Martin v. United States

civil rights litigationwrong-house raidfederal law enforcementFTCAgovernment accountabilityLandmark

Summary

Martin held that the FTCA law-enforcement proviso applies only to the intentional-tort exception in § 2680(h), not to the discretionary-function exception. It also held that the Supremacy Clause does not give the federal government a special defense in FTCA suits. The case returns to the lower court to decide remaining issues.

Background & Context

The FTCA lets people sue the United States for some torts by federal employees, but it contains many exceptions. A law-enforcement proviso allows certain intentional-tort claims against investigative or law-enforcement officers. The dispute was how that proviso interacts with other FTCA exceptions and whether the Supremacy Clause supplies a government defense.

The Question Before the Court

How does the FTCA law-enforcement proviso interact with the discretionary-function exception, and does the Supremacy Clause provide a defense to the United States in FTCA suits?

Petitioner

Curtrina Martin, et al.

Party asking the Court to review or reverse

Argued

The plaintiffs could sue under the law-enforcement proviso and the Supremacy Clause defense was wrong.

Respondent

United States

Party defending the judgment below

Argued

The discretionary-function exception still matters.

The Holding

The FTCA's law-enforcement proviso overrides only the intentional-tort exception, not the discretionary-function exception, and the Supremacy Clause does not give the United States a special defense in FTCA suits.

The Court

How the justices lined up in this decision.

9-0

Vote

Joined decision

9 justices

Amy Barrett

Majority

Brett Kavanaugh

Majority

Clarence Thomas

Majority

Elena Kagan

Majority

John Roberts

Majority

Ketanji Jackson

Majority

Neil Gorsuch

Majority

Samuel Alito

Majority

Sonia Sotomayor

Majority

What this means for you

The ruling matters for victims of federal law-enforcement mistakes because it rejects a special shield that made it harder to hold the United States liable. But it also leaves the discretionary-function exception available on remand, meaning victims still face a serious procedural hurdle.

Key Takeaways

The ruling involved a mistaken FBI raid on the wrong home.
The law-enforcement proviso does not override every FTCA exception.
The Supremacy Clause is not a special FTCA defense for the United States.
The Court vacated and remanded for further proceedings.
The practical effect is a narrower but still meaningful path for wrong-house raid claims.