Martin v. United States

Background

On October 18, 2017, an FBI SWAT team intended to search 3741 Landau Lane but instead stormed 3756 Denville Trace in suburban Atlanta, damaging property and assaulting a family: Hilliard Toi Cliatt, his partner Curtrina Martin, and her 7‑year‑old son. The family sued the United States under the Federal Tort Claims Act (FTCA) for negligent and intentional torts. The district court granted summary judgment for the government, and the Eleventh Circuit affirmed using a unique approach to the FTCA that broadened a law‑enforcement proviso and allowed a Supremacy Clause defense.

Reasoning

The Court addressed two questions: whether the FTCA’s law‑enforcement proviso applies only to the intentional‑tort exception, and whether the Supremacy Clause provides a defense to FTCA suits. Relying on the statute’s text and structure, the Court held the proviso modifies only subsection (h)’s intentional‑tort exception, not the separate discretionary‑function exception. The Court also held the Supremacy Clause does not supply a standalone defense to defeat FTCA claims because Congress made the FTCA the exclusive federal rule for the government’s tort liability and incorporated state tort law as the usual rule for liability.

Real world impact

The decision means intentional‑tort claims against federal law‑enforcement officers can proceed past subsection (h) but still may be subject to the discretionary‑function exception and ordinary state‑law defenses; the government cannot escape FTCA liability by invoking a Supremacy Clause defense. The case is vacated and sent back so the Eleventh Circuit can reevaluate discretionary‑function and state‑law liability issues.

Dissents or concurrances

Justice Sotomayor (joined by Justice Jackson) concurred, noting the discretionary‑function exception’s scope remains unsettled and urging careful review on remand to protect cases like wrong‑house raids.