18 U.S.C. § 2337
Suits against Government officials
Section applicable to any pending case or any cause of action arising on or after 4 years before
Notes of Decisions
Cited in 25
cases (3 in the last 5 years), 2002–2025 · leading case: Estates of Ungar & Ungar v. Palestinian Auth., 325 F. Supp. 2d 15 (D.R.I. 2004).
Estates of Ungar & Ungar v. Palestinian Auth., 325 F. Supp. 2d 15 (D.R.I. 2004). “§ 1604 (1976) (“FSIA”), and the Anti-Terrorism Act of 1991, 18 U.S.C. § 2337 (2)(1992)(“ATA”), 3 and because the claims asserted against them present non-justieiable political questions; 2)Plaintiffs’ claims are legally insufficient and do not support an entry of default…”
Pugh v. Socialist People's Libyan Arab Jamahiriya, 290 F. Supp. 2d 54 (D.D.C. 2003). “§ 2333 is barred by 18 U.S.C. § 2337 (2003), which states: “No action shall be maintained under section 2333 of this title [18 U.”
Ungar v. Palestine Liberation Org., 402 F.3d 274 (1st Cir. 2005). “” 18 U.S.C. § 2337 (2). Like the FSIA, the ATA contains no definition of the term “foreign state.”
Smith v. Islamic Emirate of Afghanistan, 262 F. Supp. 2d 217 (S.D.N.Y. 2003). “However, 18 U.S.C. § 2337 appears to expressly foreclose an action against Iraq and its leader.”
Biton v. Palestinian Interim Self-Gov't Auth., 310 F. Supp. 2d 172 (D.D.C. 2004). “Palestinian Statehood Citing § 2337(2) of the ATA and § 1604 of the FSIA, the defendants move to dismiss this action on the grounds that Palestine is a sovereign entity. Section 2337(2) prohibits the maintenance of a civil ATA lawsuit against “a foreign state, an agency of a…”
Bruce Joiner v. United States, 955 F.3d 399 (5th Cir. 2020). “18 U.S.C. § 2337 . Joiner argues that the Geneva Convention’s prohibition of a signatory’s “absolv[ing] itself .”
Knox v. Palestine Liberation Org., 306 F. Supp. 2d 424 (S.D.N.Y. 2004). “A 1992 amendment to the ATA bars any actions under that provision as against “a foreign state, an agency of a foreign state, or an officer or employee of a foreign state or an agency thereof acting within his or her official capacity or under color of legal authority.”
Estates of Ungar Ex Rel. Strachman v. Pales. Auth., 228 F. Supp. 2d 40 (D.R.I. 2002). “Therefore, the PA is not a “foreign state” within the meaning of 18 U.S.C. § 2337 (2) (2000), and consequently is not immune from suit under 18 U.”
Simpson v. Socialist People's Libyan Arab Jamahiriya, 362 F. Supp. 2d 168 (D.D.C. 2005). “Furthermore, 18 U.S.C. § 2337 (2) bars the use of §■ 2333 in suits against foreign states.”
Cronin v. Islamic Repub. of Iran, 238 F. Supp. 2d 222 (D.D.C. 2002). “The problem with invoking that statutory provision is 18 U.S.C. § 2337 explicitly provides that "[n]o action shall be maintained under section 2333 of this title against .”
Estates of Ungar Ex Rel. Estates Strachman v. Palestinian Auth., 315 F. Supp. 2d 164 (D.R.I. 2004). “Plaintiffs filed a surreply on October 14, 2003, arguing that the PA and PLO had failed to address any of Plaintiffs’ specific contentions.”
Schansman v. Sberbank, 128 F.4th 70 (2d Cir. 2025). “” 18 U.S.C. § 2337 (2) (the “ATA Immunity Provision”).”
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