马丁诉美国案

On October 18, 2017, an FBI SWAT team mistakenly raided the home of Curtrina Martin, Hilliard Toi Cliatt, and her 7-year-old son in suburban Atlanta, Georgia. The agents intended to execute warrants at a suspected gang hideout on Landau Lane but instead stormed 3756 Denville Trace. The error stemmed from Special Agent Guerra's reliance on a personal GPS device and the team's failure to notice the correct street sign and house number. The family suffered personal injuries and property damage. They sued the United States under the Federal Tort Claims Act (FTCA), seeking damages. The district court granted summary judgment to the government, and the Eleventh Circuit affirmed. The Supreme Court granted certiorari on January 27, 2025, heard arguments on April 29, 2025, and decided the case on June 12, 2025.

The Supreme Court unanimously vacated the Eleventh Circuit's decision and remanded the case. Justice Neil Gorsuch authored the unanimous opinion. The Court held that the law enforcement proviso in §2680(h) overrides only the intentional-tort exception, not the discretionary-function exception or other exceptions. The Court also held that the Supremacy Clause does not afford the United States a defense in FTCA suits. Justice Sotomayor filed a concurring opinion, joined by Justice Jackson. The case was remanded to the Eleventh Circuit to reconsider whether the discretionary-function exception bars the plaintiffs' claims.

Whether the federal government could be held liable under the FTCA for an FBI raid mistakenly carried out on the wrong house. The key issues were: (1) whether the law enforcement proviso in §2680(h) overrides only the intentional-tort exception or all exceptions including the discretionary-function exception; and (2) whether the Supremacy Clause provides the United States a defense in FTCA suits.

The unanimous decision was praised as a victory for victims of government overreach and federal accountability. The ruling clarified two critical aspects of FTCA jurisprudence that had been interpreted inconsistently by lower courts. It reinforced that federal law enforcement officers can be held accountable for tortious conduct and that the Supremacy Clause does not shield the government from liability. The decision also highlighted ongoing concerns about the discretionary-function exception, which critics argue has been expanded to swallow the FTCA's remedial purpose. Justices Sotomayor and Jackson suggested the exception may not apply to claims like these, signaling potential future refinement of FTCA doctrine.