September 2010 Archives

In Bennett v. Islamic Repub. of Iran, No. 09-5147, proceedings arising from a deadly bombing in Jerusalem, wherein plaintiffs sought to satisfy a default judgment against the Islamic Republic of Iran and the Iranian Ministry of Information and Security, the court affirmed the district court's order quashing writs of attachment against five of Iran's former diplomatic properties located in the District of Columbia, holding that section 201 of the Terrorism Risk Insurance Act precluded the attachments.

In Payne v. Salazar, No. 09-5291, an action alleging retaliation in violation of Title VII, the court affirmed in part the dismissal of the action for failure to exhaust administrative remedies, holding that the district court properly held that plaintiff failed to exhaust one of her claims.  However, the court reversed in part on the ground that an employee's right to trial de novo -- whether her employer is the federal government or a private company -- means that she is entitled to a plenary trial of whatever claims she brings to court, and it does not mean that she must sue on claims she has no interest in pursuing.