A Deep Dive Into Martin V. United States – A Landmark Federal Tort Claims Act Case For Personal Injury Claims

By George Creal, Atlanta Personal Injury Lawyer

The Martin v. United States case, decided by the U.S. Supreme Court on June 12, 2025, is a pivotal ruling that clarifies the scope of the Federal Tort Claims Act (FTCA) and its application to Personal Injury Claims arising from federal law enforcement misconduct. This case, stemming from a botched FBI SWAT raid on the wrong house, addresses critical legal questions about government liability for intentional and negligent torts committed by federal officers. For personal injury attorneys and victims of government misconduct, Martin offers valuable insights into navigating the complex interplay of federal immunity, state tort law, and constitutional defenses. In this blog post, I’ll break down the case, its legal significance, and what it means for those seeking justice after wrongful government actions.

The Incident: A Traumatic Wrong-House Raid

The Martin case began with a harrowing incident in Georgia, where Curtrina Martin and her partner, Mr. Cliatt, were subjected to a violent FBI SWAT team raid on their home at 3756 Denville Trace. On the day of the raid, a six-member SWAT team, led by FBI Special Agent Lawrence Guerra, mistakenly targeted the couple’s residence instead of the intended address at 3741 Landau Lane. The team breached the front door, detonated a flash-bang grenade, and stormed the home, believing they were executing a valid search and arrest warrant.

Fearing a home invasion, Martin and Cliatt hid in a bedroom closet. The SWAT team quickly located them, dragging Cliatt from the closet, throwing him to the floor, handcuffing him, and bombarding him with questions. Meanwhile, an officer trained a weapon on Martin, who was lying half-naked on the floor after falling in the closet. Only after the chaos did an officer notice mail with the home’s correct address, revealing the team’s grave mistake. The error was traced to Agent Guerra’s reliance on a personal GPS device, which misdirected him to the wrong address. Compounding the issue, Guerra failed to verify the street sign or house number, and he later discarded the GPS device, leaving no record to confirm the navigational error.

Left with physical injuries, property damage, and significant emotional trauma—but no immediate recourse—Martin and Cliatt filed a lawsuit against the United States under the FTCA, alleging both negligent and intentional torts, including assault, battery, false imprisonment, and negligence.

The Legal Framework: Understanding The FTCA

The FTCA, codified at 28 U.S.C. § 2671 et seq., allows individuals to sue the United States for torts committed by federal employees acting within the scope of their employment. It waives the federal government’s sovereign immunity under specific conditions, making the government liable “in the same manner and to the same extent as a private individual under like circumstances” under the law of the state where the tort occurred (here, Georgia). However, the FTCA includes 13 exceptions that preserve immunity in certain scenarios, two of which are central to this case:

• Intentional-Tort Exception (§ 2680(h)): This exception bars claims for certain intentional torts, such as assault, battery, and false imprisonment, unless the torts are committed by “investigative or law enforcement officers.” The “law enforcement proviso” within this subsection allows claims for six specific torts (assault, battery, false imprisonment, false arrest, malicious prosecution, and abuse of process) to proceed if committed by federal law enforcement officers.
• Discretionary-Function Exception (§ 2680(a)): This exception shields the government from liability for claims based on a federal employee’s exercise of a “discretionary function or duty,” where the action involves judgment or choice and is grounded in policy considerations.

The FTCA’s liability standard generally incorporates state tort law, meaning the government is liable if a private individual would be liable under the same circumstances. However, the Eleventh Circuit’s unique approach to these exceptions and defenses set the stage for the Supreme Court’s review.

The Eleventh Circuit’s Ruling: A Controversial Approach

After the district court granted summary judgment to the government, dismissing all of Martin and Cliatt’s claims, the Eleventh Circuit affirmed, relying on two distinctive interpretations of the FTCA that diverged from other circuits:

• Broad Application of the Law Enforcement Proviso: The Eleventh Circuit held that the law enforcement proviso in § 2680(h) not only overrides the intentional-tort exception but also all other FTCA exceptions, including the discretionary-function exception in § 2680(a). This meant that intentional-tort claims against law enforcement officers automatically proceeded to the merits, bypassing scrutiny under other exceptions.
• Supremacy Clause Defense: To balance this plaintiff-friendly reading, the Eleventh Circuit allowed the government to assert a novel affirmative defense under the Constitution’s Supremacy Clause. This defense defeated claims if the officer’s actions had “some nexus with furthering federal policy” and complied with federal law, even if they violated state tort law.

Applying this framework, the Eleventh Circuit found that the law enforcement proviso spared Martin and Cliatt’s intentional-tort claims from both the intentional-tort and discretionary-function exceptions. However, it dismissed their negligence claims under the discretionary-function exception, reasoning that Agent Guerra’s preparation for the raid involved discretionary decisions. On the intentional-tort claims, the court held that the government prevailed under the Supremacy Clause defense, as the officers’ actions were tied to federal policy (executing a warrant) and complied with federal law. As a result, the United States was granted summary judgment, leaving Martin and Cliatt without relief.

The Supreme Court’s Unanimous Decision

The Supreme Court granted certiorari to address two questions: (1) whether the law enforcement proviso overrides the discretionary-function exception, and (2) whether the Supremacy Clause provides a defense in FTCA suits. In a unanimous opinion authored by Justice Gorsuch, the Court vacated the Eleventh Circuit’s judgment, rejecting both of its outlier positions.

1. The Law Enforcement Proviso Is Limited To § 2680(h)

The Court held that the law enforcement proviso applies only to the intentional-tort exception in § 2680(h), not to other exceptions like the discretionary-function exception in § 2680(a). This conclusion rested on several textual and structural arguments:

• Placement and Grammar: The proviso is embedded within the same sentence and subsection as the intentional-tort exception, suggesting it modifies only that provision. The Court analogized this to a shopping list where a proviso (e.g., “if there is a sale”) applies only to the item it follows, not the entire list.
• Subject Matter Consistency: The proviso and intentional-tort exception both address intentional torts, reinforcing their limited scope. The proviso does not mention issues covered by other exceptions, such as lost mail or combat injuries.
• Definitional Scope: The proviso’s second sentence defines “investigative or law enforcement officer” for “this subsection” (i.e., § 2680(h)), even though the term appears elsewhere in § 2680. This indicates Congress intended a narrow application.
• Statutory Comparison: Unlike provisos placed at the end of a statutory list, which might apply broadly, Congress chose to integrate this proviso into § 2680(h), signaling its limited reach.

The Court rejected the plaintiffs’ arguments for a broader reading, including claims that the proviso’s language mirrored the FTCA’s lead-in clause or that legislative history supported a wider application. The Court emphasized that legislative history cannot override clear statutory text, and Congress’s placement of the proviso within § 2680(h) was decisive.

2. No Supremacy Clause Defense In FTCA Suits

The Court also rejected the Eleventh Circuit’s Supremacy Clause defense, finding no basis for it in the FTCA’s text or structure. The Supremacy Clause resolves conflicts between federal and state law, but the FTCA incorporates state tort law as the liability standard, eliminating such conflicts in most cases. Here, Georgia law would allow claims for assault, battery, and negligence against a private individual, and the FTCA applies the same standard to the government.

The Eleventh Circuit had relied on In re Neagle, 135 US 1, 75 (1890), a case involving a federal officer’s immunity from state criminal prosecution for acts necessary to federal duties. The Supreme Court distinguished Neagle, noting it addressed individual officer immunity, not government liability under a statute that explicitly subjects the United States to state tort law. The FTCA’s defenses, outlined in § 2674, include judicial or legislative immunity and other defenses available to the government, but do not encompass a Supremacy Clause defense. The Court concluded that Congress did not intend to import Neagle’s logic into the FTCA framework.

3. Remand Instructions

The Court vacated the Eleventh Circuit’s judgment and remanded the case for further proceedings. It instructed the lower court to:

• Reassess the Discretionary-Function Exception: The Eleventh Circuit must determine whether the discretionary-function exception bars Martin and Cliatt’s negligent or intentional-tort claims, without assuming the law enforcement proviso overrides § 2680(a).
• Apply Georgia Tort Law: For any claims surviving the discretionary-function exception, the court must evaluate liability under Georgia law, asking whether a private individual would be liable under similar circumstances, subject only to the defenses in § 2674.

The Court declined to resolve broader questions about the discretionary-function exception’s scope, such as whether it applies to careless or unconstitutional conduct, leaving these issues for the Eleventh Circuit to address on remand.

Justice Sotomayor’s Concurrence: A Caution On Discretionary Function

Justice Sotomayor, joined by Justice Jackson, wrote a concurring opinion emphasizing concerns about the discretionary-function exception’s application. She highlighted the two-part test from United States v. Gaubert 499 US 315, 322 (1991), which requires that (1) the conduct involves judgment or choice, and (2) the judgment is based on public policy considerations. Sotomayor questioned the Eleventh Circuit’s suggestion that the exception applies unless federal law “specifically prescribes” a course of conduct, arguing this approach ignores the second Gaubert prong.

Sotomayor drew parallels between Agent Guerra’s actions and Gaubert’s hypothetical of a federal employee negligently driving a car, suggesting that Guerra’s failure to verify the address or notice obvious markers (street signs, house numbers) was not grounded in policy considerations. She also underscored the FTCA’s legislative history, particularly the 1973 amendment adding the law enforcement proviso in response to wrong-house raids like the Collinsville incident. This history suggests Congress intended to allow liability for such misconduct, and courts should interpret the discretionary-function exception accordingly.

Implications For Personal Injury Claims

For personal injury attorneys and victims, Martin v. United States has several key takeaways:

• Clarified Scope of the Law Enforcement Proviso: The ruling ensures that intentional-tort claims against federal law enforcement officers (e.g., assault, battery) can proceed past the intentional-tort exception, but they remain subject to the discretionary-function exception. Attorneys must carefully analyze whether the officer’s actions involved policy-based discretion to avoid dismissal.
• Rejection of the Supremacy Clause Defense: By eliminating this defense, the Court ensures that FTCA claims are judged under state tort law standards, not a vague federal policy nexus. This levels the playing field for plaintiffs, aligning government liability with that of private individuals.
• Focus on the Discretionary-Function Exception: The remand highlights the importance of the discretionary-function exception in FTCA litigation. Attorneys should argue that careless or ministerial actions (e.g., failing to verify an address) lack the policy basis required for immunity, drawing on cases like Rich v. United States 811 F3d 140, 147(4th Cir. 2015) or Xi v. Haugen 68 F4th 824, 842 (3d Cir. 2023).
• Legislative Intent and Wrong-House Raids: Justice Sotomayor’s concurrence reinforces that Congress intended the FTCA to provide remedies for victims of wrong-house raids. This historical context can bolster arguments against overly broad applications of the discretionary-function exception.
• Strategic Litigation in the Eleventh Circuit: Given the Eleventh Circuit’s history of expansive readings of the discretionary-function exception, plaintiffs’ attorneys should emphasize Gaubert’s two-part test and cite circuit splits favoring narrower interpretations to advocate for liability.

What’s Next For Martin And Cliatt?

On remand, the Eleventh Circuit will reassess whether the discretionary-function exception bars Martin and Cliatt’s claims. Key questions include whether Agent Guerra’s failure to verify the address was a discretionary act grounded in policy, or merely careless conduct outside the exception’s protection. If any claims survive, the court will apply Georgia tort law to determine liability, potentially allowing Martin and Cliatt to recover for their injuries and damages.

Conclusion

Martin v. United States is a significant victory for victims of federal law enforcement misconduct, clarifying the FTCA’s framework and removing barriers to recovery in the Eleventh Circuit. By rejecting the Supremacy Clause defense and limiting the law enforcement proviso’s scope, the Supreme Court has reaffirmed the FTCA’s role as a critical avenue for holding the government accountable. For personal injury attorneys, this case underscores the need to navigate the discretionary-function exception strategically, leveraging state tort law and legislative history to secure justice for clients.

If you or a loved one have been harmed by federal government actions, Contact my office today. As an experienced personal injury lawyer, I can help you explore your rights under the FTCA and fight for the compensation you deserve.

George Creal is a personal injury attorney dedicated to advocating for victims of negligence and misconduct. This blog post is for informational purposes and does not constitute legal advice.