2025 Supreme(US)(scotus) 5391
SUPREME COURT OF THE UNITED STATES
Neil Gorsuch
Martin – Appellant
Versus
United States – Respondent
Syllabus
NOTE: Where it is feasible, a syllabus (headnote) will be released, as is
being done in connection with this case, at the time the opinion is issued.
The syllabus constitutes no part of the opinion of the Court but has been
prepared by the Reporter of Decisions for the convenience of the reader.
See United States v. Detroit Timber & Lumber Co.,
SUPREME COURT OF THE UNITED STATES
Syllabus MARTIN, INDIVIDUALLY AND AS PARENT AND NEXT FRIEND OF G. W., A MINOR, ET AL. v. UNITED STATES ET AL. CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE ELEVENTH CIRCUIT
No. 24–362. Argued April 29, 2025—Decided June 12, 2025
On October 18, 2017, the FBI raided the wrong house in suburban At- lanta. Officers meant to execute search and arrest warrants at a sus- pected gang hideout at 3741 Landau Lane but instead stormed 3756 Denville Trace, a quiet family home occupied by petitioners Hilliard Toi Cliatt, his partner Curtrina Martin, and her 7-year-old son. A six- member SWAT team breached the front door, detonated a flash-bang grenade, and assaulted the innocent occupants before realizing their mistake. The cause of the error was Special Agent Guerra’s reliance on a personal GPS device, combined with the team’s failure to notice the street sign for “Denville Trace” and the house number visible on the mailbox. Left with personal injuries and property damage, peti- tioners sued the United States under the Federal Tort Claims Act (FTCA), 28 U. S. C. §2671 et seq., seeking damages resulting from the officers’ alleged negligent and intentional actions during the raid. The district court granted summary judgment to the government. The Eleventh Circuit affirmed, applying a unique approach to FTCA claims. The FTCA waives the federal government’s sovereign immunity from suit as to certain torts committed by federal employees acting within the scope of their employment. But that waiver is subject to statutory exceptions, including two relevant to a law enforcement mis- conduct case like this one. The first is the intentional-tort exception in §2680(h), which bars claims against the government for 11 enumer- ated intentional torts. The second is the discretionary-function excep- tion in §2680(a), which bars claims against the government that are based on an official’s exercise of discretionary functions. Section 2 MARTIN v. UNITED STATES
Syllabus
2680(h) also contains a “law enforcement proviso” which counter-
mands the intentional-tort exception, allowing suits for six specified
torts (including assault, battery, false imprisonment, and false arrest)
to proceed against the United States when the torts are committed by
“investigative or law enforcement officers.” While most courts hold
that the law enforcement proviso applies only to the intentional-tort
exception, the Eleventh Circuit’s approach is different in two key re-
spects. First, the Eleventh Circuit alone holds that the proviso over-
rides all exceptions in §2680, including the discretionary-function ex-
ception, meaning that intentional-tort claims covered by the proviso
automatically proceed to the merits without further analysis of other
applicable §2680 exceptions. Second, to compensate for this plaintiff-
friendly approach, the Eleventh Circuit permits the government to as-
sert a restrictive Supremacy Clause defense at the liability stage, al-
lowing the government to escape liability when an officer’s actions
have “some nexus with furthering federal policy” and reasonably “com-
ply[ ] with the full range of federal law.” Denson v. United States,