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Martin v. United States (2025): Difference between revisions

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{{DISPLAYTITLE: ''{{PAGENAME}}''}}
{{DISPLAYTITLE: ''{{PAGENAME}}''}}
{{SCOTUS Menu}}
{{SCOTUS Menu}}
{{SCOTUS Infobox 3
{{SCOTUS Infobox 4
|Name = ''Martin v. United States (2025)''
|Name = ''Martin v. United States (2025)''
|Docket = 24-362
|Docket = 24-362
|Term = 2024
|Term = 2024
|Court = [[United States Supreme Court]]
|Court = [[United States Supreme Court]]
|Important dates = {{Greener| start=4/29/2025 10:00am CST| before=Argument:| after=Argued:}} April 29, 2025
|Important dates = {{Greener| start=4/29/2025 10:00am CST| before=Argument:| after=Argued:}} April 29, 2025<br>Decided: June 12, 2025
|Outcome = Pending
|Outcome = {{Vacated}} and {{remanded}}
|Vote =
|Vote =9-0
|Majority =
|Majority =[[Neil Gorsuch]] • [[John Roberts (Supreme Court)|Chief Justice John Roberts]] • [[Clarence Thomas (Supreme Court)|Clarence Thomas]] • [[Samuel Alito]] • [[Elena Kagan]] • [[Brett Kavanaugh]] • [[Amy Coney Barrett]]
|Concurring =
|Concurring =[[Sonia Sotomayor]] • [[Ketanji Brown Jackson]]
|Dissenting=
|Dissenting=
|Court membership = [[John Roberts (Supreme Court)|Chief Justice John Roberts]] • [[Clarence Thomas (Supreme Court)|Clarence Thomas]] • [[Samuel Alito]] • [[Sonia Sotomayor]] • [[Elena Kagan]] • [[Neil Gorsuch]] • [[Brett Kavanaugh]] • [[Amy Coney Barrett]] • [[Ketanji Brown Jackson]]
|Court membership = [[John Roberts (Supreme Court)|Chief Justice John Roberts]] • [[Clarence Thomas (Supreme Court)|Clarence Thomas]] • [[Samuel Alito]] • [[Sonia Sotomayor]] • [[Elena Kagan]] • [[Neil Gorsuch]] • [[Brett Kavanaugh]] • [[Amy Coney Barrett]] • [[Ketanji Brown Jackson]]
}}
}}
'''''Martin v. United States''''' is a case {{Greener| start=4/29/2025 10:00am CST| before=scheduled for argument| after=argued}} before the [[Supreme Court of the United States]] on April 29, 2025, during the court's [[Supreme Court cases, October term 2024-2025|October 2024-2025 term]].  
'''''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  [[Supreme Court cases, October term 2024-2025|October 2024-2025 term]]. The case was {{Greener| start=4/29/2025 10:00am CST| before=scheduled for argument| after=argued}} before the [[Supreme Court of the United States]] on April 29, 2025.


{{TLDRbox
{{TLDRbox
| '''[[#Background|The issue]]:''' The case {{Greener| start=6/30/2025| before=concerns| after=concerned}} the Constitution's [[Supremacy Clause]] and the [https://casetext.com/statute/united-states-code/title-28-judiciary-and-judicial-procedure/part-iv-jurisdiction-and-venue/chapter-85-district-courts-jurisdiction/section-1346-united-states-as-defendant Federal {{Tort}} Claims Act] (FTCA).  [[#Background|Click here]] to learn more about the case's background.
| '''[[#Background|The issue]]:''' The case {{Greener| start=6/30/2025| before=concerns| after=concerned}} the Constitution's [[Supremacy Clause]] and the [https://casetext.com/statute/united-states-code/title-28-judiciary-and-judicial-procedure/part-iv-jurisdiction-and-venue/chapter-85-district-courts-jurisdiction/section-1346-united-states-as-defendant Federal {{Tort}} Claims Act] (FTCA).  [[#Background|Click here]] to learn more about the case's background.
| '''[[#Questions presented|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"<ref name=qp>[https://www.supremecourt.gov/docket/docketfiles/html/qp/24-00362qp.pdf ''Supreme Court of the United States,'' "24-362 MARTIN V. UNITED STATES (2025) QP", January 27, 2025]</ref>
| '''[[#Questions presented|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."<ref name=qp>[https://www.supremecourt.gov/docket/docketfiles/html/qp/24-00362qp.pdf ''Supreme Court of the United States,'' "24-362 MARTIN V. UNITED STATES (2025) QP", January 27, 2025]</ref>
| '''[[#Outcome|The outcome]]:''' The appeal is pending adjudication before the U.S. Supreme Court.
| '''[[#Outcome|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.<ref name=opinion>[https://www.supremecourt.gov/opinions/24pdf/24-362_mjn0.pdf ''Supreme Court of the United States,'' "24-362 MARTIN V. UNITED STATES", June 12, 2025]</ref> [[#Outcome|Click here]] for more information about the ruling.
}}
}}


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The following timeline details key events in this case:
The following timeline details key events in this case:


*'''June 12, 2025:''' The U.S. Supreme Court {{vacated}} and {{remanded}} the case to the [[United States Court of Appeals for the Eleventh Circuit]].
*'''April 29, 2025:''' The U.S. Supreme Court {{Greener| start=4/29/2025 10:00am CST| before=will hear| after=heard}} oral argument.
*'''April 29, 2025:''' The U.S. Supreme Court {{Greener| start=4/29/2025 10:00am CST| before=will hear| after=heard}} oral argument.
*'''January 27, 2025:''' The U.S. Supreme Court agreed to hear the case.
*'''January 27, 2025:''' The U.S. Supreme Court agreed to hear the case.
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<html><audio controls><source src="https://www.supremecourt.gov/media/audio/mp3files/24-362.mp3" type="audio/mpeg">Your browser doesn't support the audio tag.</audio></html><br>
<html><audio controls><source src="https://www.supremecourt.gov/media/audio/mp3files/24-362.mp3" type="audio/mpeg">Your browser doesn't support the audio tag.</audio></html><br>
<br>
<br>


===Transcript===
===Transcript===
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==Outcome==
==Outcome==
The case is pending adjudication before the U.S. Supreme Court.
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." <ref name=opinion/> Justice Gorsuch delivered the opinion of the court.
 
===Opinion===
In the court's majority opinion, Justice [[Neil Gorsuch]] wrote:<ref name=opinion/>
{{quote|
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.
|author=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:<ref name=opinion/>
{{quote|
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.  
|author=Justice [[Sonia Sotomayor]]}}
 
===Text of the opinion===
Read the full opinion [https://www.supremecourt.gov/opinions/24pdf/24-362_mjn0.pdf here].
 
<pdf width="500" height="500">File: 24-362_mjn0.pdf</pdf>


==October term 2024-2025==
==October term 2024-2025==
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{{#section:Supreme Court cases, October term 2024-2025|2024-2025intro}}
{{#section:Supreme Court cases, October term 2024-2025|2024-2025intro}}


==See also==
==See also==
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[[Category:United States Supreme Court]]
[[Category:United States Supreme Court]]
[[Category:SCOTUS OT 2024]]
[[Category:SCOTUS OT 2024]]
[[Category:Pending SCOTUS cases]]
[[Category:Decided SCOTUS cases]]
[[Category:SCOTUS unanimous opinions]]
[[Category:SCOTUS majority opinions, Neil Gorsuch]]

Latest revision as of 23:56, 16 June 2025


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 Gorsuch • Chief Justice John Roberts • Clarence Thomas • Samuel Alito • Elena Kagan • Brett Kavanaugh • Amy Coney Barrett
Concurring
Sonia Sotomayor • Ketanji 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

    1. ↑ 1.0 1.1 Supreme Court of the United States, "24-362 MARTIN V. UNITED STATES (2025) QP", January 27, 2025
    2. ↑ 2.0 2.1 2.2 2.3 Supreme Court of the United States, "24-362 MARTIN V. UNITED STATES", June 12, 2025
    3. ↑ Supreme Court of the United States, "No. 24-362 Martin v. United States (2025)" accessed February 3, 2025
    4. ↑ Oyez, "Martin v. United States (2025)", accessed February 3, 2025
    5. ↑ 5.0 5.1 5.2 5.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    6. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued April 29, 2025
    7. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued April 29, 2025
    8. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
    Retrieved from "https://ballotpedia.org/wiki/index.php?title=Martin_v._United_States_(2025)&oldid=10413891"