221 of the Antiterrorism and Effective Death Penalty Act of 1996 added an exception for U.S. victims of terrorism, for any government designated by the State Department as state sponsor of terrorism. The Flatow Amendment was also added in 1996, named after lawyer Stephen Flatow who fought to sue Iran over the suicide bombing that killed his daughter Alisa in 1995, which made those responsible for such attacks liable in court. In response to the decision of Cicippio-Puleo v. Islamic Republic of Iran that made it difficult to seek private cause of action lawsuits against foreign nations even with the Flatow Amendment, the National Defense Authorization Act for Fiscal Year 2008 greatly expanded the terrorism exceptions by moving these as a whole to § 1605A, making foreign nations liable for the actions of their officers in cause of action lawsuits, and expanding exceptions for torture, extrajudicial killing, aircraft sabotage, and hostage-taking. In 2016, the Justice Against Sponsors of Terrorism Act removed the requirement that a state sponsor of terrorism be officially listed, so that victim families of the September 11 attacks could sue Saudi Arabia. Scope and applicability Retroactive application In 2004, the Supreme Court held in Republic of Austria v. Altmann, 541 U.S. 677 (2004) that the FSIA applies retroactively. That case involved a claim by the descendants of owners of famous paintings against the Austrian government for return of those paintings, which were allegedly seized during the Nazi era. As a consequence of Altmann, for lawsuits filed after the enactment of the FSIA (1976), FSIA standards of immunity and its exceptions apply, even where the conduct that took place prior to enactment of the FSIA. Exclusive basis for suit In Argentine Republic v. Amerada Hess Shipping Corp., 488 U.S. 428 (1989), the Supreme Court held that the FSIA provides the "sole basis for obtaining jurisdiction over a foreign state". In that case, a Liberian-owned oil tanker which was traveling outside of the "war zones" designated by the United Kingdom and Argentina during the Falklands War in 1982 was struck by an air to surface rocket fired by an Argentine jet. The shipping company sued Argentina in federal court claiming that Argentina's actions violated the Alien Tort Statute 28 U.S.C. § 1350 and general admiralty law. Because the Court found that the FSIA provided the exclusive means of suing the foreign sovereign, the Court determined that the plaintiffs were