D.C. Circuit finds that FSIA definition of "hostage taking" focuses on state of mind of hostage taker thus making it unnecessary for plaintiff to show that hostage taker communicated demand showing underlying intent to third party. From: International Law Update | Date: November 1, 2006 | COPYRIGHT 2006 Transnational Law Associates. This material is published under license from the publisher through the Gale Group, Farmington Hills, Michigan.  All inquiries regarding rights should be directed to the Gale Group.Copyright information

In February 1987, a Mediterranean storm drove the private yacht carrying Sandra Jean Simpson (Plaintiff) and her husband, Dr. Mostafa Karim, off course. Eventually, it docked in the Libyan port of Benghazi. Libyan officers boarded and arrested the passengers and crew. The Libyans released Simpson after three months. They held her husband, however, seven more months under grim conditions. He died of cancer in 1993.

Plaintiff sued Libya, alleging, inter alia, torture, hos...