On January 19, 1981, the United States signed. an agreement with Iran that achieved the release of fifty-two American hostages held captive in Iran for over a year. In exchange for the safe return of the hostages, the United States returned Iranian property that had been seized in this country pursuant to a presidential order. The agreement, ending what one court termed a "sorry chapter [in] the history of our country,"' required a controversial intrusion by the executive into federal court litigation. The Supreme Court sought to lay the controversy to rest in Dames & Moore v. Regan.
Roman Pipko & Jonathan S. Sack,
Rediscovering Executive Authority: Claims Settlement and Foreign Sovereign Immunity,
Yale J. Int'l L.
Available at: http://digitalcommons.law.yale.edu/yjil/vol10/iss2/8