The U.S. Court of Appeals for the Eighth Circuit has affirmed a district court's dismissal of an unusual civil rights lawsuit that named the State of Israel, Prime Minister Benjamin Netanyahu, and several Arkansas law enforcement officials as defendants.
The case, *Yoram Razz v. State of Israel* (8th Cir. 2026), involved plaintiff Yoram Razz challenging what appears to be a combination of foreign and domestic defendants in a civil rights action. The defendants included the State of Israel through Prime Minister Benjamin Netanyahu, Sheriff Daniel Perry of Crawford County, Arkansas, Joshua Winford who serves as Chief of Police, Joseph Saunders who is Fire Chief of Dyer, Arkansas, Jonathan Wear who is Chief of Police of Van Buren, Arkansas, and Aldi USA.
The U.S. District Court for the Western District of Arkansas in Fort Smith originally dismissed Razz's lawsuit on two primary grounds: failure to effect proper service of process on the State of Israel and failure to state a valid legal claim upon which relief could be granted.
In a brief per curiam opinion filed Jan. 26, the three-judge panel consisting of Circuit Judges Loken, Kelly, and Grasz found no basis for reversal of the district court's decision. The appeals court noted it had carefully reviewed both the record and the parties' arguments on appeal before reaching its conclusion.
The Eighth Circuit applied de novo review standards for both grounds of dismissal. The court cited *Waters v. Madson* (8th Cir. 2019) for the principle that dismissals for failure to state a claim are reviewed de novo, meaning the appeals court examines the legal issues without deference to the lower court's conclusions.
For issues involving the Foreign Sovereign Immunities Act, the panel referenced *Missouri ex rel. Bailey v. People's Republic of China* (8th Cir. 2024), which established that determinations of subject-matter jurisdiction under the FSIA receive de novo review on appeal.
The case appears to have involved complex jurisdictional issues given the mix of foreign and domestic defendants. The Foreign Sovereign Immunities Act generally provides immunity to foreign states from lawsuits in U.S. courts, with specific exceptions. The State of Israel, as a foreign sovereign, would typically be protected by such immunity absent circumstances falling within statutory exceptions.
Service of process requirements for foreign defendants are particularly strict under federal civil procedure rules. The Federal Rules of Civil Procedure require specific methods for serving foreign states, including compliance with international treaties and diplomatic protocols. Failure to follow these requirements can result in dismissal regardless of the underlying merits of a case.
The inclusion of Arkansas law enforcement officials alongside Israeli defendants suggests Razz may have been attempting to link local and international issues in a single lawsuit. However, federal courts require plaintiffs to establish proper jurisdiction over all defendants and to articulate valid legal theories connecting the various parties.
The brief nature of the appeals court's opinion indicates the panel found the district court's reasoning clearly correct on both procedural and substantive grounds. Per curiam opinions are typically reserved for cases where the legal issues are straightforward or the appeal lacks merit.
The case was submitted to the appeals court on Jan. 16, 2026, and decided just 10 days later, suggesting the court viewed the appeal as lacking sufficient merit to warrant extended deliberation or oral argument. The opinion was designated as unpublished, meaning it will have limited precedential value for future cases.
While the specific factual allegations underlying Razz's civil rights claims are not detailed in the available portion of the opinion, the dismissal on multiple grounds suggests fundamental problems with both the legal theory and procedural compliance of the lawsuit.
The case illustrates the challenges plaintiffs face when attempting to sue foreign governments in U.S. courts, particularly regarding proper service requirements and jurisdictional limitations. The Foreign Sovereign Immunities Act creates a presumption of immunity for foreign states, requiring plaintiffs to demonstrate that specific statutory exceptions apply.
For civil rights plaintiffs, the case also demonstrates the importance of properly pleading factual allegations sufficient to state a plausible claim for relief under federal civil rights statutes. Courts will dismiss cases that fail to meet basic pleading standards regardless of a plaintiff's underlying grievances.
The affirmance means Razz's claims against all defendants have been definitively rejected by the federal court system. The combination of service failures and pleading deficiencies created insurmountable obstacles to proceeding with the litigation.
This case adds to the body of Eighth Circuit precedent addressing both Foreign Sovereign Immunities Act issues and civil rights pleading standards, though its unpublished status limits its formal precedential impact on future litigation involving similar jurisdictional and procedural questions.