Martin v. United States

Supreme Court of the United States · 2025 · Torts

TortsFederal Tort Claims ActSovereign ImmunityIntentional TortsDiscretionary FunctionFTCA28 U.S.C. §2680(h)28 U.S.C. §2680(a)

Facts

In October 2017, FBI officers intended to execute warrants at 3741 Landau Lane but instead raided 3756 Denville Trace, where Curtrina Martin, Hilliard Toi Cliatt, and Martin's 7-year-old son lived. A SWAT team breached the door, deployed a flash-bang grenade, dragged Cliatt from a closet, handcuffed him, and pointed a weapon at Martin before realizing they had entered the wrong home. The mistake stemmed from Special Agent Guerra's use of his personal GPS and the officers' failure to notice the street sign and visible house number. The plaintiffs sued under the FTCA for personal injuries and property damage caused by alleged negligent and intentional torts.

Issue

Does the FTCA's law enforcement proviso in §2680(h) override only the intentional-tort exception in that subsection, or does it also override the discretionary-function exception and other exceptions in §2680? And may the United States defeat FTCA liability by asserting a Supremacy Clause defense based on a federal officer's connection to federal policy and compliance with federal law?

Rule

Under the FTCA, the law enforcement proviso in §2680(h) modifies only the intentional-tort exception contained in subsection (h); it does not displace the discretionary-function exception in §2680(a) or any other exception in §2680. In FTCA suits, the United States' liability is generally determined by whether a private individual under like circumstances would be liable under the law of the place where the act or omission occurred, subject to defenses recognized in §2674, and the Supremacy Clause does not furnish the government a separate defense.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Phoenix, FBI agents executed a search warrant at an apartment after a team leader misread a handwritten address in the briefing packet. During the entry, an agent struck Luis Romero with a rifle butt and handcuffed him before the team realized it had entered the wrong unit. Romero sued the United States under the FTCA for assault and battery by federal law enforcement officers.

The government argues that because Romero's assault and battery claims fall within the FTCA's law enforcement proviso, no other FTCA exception can bar those claims. How should the court rule?

Explanation. The majority held that the law enforcement proviso in §2680(h) modifies only the intentional-tort exception in that same subsection. It does not override §2680(a)'s discretionary-function exception or other §2680 exceptions. So a qualifying assault or battery claim survives subsection (h), but the court must still analyze any separately applicable exception. (Derived from Martin v. United States (n.d.).)