his departure, and a bribe paid to an official of Iran’s national airline to secure passage out of Iran.
- The United States filed Yeager’s claim before the Iran–U.S. Claims Tribunal and separately sought an interlocutory ruling that approximately 1,500 U.S. nationals who left Iran between October 1978 and February 1979 were unlawfully expelled.

## Issues

1. Whether a wrongful-expulsion claim falls within the Tribunal’s jurisdiction as a “measure affecting property rights.”
2. Whether the Revolutionary Guards’ conduct and the airline official’s bribe demand were attributable to Iran.
3. Whether Yeager’s removal violated the customary international law minimum standard governing expulsion of aliens, including a reasonable opportunity to wind up affairs.
4. Whether the Tribunal should issue a generalized interlocutory determination that all similarly situated U.S. nationals were unlawfully expelled and entitled to compensation.
5. What categories of damages were recoverable from Iran (property-related losses, bribe payment, and contract-related losses).

## Decision

- The Tribunal held it had jurisdiction because the manner and circumstances of Yeager’s expulsion directly affected his property and property rights.
- The Tribunal attributed the Revolutionary Guards’ coercive acts to Iran, treating them as de facto organs or agents of the State during the relevant revolutionary period.
- The Tribunal attributed the airline official’s bribe extraction to Iran because it was tied to the official’s exercise of authority over departure formalities.
- The Tribunal found Yeager was expelled in breach of the minimum international standard, including Iran’s failure to provide a reasonable opportunity to wind up affairs and the coercive nature of the removal.
- The Tribunal denied the requested mass interlocutory ruling, requiring individualized proof of expulsion and injury.
- The Tribunal allowed recovery for specified property-related losses attributable to the expulsion, including the bribe payment, but denied recovery for losses stemming from Bell Helicopter International’s lawful termination of Yeager’s employment contract.

## Legal Principles

- A tribunal with jurisdiction over measures affecting property rights may hear an expulsion-based claim when the expulsion directly and materially impacts the claimant’s property and economic interests.
- Under customary international law, a State’s power to expel aliens is limited by the minimum international standard, including a duty to avoid coercive or arbitrary expulsion and to allow a reasonable opportunity to wind up affairs.
- In revolutionary or transitional contexts, groups exercising public authority may be treated as State organs or agents for attribution when they act as de facto governmental authorities.
- Misuse of official authority (including demanding a bribe in connection with official exit procedures) can remain attributable to the State when performed in an official capacity.
- Generalized determinations of wrongful expulsion and compensation are inappropriate where liability turns on fact-specific assessments of each claimant’s circumstances and proof.

## Conclusion

The Tribunal concluded that Yeager’s coerced departure constituted an internationally wrongful expulsion attributable to Iran, supporting compensation for property-related losses (including a bribe paid to secure exit), while excluding damages tied to a private employer’s lawful contract termination and rejecting a blanket interlocutory ruling for other claimants.


Yeager v. Iran, 17 Iran-U.S. Cl. Trib. Rep. 92 (Iran-U.S. Cl. Trib. 1987)