28 U.S.C. § 1604
Section 1604 · Immunity of a foreign state from jurisdiction
This is § 4 of the Foreign Sovereign Immunities Act of 1976
Amended 1 time on record
Applied in 717 court decisions — leading case Verlinden B. v. v. Central Bank of Nigeria (1983)
Most recently applied in CC/Devas (Mauritius) Ltd. v. Antrix Corp. (June 2025)
Applied most in the District Circuit Circuit (176 decisions)
Cases citing this section usually also cite 28 U.S.C. § 1605 · 28 U.S.C. § 1603 · 28 U.S.C. § 1330
How often courts cite this section
Court decisions citing this, by year.Markers show enactment, consequential amendments, and circuit splits over this section — watch for a citation surge after a change or a disagreement. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
Subject to existing international agreements to which the United States is a party at the time of enactment of this Act a foreign state shall be immune from the jurisdiction of the courts of the United States and of the States except as provided in sections 1605 to 1607 of this chapter.
Editorial notes U.S. Code · Office of the Law Revision Counsel
References in Text
The time of enactment of this Act, referred to in text, probably means the time of enactment of Pub. L. 94–583, which was approved Oct. 21, 1976.