Narrative Summary: Peterson v. Islamic Republic of Iran

The Second Circuit affirmed in part and vacated in part the dismissal of plaintiffs' claims against foreign banks, holding that settlement agreements released some but not all non-turnover claims. The court reasoned that while assets were located abroad, New York state law permits an exercise of in personam jurisdiction to compel a non-sovereign possessor to turn over extraterritorial sovereign assets. Consequently, the case is remanded for the district court to determine if such jurisdiction exists and whether execution immunity would ultimately bar turnover. Read the full decision narrative and case summary.