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Martin v. United States (2025)

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Supreme Court of the United States
Martin v. United States (2025)
Term: 2024
Important Dates
Argued: April 29, 2025
Decided: June 12, 2025
Outcome
vacated and remanded
Vote
9-0
Majority
Neil GorsuchChief Justice John RobertsClarence ThomasSamuel AlitoElena KaganBrett KavanaughAmy Coney Barrett
Concurring
Sonia SotomayorKetanji Brown Jackson

Martin v. United States is a case that was decided by the Supreme Court of the United States on June 12, 2025, during the court's October 2024-2025 term. The case was argued before the Supreme Court of the United States on April 29, 2025.

HIGHLIGHTS
  • The issue: The case concerned the Constitution's Supremacy Clause and the Federal tort Claims Act (FTCA). Click here to learn more about the case's background.
  • The questions presented: "1. Whether the Constitution's Supremacy Clause bars claims under the FTCA-a federal statute enacted by Congress-when the negligent or wrongful acts of federal employees 'have some nexus with furthering federal policy and can reasonably be characterized as complying with the full range of federal law.' Pet. App. 17a (quotation omitted). 2. Whether the FTCA's discretionary-function exception bars claims for torts arising from wrong-house raids and similar negligent or wrongful acts by federal employees."[1]
  • The outcome: The Court vacated and remanded the decision of the United States Court of Appeals for the Eleventh Circuit in a 9-0 ruling, holding that "[t]he law enforcement proviso in §2680(h) overrides only the intentional-tort exception in that subsection, not the discretionary-function exception or other exceptions throughout §2680... [and that t]he Supremacy Clause does not afford the United States a defense in FTCA suits." Justice Neil Gorsuch delivered the majority opinion of the court.[2] Click here for more information about the ruling.

  • The case came on a writ of certiorari to the United States Court of Appeals for the Eleventh Circuit. To review the lower court's opinion, click here.

    Background

    Case summary

    The following are the parties to this case:[3]

    • Petitioner: Curtrina Martin, Individually and as Parent and Next Friend of G. W., a Minor, et al.
      • Legal counsel: Patrick Michael Jaicomo (Institute for Justice)
    • Respondent: United States

    The following summary of the case was published by Oyez, a free law project from Cornell’s Legal Information Institute, Justia, and the Chicago-Kent College of Law:[4]

    In October 2017, six FBI agents, led by Special Agent Lawrence Guerra, mistakenly executed a no-knock search warrant at the home of Curtrina Martin and her family in Atlanta, Georgia. The intended target was a nearby home suspected to contain violent gang member Joseph Riley. Due to similarities between the two properties and issues with navigating to the correct address, the agents entered Martin’s home instead. The SWAT team, in full tactical gear, entered the house, causing fear and distress to its occupants. They later realized the mistake and promptly left the scene, later apologizing and assuring the family that the FBI would handle any damages.

    Martin and her family sued the U.S. government and the agents, claiming violations of their Fourth Amendment rights and seeking damages under Georgia state law. The district court granted summary judgment for the defendants. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the decision, ruling that the agents were entitled to qualified immunity and that the Federal tort Claims Act claims were barred by the Supremacy Clause and the Discretionary function exception.[5]

    To learn more about this case, see the following:

    Timeline

    The following timeline details key events in this case:

    Questions presented

    The petitioner presented the following questions to the court:[1]

    Questions presented:
    1. Whether the Constitution's Supremacy Clause bars claims under the FTCA-a federal statute enacted by Congress-when the negligent or wrongful acts of federal employees "have some nexus with furthering federal policy and can reasonably be characterized as complying with the full range of federal law." Pet. App. 17a (quotation omitted). 2. Whether the FTCA's discretionary-function exception bars claims for torts arising from wrong-house raids and similar negligent or wrongful acts by federal employees[5]

    Oral argument

    Audio

    Audio of oral argument:[6]



    Transcript

    Transcript of oral argument:[7]

    Outcome

    In a 9-0 opinion, the court vacated and remanded the judgment of the United States Court of Appeals for the Eleventh Circuit, holding that "[t]he law enforcement proviso in §2680(h) overrides only the intentional-tort exception in that subsection, not the discretionary-function exception or other exceptions throughout §2680... [and that t]he Supremacy Clause does not afford the United States a defense in FTCA suits." [2] Justice Gorsuch delivered the opinion of the court.

    Opinion

    In the court's majority opinion, Justice Neil Gorsuch wrote:[2]

    If federal officers raid the wrong house, causing property damage and assaulting innocent occupants, may the homeowners sue the government for damages? The answer is not as obvious as it might be. All agree that the Federal Tort Claims Act permits some suits for wrong-house raids. But the scope of the Act’s permission is much less clear. This case poses two questions about the Act’s application: one concerning the FTCA’s sovereign-immunity waiver, and the other touching on the defenses the United States may assert. [5]

    —Justice Neil Gorsuch

    Concurring opinion

    Justice Sonia Sotomayor filed a concurring opinion, joined by Justice Ketanji Brown Jackson.

    In her concurring opinion, Justice Sotomayor wrote:[2]

    The law enforcement proviso modifies only the subsection in which it is located: Section 2680(h)’s intentional-tort exception. Ante, at 6–11. The United States, moreover, may not defeat an FTCA suit simply by “showing that a federal officer’s acts had ‘some nexus with furthering federal policy’ and ‘compli[ed] with the full range of federal law.’” Ante, at 11–12 (alteration in original). With those two principles clarified, I also agree that the Eleventh Circuit must now consider on remand whether the FTCA’s discretionary-function exception bars plaintiffs’ negligent- and intentional-tort claims. Ante, at 17–18. I write separately to underscore that there is reason to think the discretionary-function exception may not apply to these claims. [5]

    —Justice Sonia Sotomayor

    Text of the opinion

    Read the full opinion here.

    October term 2024-2025

    See also: Supreme Court cases, October term 2024-2025

    The Supreme Court began hearing cases for the term on October 7, 2024. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[8]

    See also

    External links

    Footnotes