Martin v. United States

Martin v. United States
Supreme Court of the United States
Argued April 29, 2025
Full case name	Curtrina Martin, et al., v. United States of America, et al.
Docket no.	24-362
Argument	Oral argument
Questions presented
(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 be reasonably characterized as complying with the full range of federal law. (2) Whether the discretionary-function exception is categorically inapplicable to claims arising under the law enforcement proviso to the intentional torts exception.
Court membership
Chief Justice John Roberts Associate Justices Clarence Thomas · Samuel Alito Sonia Sotomayor · Elena Kagan Neil Gorsuch · Brett Kavanaugh Amy Coney Barrett · Ketanji Brown Jackson

Martin v. United States, No. 24-362 (2025), is a pending U.S. Supreme Court case regarding the limitations of the Federal Tort Claims Act (FTCA), a federal law which allows private parties to sue the federal government for torts (civil wrongs) committed by persons acting on behalf of the federal government.

On October 18, 2017, a team of SWAT agents of the Federal Bureau of Investigation raided the home of Trina Martin, her partner at the time Toi Cliatt, and Martin's 7-year-old son. The agents forcefully entered the house with guns drawn using a battering ram and flash grenades. After handcuffing Cliatt and questioning him, the agents realized they had entered the wrong house by mistake. They had intended to arrest a suspected gang member who lived nearby.

In 2019, Martin and Cliatt sued the federal government under the FTCA for the wrong-house raid. A federal judge initially dismissed the case, and the U.S. Court of Appeals for the Eleventh Circuit upheld that dismissal, holding that the FTCA's "discretionary-function exception", as well as the Constitution's Supremacy Clause, prevents Martin and Cliatt from bringing their claims under the FTCA. The Supreme Court granted certiorari on January 27, 2025. The court heard oral arguments on April 29, 2025. A decision is expected by June or July 2025.

Background

Federal Tort Claims Act

Main article: Federal Tort Claims Act

The doctrine of sovereign immunity ordinarily prevents private individuals from suing the United States federal government, except in cases where Congress allows the federal government to be sued. In 1946, Congress enacted the Federal Tort Claims Act (FTCA) to allow private persons to sue the federal government in cases where a government employee commits a tort (a civil wrong) "while acting within the scope of" their position in the government.

The FTCA has a number of exceptions, however, one of which is called the "discretionary function exception", which prevents the FTCA from being used to sue the government when the claims are "based on an employee’s performance or failure to perform 'a discretionary function or duty ... whether or not the discretion involved be abused.'" According to the Harvard Law Review, lower courts have applied a broad interpretation of this exception, allowing the government to succeed in invoking it to dismiss "nearly seventy-five percent of claims". At the same time, however, the FTCA has a provision called the "law-enforcement proviso", which specifically allows for persons to sue the government for "claims arising out of 'assault, battery, false imprisonment, false arrest, abuse of process, or malicious prosecution' committed by federal law-enforcement officers".

Wrong-house raid

On the morning of October 18, 2017, a team of six SWAT agents led by Lawrence Guerra of the Federal Bureau of Investigation forcefully entered a home near Atlanta, Georgia, seeking to arrest a suspected gang member named Joseph Riley. In fact, the home was occupied by Trina Martin; Toi Cliatt, Martin's boyfriend at the time; and Martin's son Gabe, who was seven years old at the time. The agents broke down the door using a battering ram and then set off a flash grenade. Upon hearing the noise, Cliatt stated that he initially thought of reaching for his shotgun but hesitated, thinking the intruders might be law enforcement. He and Martin then hid a closet, unable to reach Martin's son, who cried for her from another room and hid under his bed. According to court documents, after the agents handcuffed Cliatt, one of them noticed that he did not have the tattoos they expected on the intended target of the raid. When the agent asked Cliatt for his name and address, that was when they realized they had entered the wrong house. The agents then left and arrested the intended target at the correct house, who was later convicted. Guerra, the lead FBI agent, later returned to apologize and gave Martin and Cliatt the business card of his supervisor. In total, the FBI spent some five minutes in Martin and Cliatt's house.

Martin, Cliatt, and Martin's son have stated that they suffered psychological trauma from the incident. In an article published by the Associated Press, Martin stated that she had to quit being a track coach "because the starting pistol reminded her of the flashbang grenade the agents set off". In the same article, Cliatt stated that he developed problems sleeping, which led him to quit his job as a truck driver. In an article published in 2025 by ABC News, Martin's son Gabe—who was now 13—stated that "the experience dramatically altered his life" and that he "didn't really have a childhood growing up because of that".

Lower court proceedings

In 2019, Martin and Cliatt sued the federal government under the Federal Tort Claims Act, bringing claims of "false arrest, negligence, false imprisonment, and assault and battery", among others. A judge in the U.S. District Court for the Northern District of Georgia dismissed Martin and Cliatt's case in 2022, and a panel of the U.S. Court of Appeals for the Eleventh Circuit affirmed that decision in 2024. The court of appeals held that Martin and Cliatt could not bring their claims under the FTCA for two reasons. First, the Eleventh Circuit held that the Supremacy Clause of the U.S. Constitution, which states that federal laws and the federal Constitution take precedence over state laws, prevents Martin and Cliatt from bringing liability claims against the federal government based on state law when the government's actions "'have some nexus with furthering federal policy' and 'can reasonably be characterized as complying with the full range of federal law'". Second, the Eleventh Circuit also held that the discretionary function exception prevents Martin and Cliatt from bringing their claims under the FTCA, even though some of the claims may fall under the law enforcement proviso.

Supreme Court

The Supreme Court granted certiorari on January 27, 2025, limited to two questions:

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 be reasonably characterized as complying with the full range of federal law."
2. "Whether the discretionary-function exception is categorically inapplicable to claims arising under the law enforcement proviso to the intentional torts exception."

Oral argument

The court heard oral arguments on April 29, 2025. Counsel for petitioners Martin and Cliatt argued that the FTCA discretionary function exception never applies to claims under the law enforcement proviso, while the government argued that the law enforcement proviso does not create "an exception to the discretionary function exception". An article published by NBC News reported that the "justices did not seem too impressed by either side's arguments" during the oral argument, and it speculated that the court would hand down a "narrow win" for Martin and Cliatt but also "allow a lower court another chance to decide whether the claims are covered by the discretionary function exception". On the question of the Supremacy Clause, the government conceded that the Eleventh Circuit erred but argued that the discretionary function exception meant that the Supreme Court did not need to decide on that question. The Supreme Court appointed a separate lawyer to defend the Eleventh Circuit's Supremacy Clause argument, but according to an analysis published in SCOTUSblog, "the justices had relatively few questions for him" during oral argument.

See also

• List of pending United States Supreme Court cases

External links

• Martin v. United States on Oyez
• Martin v. United States on SCOTUSblog