Martin v. United States, 605 U.S. 395

Background

In 2017, FBI agents mistakenly raided the wrong house in suburban Atlanta, assaulting and injuring innocent occupants (Martin, Cliatt, and Cliatt's son).
The error resulted from reliance on incorrect GPS data and failures to confirm the actual street and address.
The victims sued the United States under the Federal Tort Claims Act (FTCA) for damages from alleged negligent and intentional actions during the raid.
The district court granted summary judgment for the government; the Eleventh Circuit affirmed, applying its unique reading of FTCA exceptions.
The Supreme Court reviewed the case to resolve two legal questions about the FTCA’s sovereign immunity exceptions and available government defenses.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Scope of Law Enforcement Proviso	Proviso should override all FTCA §2680 exceptions, including discretionary-function, allowing intentional-tort claims to proceed.	Proviso overrides only the intentional-tort exception in §2680(h), not other exceptions like discretionary-function.	Proviso applies only to §2680(h)'s intentional-tort exception, not the discretionary-function exception or others.
Supremacy Clause Defense	Government may only raise defenses in FTCA as allowed by statute, not a Supremacy Clause defense unique to federal actors.	Eleventh Circuit permitted government to defeat claims if conduct had a nexus to federal policy and complied with federal law (Supremacy Clause defense).	FTCA does not allow a general Supremacy Clause defense; government is liable under FTCA as a private person under the law of the place, absent federal preemption.
Application of Discretionary-Function Exception	Discretionary-function exception should not shield government from liability for wrong-house raids or non-policy-based carelessness.	Discretionary-function exception applies broadly, barring negligence claims and possibly intentional torts linked to agent discretion.	On remand, discretionary-function exception must be applied correctly to both negligence and intentional torts, interpreting the scope consistent with Supreme Court precedent.
State vs. Federal Standards for Liability	Georgia tort law governs liability for FTCA claims arising from officer conduct in Georgia.	Federal interests and policies could preempt state tort liability (per Eleventh Circuit).	FTCA adopts state tort law as the liability standard unless federal law expressly preempts it.

Key Cases Cited

United States v. Detroit Timber & Lumber Co., 200 U.S. 321 (discusses the use of Court-prepared syllabus)
United States v. Gaubert, 499 U.S. 315 (defines and applies the discretionary-function exception under the FTCA)
Berkovitz v. United States, 486 U.S. 531 (addresses when the discretionary-function exception applies)
Millbrook v. United States, 569 U.S. 50 (explains the law enforcement proviso in §2680(h))
Carlson v. Green, 446 U.S. 14 (addresses FTCA liability using state tort law)
In re Neagle, 135 U.S. 1 (Supremacy Clause defense for federal officials in criminal prosecution, not tort liability)
Hui v. Castaneda, 599 U.S. 799 (FTCA is the exclusive remedy for official conduct)
Alaska v. United States, 545 U.S. 75 (statutory construction of provisos)
Jama v. Immigration and Customs Enforcement, 543 U.S. 335 (discusses discrete statutory exceptions)