The United States Supreme Court has agreed to hear Martin v. United States, a case that could have serious implications for individuals seeking to hold the federal government accountable for wrongful actions during law enforcement operations.
At the heart of the case is whether a Georgia family can sue the federal government after FBI agents mistakenly raided their home in 2015.
The case raises two important questions:
- Whether the Constitution’s Supremacy Clause bars claims under the Federal Tort Claims Act (FTCA) when federal actions further government policy, and
- Whether the discretionary-function exception shields law enforcement from liability in cases like this one.
Let’s take a closer look.
The mistaken raid that traumatized a Georgia family
On an early morning in 2015, Curtrina “Trina” Martin, Hilliard “Toi” Cliatt, and Martin’s young son Gabriel were startled awake in their suburban Atlanta home.
FBI agents armed with a no-knock warrant burst into their house, deployed a flashbang grenade, and pointed guns at the family.
Gabriel, just eight years old at the time, recalls, “I woke up and thought we were being robbed.”
Martin and Cliatt, fearing for their lives, hid in a closet until agents dragged Cliatt out and handcuffed him at gun point.
The FBI, which had intended to enter the home of Joseph Riley, an alleged gang member, soon realized they were in the wrong house. The intended target’s home was less than 500 feet away, on a different street with a similar address.
The FBI agents quickly apologized and moved on to the correct home.
The damage, however, was already done. While the family’s shattered front door was certainly an annoyance, the lasting emotional trauma they endured was far more devastating.
“This part chokes me up. It chokes me up all the time… that I couldn’t protect my child,” Martin said.
Despite a federal law—the FTCA—that allows individuals to sue the government for wrongful actions by federal employees, Martin and Cliatt’s lawsuit was dismissed by the Eleventh Circuit Court of Appeals. The court ruled that the claims were barred by the supremacy clause and the discretionary-function exception. Now, the Supreme Court will decide whether these legal doctrines shield the government from liability.
What is the Federal Tort Claims Act?
The FTCA, enacted in 1946, provides individuals with an avenue for suing the federal government for wrongful or negligent acts committed by federal employees.
Under the FTCA, the government waives its sovereign immunity in cases where a private individual would be held liable under similar circumstances.
In 1974, legislators specifically added language (referred to as the “law enforcement proviso”) emphasizing that this waiver includes situations where federal law enforcement officers commit intentional torts like assault, battery, and false imprisonment.
However there are exceptions to the waiver.
One notable exception is the discretionary-function exception, which protects government officials from liability for actions involving policy-driven discretion.
What is the discretionary-function exception?
The discretionary-function exception shields the federal government from lawsuits when employees perform actions or make decisions grounded in policy judgment or discretion. This means that when federal employees must weigh various policy considerations—such as public safety, resource allocation, or national security—their decisions are protected from liability, even if those decisions result in harm.
The purpose of this exception is to prevent courts from second-guessing legislative and administrative decisions that involve complex policy tradeoffs. It recognizes that some government functions require judgment and flexibility and that holding the government liable for every mistake could hinder effective governance.
Examples of the discretionary-function exception in action include:
- A federal agency decides how to allocate disaster relief funds after a hurricane. If someone believes the allocation was unfair or harmful, the agency’s decision would likely be protected under the discretionary-function exception.
- The National Park Service chooses not to install additional warning signs on a hiking trail, and a hiker is injured. The decision, based on budget and environmental considerations, would likely fall under the exception.
Courts have grappled with how the discretionary-function exception interacts with the law enforcement proviso.
The key legal issues
The Supreme Court will address two pivotal questions in Martin v. United States:
- Does the supremacy clause bar claims under the FTCA? The government argues that federal actions linked to advancing federal policy are protected by the supremacy clause, which establishes that federal law overrides conflicting state laws. The Eleventh Circuit agreed, reasoning that the FBI’s actions had a nexus with federal policy.
- Does the discretionary-function exception apply to law enforcement actions? The discretionary-function exception shields federal officials from liability for decisions involving judgment or policy. Martin and Cliatt’s attorneys argue that this exception should not apply when agents’ actions violate the law enforcement proviso.
You can read the court documents that have been filed in the case here.
Broader implications for innocent victims of no-knock mistakes
Mistaken raids are not uncommon.
The outcome of this case could impact how future claims against federal law enforcement are handled under the FTCA. If the Court limits the scope of the discretionary-function exception, victims of wrongful raids (and similar actions) may find it easier to seek compensation for their losses.
“When police—including the FBI—raid the wrong house, they must be held responsible for the damages,” said Anya Bidwell, an attorney with the Institute for Justice, which represents the family.
On the other hand, a ruling in favor of the government could reinforce the broad immunity federal law enforcement currently enjoys, leaving victims without recourse.
Can you sue the government for a wrongful raid?
The answer, for now, is complicated. Under the FTCA, you can sue the government if a federal employee’s actions would make a private individual liable under state law. However, exceptions like the discretionary-function rule often make these cases difficult to win.
Mistaken raids highlight the tension between public safety and individual rights. While law enforcement agencies argue that split-second decisions are necessary to ensure public safety, victims like Martin and Cliatt point to the lasting harm caused by these errors.
The Supreme Court’s decision in Martin v. United States will provide clarity on whether innocent victims of federal law enforcement mistakes can seek justice.
What to do if you’re the victim of a botched raid
If your home has been mistakenly raided by law enforcement, consider taking these steps:
- Document the incident: Take photos of any damage, such as broken doors or windows, and keep detailed notes about what happened. Record dates, times, and any statements made by law enforcement officers.
- Preserve evidence: Avoid cleaning up or repairing damage until you’ve documented everything. Save security camera footage, if available, and gather witness accounts from neighbors or others who may have seen the incident.
- Seek medical or emotional support: If anyone in your household was physically harmed or emotionally traumatized, obtain medical or psychological evaluations.
- Consult an attorney: Find a lawyer experienced in Federal Tort Claims Act cases and law enforcement liability. They can help you understand your rights and build a strong case.
- File a claim promptly: Under the FTCA, there are strict deadlines for filing a claim against the government. An attorney can help ensure you meet these deadlines.