Rodriguez v. Pan American Health Organization

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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Ingrid (Wuerth) Brunk

Vanderbilt Law School
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William Dodge

George Washington University Law School
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Maggie Gardner

Cornell Law School
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John F. Coyle

University of North Carolina School of Law
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Hannah Buxbaum

UC Davis School 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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Natalie Reid

Debevoise & Plimpton LLP
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Beatrice Walton

Debevoise & Plimpton LLP
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