In 2005, the Ninth Circuit indicated that it was willing to consider a challenge to the constitutionality of AEDPA on separation of powers grounds under City of Boerne v. Flores and Marbury v. Madison,[REF] but it has since decided that the issue had been settled by circuit precedent [REF].
Basketball player and later coach Steve Kerr and his siblings and mother sued the Iranian government under Act for the 1984 killing of Steve Kerr's father, Malcolm H. Kerr, in Beirut, Lebanon [REF].