Indiana Jones and the Foreign Sovereign Immunities Act (FSIA): Interpreting FSIA's State Sponsored Terror Exception

In the opening scenes of Director Steven Spielberg’s Indiana Jones and the Last Crusade, the movie’s namesake hero, a young Indiana Jones fights to reclaim a long-lost golden crucifix, once owned by 16th century Spanish explorer Francisco Vázquez de Coronado, from a thief.1 Before attempting to reclaim the cross from the thief, Jones argues the point that curators, cultural heritage enthusiasts, and perhaps even the Seventh Circuit Court of Appeals of the United States would all agree with: “It belongs in a museum!”2 Echoing Dr. Jones’s sentiment, the Seventh Circuit recently held in Rubin v. Islamic Republic of Iran that a collection of Persian antiquities, comprised of thousands of ancient and inscribed stone tablets, should remain in the collection of the University of Chicago’s Oriental Institute.3 However, unlike Jones’ attempt to keep the artifact from a thief, the court kept American victims of terrorist activity from seizing the tablets in order to satisfy legal judgments won against Iran.4 Over the last two decades, U.S. courts have ruled that the Islamic Republic of Iran owes victims of state-sponsored terror nearly a billion