In 2001, Cicippio's children brought an additional suit against Iran, seeking punitive damages for emotional distress and loss of solatium during the hostage period of Cicippio under FSIA and the Flatow Amendment. Cicippio sought to consolidate his children's to his completed case, and subsequently seek summary judgement based on the prior ruling. In 2002 the United States District Court for the District of Columbia denied the motion for summary judgement, as well as consolidation, but further also dismissed the children's case as lacking standing, in that FSIA nor the Flatow Amendment does not create a private cause of action for cases of punitive damages.
