Collateral Order Doctrine

D.C. Circuit Holds Jurisdictional Discovery in FSIA Cases Not Immediately Appealable

Last Friday, August 14, 2026, the D.C. Circuit held in Rodriguez v. Pan American Health Organization that international organizations, and by extension foreign states, cannot immediately appeal district court orders for jurisdictional discovery aimed at determining if they are immune from suit. (Disclosure: I joined an amicus brief urging the court to take this position.)…

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Immediate Appeals in Foreign Sovereign Litigation

Foreign governments have many advantages in litigation.  Chief among them is sovereign immunity.  Under the Foreign Sovereign Immunities Act, foreign states and their agencies and instrumentalities are immune from suit in United States courts unless the case falls within one of the statute’s specific exceptions to immunity.  That substantive immunity also confers important procedural advantages. …

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Ingrid (Wuerth) Brunk

Vanderbilt Law School
ingrid.brunk@vanderbilt.eduEmail

William Dodge

George Washington University Law School
william.dodge@law.gwu.eduEmail

Maggie Gardner

Cornell Law School
mgardner@cornell.eduEmail

John F. Coyle

University of North Carolina School of Law
jfcoyle@email.unc.eduEmail

Hannah Buxbaum

UC Davis School of Law
hbuxbaum@ucdavis.eduEmail

Marketa Trimble

William S. Boyd School of Law, University of Nevada, Las Vegas
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Aaron D. Simowitz

Willamette University College of Law
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Robert Kry

MoloLamken LLP
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Jackson Myers

MoloLamken LLP
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Russell Pulver

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Rachel Bayefsky

University of Virginia School of Law
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Paul B. Stephan

University of Virginia School of Law
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Alex Rivenbark

Law Clerk
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Junhao Chen

New York University
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Yanbai Andrea Wang

University of Pennsylvania Carey Law School
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