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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.

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