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United States (U. S.) Court of Appeals for the District of Columbia (D.C.) Circuit: Sandra Jean Simpson V. Socialist People's Libyan Arab Jamahiriya

Published online by Cambridge University Press:  27 February 2017

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Type
Judicial and Similar Proceedings
Information
International Legal Materials , Volume 42 , Issue 4 , July 2003 , pp. 991 - 994
Copyright
Copyright © American Society of International Law 2003

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Footnotes

*

326 F.3d 230 (D.C. Cir. 2003).

References

Endnotes

1 As we acknowledged recently in Price v. Socialist People's Libyan Arab Jamahiriya, 294 F. 3d 82, 87 (D. C. Cir. 2002), the Flatow Amendment does not list “foreign states” among the parties against whom an action may be brought. Libya, recognizing this, argues that Simpson's complaint should be dismissed because the Flatow Amendment does not create a federal cause of action against foreign states. However, Libya concedes that it failed to raise this issue in the District Court, so we do not pass on this issue here *Elisabeth C. Handl is a doctorate candidate (Dr. iur.) at the University of Graz, Austria; Mag. iur., University of Graz; L.L.M., The George Washington University Law School (international ' comparative law).