Primarily to seek justice for the torture of John Doe I, John Doe II, and John Doe III, who allege they were tortured at the hands of SAVAK under the leadership of Parvez Sabeti. For decades, those who were arbitrarily arrested and tortured during the Shah’s regime have been denied recognition. This case is about ensuring that all victims of torture in Iran are recognized and have a meaningful path to seek accountability.

This case also highlights that accountability is necessary to end cycles of violence. Impunity for Shah-era crimes has provided a precedent for the Islamic regime’s impunity for crimes against Iranians. Justice for human rights atrocities committed in the past builds the foundation for democracy in the future. This case is not only about torture during the Shah’s regime, nor only about the three Plaintiffs. By establishing that perpetrators of atrocity can be held accountable regardless of which regime committed the atrocities or how much time has passed, our clients hope to help build the norms and institutions that will shape whatever comes next for Iran, and for countries facing similar transitions around the world.

The complaint was filed in the U.S. District Court for the Middle District of Florida, Orlando Division.

Justice is not currently possible in Iran. However, the Plaintiffs could seek justice in U.S. courts because Sabeti, who Plaintiffs allege was the Deputy Director of SAVAK—the intelligence agency allegedly responsible for Plaintiffs’ torture—and head of the SAVAK’s Third Division, was found in the United States in 2023. Because he is living in the United States, Sabeti is subject to its laws and courts. Even though the human rights abuses alleged in the complaint took place in Iran, a U.S. law—the Torture Victim Protection Act—allows survivors and the families of victims of certain atrocities committed abroad to seek justice against perpetrators who are present in the United States.

Plaintiffs are proceeding pseudonymously in this case because they fear retaliation against themselves and their families from supporters of the Shah as well as the current Iranian government. Sabeti’s critics have received death threats. Despite filing the case pseudonymously, Plaintiffs have also received threats of violence and death since the complaint was filed. Even though there is a presumption in favor of plaintiffs using their real names in court proceedings in the U.S., the Court has decided, because of the evidence Plaintiffs have provided about the risks to them, they can proceed pseudonymously. Despite the safety risks, Plaintiffs believe it is important to proceed with the case to ensure that Sabeti is held to account and to highlight the role that SAVAK played during the Shah’s regime and the influence it has had on the Islamic regime’s torture and repression apparatus.

Plaintiff John Doe I was a student at Tabriz University in early 1974 when he was allegedly arrested by SAVAK in his dormitory. He was interrogated and tortured allegedly by members of SAVAK.

Plaintiff John Doe II was an Iranian artist; he was arrested several times in the 1970s because of his art and political beliefs. Each time he was arrested, he was tortured allegedly by members of SAVAK.

Plaintiff John Doe III was only a high school student when he was arrested allegedly by members of SAVAK. He was accused of being part of a group who shared literature and had anti-Shah views. After his arrest he was tortured allegedly by members of the Komiteh Moshtarak.

The defendant is Parvez Sabeti. Plaintiffs allege that from 1972 to 1978, Sabeti was the Deputy Director of SAVAK and the head of SAVAK’s Third Division, tasked with Iran’s internal security. Sabeti also allegedly served as the Chairman of the Komiteh Moshtarak—an interagency task force that included SAVAK and was tasked with arresting, interrogating, and torturing dissidents and political opponents of the Shah’s regime. Plaintiffs allege that Sabeti is an architect of the institutionalization of torture in Iran, including the use of forced public recantations obtained through torture, practices still employed in Iran today.

In 2023 a photo of Sabeti at a public demonstration in the United States surfaced on Twitter (now X). The post went viral in the Iranian community and Sabeti then appeared in a five-part television documentary detailing his life. These public appearances were Plaintiffs’ first indication that Sabeti was living in the United States.

Bringing a human rights case in US courts requires a legal connection to the U.S., typically that the perpetrator is physically present in the United States. Sabeti lives here, and as the alleged former deputy head of SAVAK he allegedly bears direct responsibility for a systematic program of torture. His presence in the U.S. creates a rare and important opportunity to pursue accountability for crimes that have gone unaddressed for decades. This does not mean other perpetrators—including those responsible for abuses committed under the Islamic Republic—should not also be held accountable, and other organizations are working tirelessly to try to address that accountability gap.

SAVAK stands for Sāzmān-e Ettelā’āt va Amniyat-e Keshvar, which translates to the “Bureau for Intelligence and Security.” SAVAK was the intelligence agency and secret police in Iran during the government of Mohammad Reza Pahlavi, the former Shah of Iran. The Komiteh Moshtarak or the Joint Anti-Sabotage Committee. It was a multi-agency task force, which included SAVAK, created to combat “sabotage” or anti-state subversion. Plaintiffs allege in the Complaint that in practice the Joint Committee was tasked with detaining, torturing, and persecuting the Shah’s perceived political opponents. Plaintiffs were all allegedly detained by SAVAK and/or the Joint Committee for perceived crimes and tortured. Plaintiffs allege that SAVAK was absorbed and adapted by the Islamic Republic of Iran building on the legacy of torture developed by Sabeti and SAVAK.

Plaintiffs allege in the Complaint that in his role as Deputy Director of SAVAK, head of SAVAK’s Third Division, tasked with internal security, and Chairman of the Komiteh Moshtarak, Sabeti exercised command and control over Iran’s security apparatus for several years during the 1970s, and ordered or approved the torture of thousands of Iranian citizens, including John Doe I, John Doe II, and John Doe III. In these roles, Plaintiffs allege, Sabeti was effectively in charge of interrogations and established the policies and practices concerning arresting, detaining, and interrogating perceived dissidents, including Plaintiffs, and their systematic torture. Plaintiffs allege that because of his control and supervision over the security apparatus and the torturers who conducted the interrogations of political dissidents, Sabeti is indirectly liable for their torture. The Plaintiffs have all brought claims for torture against Sabeti under the Torture Victims Protection Act.

The Torture Victims Protection Act is a U.S. federal law which allows victims and their family members to file lawsuits in U.S. federal courts against individuals responsible for torture or extrajudicial killing. Under the TVPA, both U.S. citizens and non-citizens may file suit. For the U.S. court to have the authority to hear the case against a perpetrator, they must have some connection to the U.S. (usually that means that they live in the U.S.) or they must be served in person in the U.S.

While the U.S. has both criminal and civil laws that apply to torture and serious violations of international law committed overseas, only the U.S. government can pursue criminal charges. Survivors and their lawyers do not have the ability to bring a criminal case for torture or put someone in jail. Individuals, like the Plaintiffs in this case, can only bring civil cases for money damages to seek justice.

Sabeti filed a motion arguing that Plaintiffs filed their Complaint too late. The TVPA usually requires that claims are filed within ten years of the torture or extrajudicial killing and Plaintiffs here filed their Complaint more than ten years after they experienced torture in Iran. This time limit has some exceptions and Plaintiffs have argued to the Court that because they legitimately feared for their safety and Sabeti hid his location and whereabouts until 2023, they couldn’t have filed the Complaint any sooner and so the ten-year time limit should be extended.

If the court rules in Plaintiffs’ favor, the case will move into the discovery phase regarding Plaintiffs’ torture allegations. This is the phase where both sides gather and exchange evidence. We can request documents, take witness statements, and build the factual record we’ll need to proceed to trial.

The Center for Justice and Accountability (CJA) is a U.S.-based international human rights organization that works with communities impacted by torture, war crimes, crimes against humanity, and other serious human rights abuses to seek truth, justice, and redress using innovative litigation and transitional justice strategies. CJA is the foremost organization bringing claims under the Torture Victim Protection Act and has successfully brought cases against defendants such as the Minister of Defense of Somalia’s Siad Barre regime, the military officer responsible for the assassination of Chilean activist and singer Victor Jara, and Syria’s Assad regime for its use of torture in detention centers. Along with co-counsel, Foley Hoag LLP, CJA represents John Doe I, John Doe II, and John Doe III.

You can find more information about the case, including all the relevant court filings, on CJA’s website here. We will also periodically post updates on our social media, so follow along on BlueSky, Facebook, LinkedIn, X, and Instagram.