The Clock That Has Yet to Start Ticking

On 6 October 2026, a US federal district court in Florida allowed a torture case involving alleged abuses committed more than 50 years ago by agents of SAVAK, the intelligence service of Iran’s last Shah, to proceed to consideration on its merits under the Torture Victim Protection Act (TVPA). Two unusual features distinguish this case from similar TVPA torture suits: the prohibition on disclosing the plaintiffs’ identities to the defendant, Parviz Sabeti, who served as a Deputy Director of SAVAK in the 1970s, and the equitable tolling of the statute of limitations for as long as an authoritarian regime remains in power in Iran. The ruling could pave the way for other Iranian torture survivors to pursue justice notwithstanding the statute of limitations and could potentially benefit survivors from other countries that have never undertaken a democratic reckoning with past crimes, regardless of how much time has elapsed since those crimes were committed.

But the case is about more than accountability for crimes committed half a century ago. By recognising evidence of institutional continuity between the Shah’s intelligence service and that of the Islamic Republic, the Florida court has also challenged a longstanding understanding of transitional justice in Iran. Any future reckoning with Iran’s past must confront the Shah’s repression and its legacy within the Islamic Republic.

Doe I v. Sabeti After Fifty Years

The plaintiffs, three Iranian men living in California and identified only as John Doe I, II and III, sued Parviz Sabeti in February 2025. Sabeti, 90, is a long-time resident of Orlando who served in the 1970s as a Deputy Director of SAVAK, head of its internal security division, and head of the Komiteh Moshtarak (Joint Anti-Sabotage Committee). At the time, the plaintiffs were, respectively, a high school student, a university student and an artist. Now aged between 68 and 85, they allege that, under a system of political repression designed, authorised and overseen by Sabeti, they were arrested, subjected to prolonged detention and tortured for their suspected involvement in non-violent anti-Shah activities. The abuse they describe includes beatings, electric shocks, genital abuse and the “Apollo” device, an electric chair fitted with a metal mask that muffled and amplified the victim’s own screams. The plaintiffs, like many others from Iran’s leftist and progressive movements, were forced to flee after the 1979 revolution because the newly established Islamic Republic proved as hostile to them as the Shah’s regime had been. They thus became victims of two successive regimes, neither of which offered them any meaningful opportunity to seek justice.

The TVPA creates a federal civil cause of action against individuals who commit torture or extrajudicial killing abroad under a foreign government’s actual or apparent authority, allowing US courts to award damages even where both the victim and the perpetrator are foreign nationals. Claims must generally be filed within ten years, though courts may extend that period through equitable tolling when circumstances such as imprisonment, reasonable fear of retaliation, or a defendant’s concealment prevented earlier filing.

Anonymous Even to the Defendant

From the outset, all three plaintiffs sought anonymity, citing fears of reprisals from Sabeti, the Iranian monarchists, and the Islamic Republic. Judicial proceedings in the United States are presumptively open to the public, including the identities of the parties. Accordingly, permitting a plaintiff to proceed anonymously is an exceptional measure that must be supported by compelling and carefully substantiated grounds. The Florida court relied on Doe v. Stegall for the factors governing pseudonymity, including credible threats of violence or physical harm, and on Doe v. Islamic Salvation Front as the closest precedent for temporarily preventing a defendant from personally learning the plaintiffs’ identities while permitting limited disclosure for discovery.

The court granted the plaintiffs leave to proceed under pseudonyms (p. 9) and subsequently rejected Sabeti’s attempts to overturn that decision, citing serious online threats made by monarchists and death threats against the plaintiffs’ counsel that the FBI traced to an individual in Iran (pp. 7–9). It later permitted disclosure of their identities to defence counsel, experts and investigators (pp. 5–8, 12), while continuing to withhold them from Sabeti personally until discovery on the merits. The court reaffirmed this conclusion in its October 2026 order, citing “Defendant’s fear-inducing reputation, and his demonstrable connections to clandestine intelligence agencies” (p. 36).

While allowing plaintiffs to proceed under pseudonyms is an established but exceptional practice in US courts, withholding their identities even from the defendant personally is considerably rarer. Acknowledging that there was “scant precedent” for its decision (December 2025 order, p. 7), the Florida court emphasised the extraordinary circumstances of the case. These included the concerns about Sabeti’s reputation and intelligence connections, as well as his admitted contacts with individuals who had made death threats against the plaintiffs and their counsel. Nevertheless, the protection was limited to the preliminary phase of the proceedings, as the court reminded the plaintiffs that they “will be required to share their identities with Defendant for discovery on the merits of their claim” (p. 61).

No End Point for Equitable Tolling

In response to Sabeti’s statute-of-limitations defence, the plaintiffs argued that their fear of reprisals from both the Islamic Republic and monarchists justified the delay; that Sabeti had lived clandestinely since fleeing Iran in late 1978, a fact confirmed even by his own daughter; and that they had learned of his whereabouts only through a 2023 social media post. Following a period of discovery limited to the statute-of-limitations issue (pp. 15–16), the court rejected Sabeti’s motion for summary judgment on 6 October 2026 and held that the claims were subject to equitable tolling.

The court treated equitable tolling as requiring two distinct elements: extraordinary circumstances preventing timely filing and the diligent pursuit of rights. Regarding extraordinary circumstances, the court confirmed that the plaintiffs reasonably feared reprisals for seeking accountability under the TVPA, as discussed earlier. Perhaps its most consequential conclusion, however, concerned the tolling date. The court reviewed four leading Eleventh Circuit TVPA cases in which equitable tolling ended after a discernible political change: Jean v. Dorelien, where Haiti’s military regime ended in 1994; Cabello v. Fernández-Larios, where Chile elected its first post-junta civilian president in 1990; Arce v. Garcia, where El Salvador’s civil war ended in 1992; and Camps v. Bravo, where tolling continued until 2005 because Argentina’s military remained influential and protected by amnesty laws even after the restoration of democratic government. Unlike in those cases, the court stated that “in this case, no end point has ever materialized—two, overlapping authoritarian regimes have remained in power in Iran since Plaintiffs were tortured approximately fifty years ago” (p. 28). The court further stated: “And though the facts underlying Plaintiffs’ lawsuit arose under the Shah’s regime, the IRI which replaced him has built upon that troubling legacy – in fact, the IRI has almost certainly exceeded it” (pp. 28–29). It also found that the plaintiffs “could not reasonably have expected to achieve justice” without genuine fear of reprisal while either regime remained in power (p. 31). It concluded that, although the events underlying the plaintiffs’ claims occurred more than fifty years ago, binding precedent indicated that their claims could still reasonably be tried as “the clock on the TVPA statute of limitations has not even begun to run” (p. 45). This far-reaching conclusion could allow survivors to pursue claims under the TVPA decades after the alleged abuses, as long as authoritarian rule continues to prevent them from seeking justice.

The court further held that Sabeti’s concealment of his whereabouts constituted a separate extraordinary circumstance supporting tolling until at least February 2023 (p. 54). On diligence, the court relied particularly on Camps, Cabello, and Dotson to hold that the plaintiffs were required to exercise “reasonable diligence”, not “maximum feasible diligence” (p. 18), assessed in the context of the obstacles they faced, and were not necessarily expected to search continuously for the defendant when fear, concealment, or other barriers made litigation unrealistic.

The Third Side of Justice

SAVAK’s crimes have never been examined through a fair judicial process, either inside or outside Iran, or even by an informal truth commission or people’s tribunal. TVPA suits concern individual liability for damages, and it remains uncertain whether the Sabeti case will result in a judgment on the merits, given the possibility of settlement or the defendant’s death. Nevertheless, the proceedings could, for the first time, allow evidence that has circulated for decades in the form of testimony, memoirs and partisan claims to be tested before an independent court under procedural rules binding both parties.

As the Florida court stated, “there is substantial evidence in the record that the Shah’s SAVAK was simply repurposed by the IRI (after executing a number of its top personnel) into its own abusive intelligence agency known as SAVAMA” (p. 29). By examining SAVAK’s record and its institutional and operational continuity with the Islamic Republic’s intelligence apparatus, the case could contribute to a fuller account of a fiercely contested era that has never been adequately incorporated into Iran’s collective memory, while broadening the country’s transitional justice debate.

Until recently, debates on transitional justice in Iran focused solely on the post-1979 period, treating human rights violations by the Islamic Republic as a matter between two parties: the regime and its victims. Violations from the pre-revolutionary era, particularly those committed by SAVAK against political dissidents, were considered historical footnotes. Recent developments have shifted this paradigm. Reza Pahlavi, the Shah’s son, who has spent almost his entire adult life outside Iran, has increasingly positioned himself as the leader of Iran’s transition to democracy. The Florida case could now pose a dilemma for him and his movement, which calls for a full return to the Shah’s era. Among some hardline monarchist circles, this has been accompanied by the glorification of SAVAK. Asked by a Dutch television presenter about SAVAK’s executions and torture, Pahlavi recently said he was proud of his heritage and of his father’s record, describing the Shah as one of Iran’s greatest leaders who had guided the country through difficult Cold War circumstances. Pressed on whether he was equally proud of the SAVAK-linked executions and torture specifically, he declined to give a direct answer.

Should Pahlavi play a role in a political transition, a prospect supported by some Israeli and far-right European politicians, his approach to his father’s repression will be no small matter. Concerns about the recurrence of Shah-era repression were heightened when Pahlavi supporters marched through London, Copenhagen and Regensburg in black or military-style uniforms, some masked and carrying SAVAK flags or wearing its emblem. In this political context, transitional justice in Iran can no longer be understood as a two-party process between the Islamic Republic and its victims. It is triangular: the Shah’s crimes and their victims constitute a third dimension, bringing with them rights to truth, justice and reparations, as well as the public’s right to know and to guarantees of non-repetition. By recognising evidence of institutional continuity between SAVAK and the Islamic Republic’s intelligence apparatus, while also acknowledging threats to the plaintiffs from both Pahlavi supporters and the Islamic Republic, the Florida court has brought this neglected dimension into the present. Sabeti’s case therefore matters beyond one courtroom, with implications for Pahlavi, his movement and the shape of any future transitional justice process in Iran.