Martin v. United States
145 S. Ct. 1689, 605 U.S. 395 (2025)
Rule of Law:
The law enforcement proviso in the Federal Tort Claims Act modifies only the intentional-tort exception in § 2680(h), not the discretionary-function exception in § 2680(a), and the Supremacy Clause does not provide the United States with an independent defense against liability under the Act.
Facts:
- FBI Agent Guerra prepared to execute search and arrest warrants at a suspected gang hideout located at 3741 Landau Lane.
- On the day of the raid, Agent Guerra relied on a personal GPS device that incorrectly navigated the SWAT team to 3756 Denville Trace.
- The SWAT team failed to notice the street sign for 'Denville Trace' and the specific house number visible on the mailbox.
- Agents breached the front door of the plaintiffs' home, detonated a flash-bang grenade, and stormed the residence.
- The agents discovered occupants Cliatt and Martin hiding in a bedroom closet, dragged them out, threw them to the floor, and handcuffed them.
- An officer eventually found mail inside the home bearing the address, leading the team to realize they had raided the wrong house.
Procedural Posture:
- The plaintiffs sued the United States in the U.S. District Court for the Northern District of Georgia.
- The District Court granted summary judgment in favor of the United States.
- The plaintiffs appealed to the U.S. Court of Appeals for the Eleventh Circuit.
- The Eleventh Circuit affirmed the judgment of the District Court.
- The plaintiffs petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does the law enforcement proviso in the Federal Tort Claims Act override the statute's discretionary-function exception, and does the Supremacy Clause afford the United States a defense against tort liability?
Opinions:
Majority - Justice Gorsuch
No, the proviso does not override the discretionary-function exception, and the Supremacy Clause does not grant the government a special defense. The text and structure of the Federal Tort Claims Act (FTCA) place the law enforcement proviso strictly within subsection (h), which addresses intentional torts. Statutory provisos generally modify only the provision to which they are attached, and the grammatical structure of § 2680 confirms that each exception is a distinct provision. Regarding the Supremacy Clause, the FTCA explicitly waives sovereign immunity and accepts liability under state law rules applicable to private individuals. Because the federal statute incorporates state law, there is no conflict between state and federal law for the Supremacy Clause to resolve. The precedent of In re Neagle applies to immunity from state criminal prosecution, not civil liability where Congress has legislated a waiver.
Concurring - Justice Sotomayor
Yes, the Court correctly interprets the statute, but on remand, the lower court should apply the discretionary-function exception with skepticism regarding these specific facts. The discretionary-function exception is designed to protect decisions based on social, economic, and political policy, not mere carelessness. Negligent actions such as following a personal GPS to the wrong address or failing to read street signs likely do not involve the type of policy judgment the statute intends to shield.
Analysis:
This decision resolves a circuit split by rejecting the Eleventh Circuit's unique 'plaintiff-friendly' reading of the proviso combined with its 'defendant-friendly' Supremacy Clause defense. By strictly limiting the law enforcement proviso to the intentional-tort exception, the Court clarifies that plaintiffs suing for police misconduct must independently satisfy the discretionary-function exception. However, by eliminating the novel Supremacy Clause defense, the Court ensures that the government cannot evade liability solely by claiming a 'nexus' to federal policy when state law would otherwise impose liability on a private person. This returns the focus of FTCA litigation to the text of the statute and the applicable state tort law.
