In S.H. v. United States, No. 15-15000 (9th Cir. Apr. 10, 2017), the Ninth Circuit vacated the EDCA court's judgment in favor of plaintiffs who brought a Federal Tort Claims Act action against the United States, holding that plaintiffs' claims arose in Spain and thus were barred by the Act's foreign country exception. Plaintiff S.H. was born prematurely while her family was stationed at a United States Air Force base in Spain and, as a result of her premature birth, S.H. suffered permanent brain injury that led to a diagnosis of cereal palsy after she returned to the United States.