Martin v. United States
The Supreme Court unanimously ruled that a family wrongly raided by an FBI SWAT team can move forward with their lawsuit against the federal government, clearing away two faulty legal doctrines that a federal appeals court had used to shield the government from accountability.
The decision rejects an approach used only by courts in the Southeast — one that had made it uniquely hard for victims of mistaken federal law enforcement raids to recover damages — and sends the case back to be reconsidered under the correct rules.
How it got here: A federal district court granted the government summary judgment on all claims; the Eleventh Circuit affirmed using its unique two-part approach; the family asked the Supreme Court to step in and the Court agreed to hear the case.
The Case in Depth
What happened
In October 2017, an FBI SWAT team broke down the front door of a quiet suburban Atlanta home with a flash-bang grenade, dragged the male occupant from a closet, pinned the female occupant at gunpoint while she lay half-undressed on the floor, and terrorized her 7-year-old son — before an officer found a piece of mail and realized they had the wrong address entirely. The agents had been led to the wrong street by a personal GPS device. The family sued the federal government for personal injuries and property damage.
The question before the Court
After FBI agents mistakenly raided an innocent family's home — assaulting the occupants and causing property damage — could the family sue the federal government, and had the appeals court been applying the wrong legal rules to block such suits?
The Court's answer
On the first question: No — a specific provision called the law enforcement proviso removes only the intentional-tort exception for claims against federal law enforcement officers; it does not also override the separate discretionary-function exception. The Eleventh Circuit was therefore wrong to automatically advance intentional-tort claims past that second immunity hurdle. Whether the discretionary-function exception actually blocks these specific claims must be decided by the lower court on remand, under the correct framework.
On the second question: the government cannot invoke the Supremacy Clause — the constitutional rule that federal law beats conflicting state law — as a special defense in these suits. Because the law governing government lawsuits (the FTCA) expressly makes the government liable under the same state law rules that would apply to any private person, there is typically no federal-state conflict for the Supremacy Clause to resolve. The 19th-century precedent the Eleventh Circuit relied on involved shielding an individual federal marshal from a state murder prosecution — a very different situation from Congress expressly binding the federal government to state tort liability on the same terms as private parties.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
People wrongly targeted by federal law enforcement raids now have a clearer path to sue the government for their injuries. A constitutional defense — available nowhere else in the country — that automatically shielded federal agents in Southeastern courts is gone. The case also signals that courts may not use a broad discretionary immunity doctrine to protect careless or ministerial errors by federal officers.
What changes now
The case returns to the Eleventh Circuit, which must reconsider from scratch whether the discretionary-function exception bars the family's negligence claims, intentional-tort claims, or both — this time without the mistaken assumption that the law enforcement proviso automatically shields intentional-tort claims from that analysis. If any claims survive, the court must assess liability under Georgia state law. The Supreme Court declined to resolve broader circuit disagreements about the exact scope of the discretionary-function exception, leaving those questions for a future case.
What this does not decide
The Court did not decide whether the discretionary-function exception ultimately bars this specific family's claims. It also left unresolved persistent circuit disagreements about whether that exception covers careless conduct, unconstitutional conduct, or ministerial tasks — questions Justice Sotomayor flagged as overdue for the Court's attention.
Concurrences and dissents
Concurrence — Justice Sotomayor
Justice Sotomayor joins the majority in full but writes separately to signal that the discretionary-function exception likely should not shield Agent Guerra's conduct on remand. She argues that checking a GPS, reading a street sign, and confirming a house number before breaking down a door resemble the Court's negligent-driving hypothetical — individual carelessness, not a policy judgment — and therefore may fall outside the exception's protection. She also calls on the Court to directly address the exception's long-unsettled boundaries in a future case, noting it has been 34 years since the Court last weighed in.
How the Court got there
The legal reasoning, step by step
- The Federal Tort Claims Act (FTCA) waives the government's usual immunity from lawsuits for torts committed by federal employees, but carves out 13 exceptions — including the intentional-tort exception (blocking certain claims for harms like assault and battery) and the discretionary-function exception (blocking claims that second-guess an official's judgment calls). Both exceptions were relevant here.
- A 'law enforcement proviso' embedded inside the intentional-tort exception (subsection (h)) restores the right to sue when federal law enforcement officers commit specific torts like assault or battery. The Court applied the baseline rule that statutory provisos modify only the provision in which they appear — like a 'Steak: If there is a sale' note on a grocery list that applies to steak alone, not to everything else on the list.
- Multiple textual signals confirmed the proviso's limited reach: it shares the same sentence and subsection as the intentional-tort exception; it covers the same subject matter (intentional torts) while the other 12 exceptions cover entirely different topics; its own definitional sentence explicitly limits its definition of 'investigative or law enforcement officer' to 'this subsection'; and Congress chose to embed it mid-list rather than append it at the end, as it does when it intends a proviso to apply broadly. Legislative history suggesting a broader intent cannot override what the statute's text clearly says.
- On the Supremacy Clause defense: The FTCA is itself the supreme federal law governing government tort liability, and it expressly makes the government liable under the same state law standard as a private individual. Because the federal statute incorporates state law rather than conflicting with it, there is ordinarily no clash for the Supremacy Clause to resolve — in this case, Georgia tort law governed, and Georgia would allow a private person to be sued for what the agents did.
- The Eleventh Circuit had leaned on In re Neagle (an 1890 case) to justify the Supremacy Clause defense. The Court distinguished that case: it dealt with shielding an individual federal marshal from a state criminal murder prosecution for actions he was duty-bound to take, not with a statute that expressly binds the federal government to state tort liability on the same terms as private parties. A private person could never invoke In re Neagle, but the FTCA puts the government on the same footing as private parties.
- The Court sent the case back for the Eleventh Circuit to apply the discretionary-function exception correctly — asking at each step whether Agent Guerra's conduct involved a real element of judgment and, if so, whether that judgment was the kind grounded in policy considerations that Congress meant to shield from judicial second-guessing. Any surviving claims must then be measured against Georgia state law, not a Supremacy Clause defense.
Doctrinal impact
Cases affected by this decision
Distinguishes In re Neagle (135 U.S. 1)
That case shielded an individual federal officer from a state murder prosecution; it does not apply where Congress has expressly bound the government to state tort liability.