Martin v. United States
Issues
Is the United States immune to a lawsuit under the Federal Tort Claims Act (“FTCA”) when law enforcement agents raided the wrong home; and, what takes precedence in wrong-house raid cases: the government’s liability for intentional wrongdoing of law enforcement officers, or the “discretionary-function exception” in the FTCA that exempts government liability when any government employee carries out government functions that require discretion?
The Federal Tort Claims Act allows people to sue the United States government for wrongful acts by law enforcement officers in situations where a private person could be liable under the same circumstances. However, there are two key exceptions. The “discretionary-function exception” shields the government from lawsuits when federal employees are performing government functions. The “intentional-torts exception” also protects the government from lawsuits involving intentional torts committed by federal employees. Nevertheless, the “law enforcement proviso” within the intentional-torts exception allows people to sue for certain wrongful acts when committed by law enforcement officers specifically as opposed to other government employees. Curtrina Martin and other petitioners argue that the law enforcement proviso allows them to recover monetary damages when the FBI raided their house because their house was not the correct target. Martin also argues that the Supremacy Clause does not shield the government from Federal Tort Claims Act lawsuits. The United States, on the other hand, argues that the discretionary-function exception is a separate exception from the law enforcement provision and shields the government from Federal Tort Claims Act lawsuits. The court-appointed amici curiae also counters that the United States can raise the Supremacy Clause as a defense against liability since the government can raise any defense that a private individual could have in the case. The Supreme Court’s decision in this case will affect the legal remedies that civilians have when mistakenly identified as suspects and harmed by law enforcement officers along with the ability of law enforcement to effectively perform their duties.
Questions as Framed for the Court by the Parties
(1) Whether the Constitution’s supremacy clause bars claims under the Federal Tort Claims Act when the negligent or wrongful acts of federal employees have some nexus with furthering federal policy and can reasonably be characterized as complying with the full range of federal law; and (2) whether the discretionary-function exception is categorically inapplicable to claims arising under the law enforcement proviso to the intentional torts exception.
Curtrina Martin, her minor child G.W., and Hilliard Cliatt lived in the suburbs of Atlanta, Georgia. Martin v. United States at *3. In 2017, the FBI executed a search warrant at their house believing it to belong to a known gang member.
Additional Resources
- Amy Howe, Justices take up case on right to sue over mistaken SWAT raid, SCOTUSblog (Jan. 27, 2025).
- Maureen Groppe, FBI SWAT team raided the wrong house. Can family sue? Supreme Court will decide., USA Today (Jan. 27, 2025).
- Rosie Manins, Atlanta family in mistaken FBI raid gets case before U.S. Supreme Court, The Atlanta Journal-Constitution (Jan. 30, 2025).
- Chart Riggall, Justices Told 11th Circ.'s FTCA Ruling Is 'Upside-Down', Law 360 (March 14, 2025).
- Debra Cassens Weiss, Supreme Court will decide whether family can sue over mistaken raid by FBI SWAT team, ABA Journal (Jan. 28, 2025).