enactment of the Justice Against Sponsors of Terrorism Act in 2016 has allowed U.S. citizens to sue foreign powers over terrorist acts committed on U.S. soil. Jurisdictional statute The FSIA is a jurisdictional statute. It indicates what conditions must be met in order for a lawsuit against a foreign state to be instituted, not what conduct by a foreign sovereign is actionable. If a foreign defendant qualifies as a "foreign state" under the FSIA, the Act provides that it shall be immune to suit in any U.S. court—federal or state—unless a statutory exception to immunity applies. The applicability of an exception to immunity is a matter of subject-matter jurisdiction, meaning if there is no exception to immunity, a court cannot hear the claim and must dismiss the suit. In Verlinden B.V. v. Central Bank of Nigeria, the defendant challenged the jurisdiction of the district court, saying that FSIA could not give jurisdiction to the district court since it was not a case "arising under" federal law. The Supreme Court found that since any invocation of jurisdiction under the FSIA would necessarily involve analysis of the exceptions to FSIA, FSIA cases by definition arise under federal law. Under the FSIA, the burden of proof is initially on the defendant to establish that it is a "foreign state" under the FSIA and therefore entitled to state immunity. "Foreign state" is defined at 28 U.S.C. § 1603(a),(b). Once the defendant establishes that it is a foreign state, for the lawsuit to proceed, the plaintiff must prove that one of the Act's exceptions to immunity apply. The exceptions define both the types of actions as to which immunity does not attach and the territorial nexus required for adjudication in U.S. courts. The Act creates a form of long-arm statute establishing jurisdiction over claims that meet the criteria. The exceptions are listed at 28 U.S.C. §§ 1605, 1605A, and 1607. The most common exceptions are when the foreign state waives immunity (§ 1605(a)(1)) or agrees to submit a dispute to arbitration (§ 1605(a)(6)), engages in a commercial activity (§ 1605(a)(2)), commits a tort in the United States causing "personal injury or death, or damage to or loss of property" (such as a common traffic collision) (§ 1605(a)(5)), or expropriates property in violation of international law (§ 1605(a)(3)). The FSIA also excludes immunity in cases involving certain counterclaims (§ 1607) and admiralty claims (§ 1605(b)). Section