Docket 24-362
Martin v. United States
DecidedJun 12, 2025
9-0unanimous decision
Source: CourtListener.
Court rules FBI wrong-house raid victims can sue under federal tort law, rejects two Eleventh Circuit defenses
What it does
The Court unanimously held that the law enforcement proviso in the Federal Tort Claims Act overrides only the intentional-tort exception in the subsection where it appears, not the discretionary-function exception or any other exception in the statute. The Court also unanimously rejected the Eleventh Circuit's rule allowing the federal government to escape liability by showing its officers' actions had "some nexus with furthering federal policy" under the Supremacy Clause. The case was sent back to the Eleventh Circuit to apply the correct legal framework, including a fresh look at whether the discretionary-function exception bars any of the plaintiffs' claims.
Who benefits
People who are injured during wrong-house raids or other law enforcement misconduct by federal officers and who seek damages from the federal government under the Federal Tort Claims Act. Specifically, the Martin and Cliatt family, whose home was wrongly raided by an FBI SWAT team, now have their claims sent back for reconsideration under the correct legal standard.
Who is affected
The federal government and federal law enforcement agencies, which can no longer use the Eleventh Circuit's broad Supremacy Clause defense to automatically defeat tort claims, and which must now have the discretionary-function exception analyzed separately for both negligence and intentional-tort claims in that circuit.
Practical impact
In the Eleventh Circuit (covering Florida, Georgia, and Alabama), federal courts must now analyze the discretionary-function exception separately for both negligence and intentional-tort claims brought against the government — intentional-tort claims covered by the law enforcement proviso no longer automatically bypass that exception. Across all federal circuits, the government may no longer assert a Supremacy Clause defense to escape liability in Federal Tort Claims Act suits; instead, liability is determined by whether a private individual would be liable under the state law where the conduct occurred. The Martin and Cliatt family's case returns to the Eleventh Circuit, which must now decide whether the discretionary-function exception bars their claims without relying on either of the two legal shortcuts the Supreme Court rejected.
Majority reasoning
The Court reasoned that the law enforcement proviso is embedded within subsection (h) of the statute — the same sentence as the intentional-tort exception — and that statutory provisos generally modify only the provision in which they appear, not an entire list of separate exceptions. The Court pointed to multiple textual clues confirming this narrow reading: each exception in §2680 forms a structurally separate sentence; the proviso addresses only intentional torts, while other exceptions cover unrelated topics like lost mail or combat injuries; and the proviso's own definitional sentence expressly limits its definition of "investigative or law enforcement officer" to "this subsection." On the Supremacy Clause defense, the Court held that the Federal Tort Claims Act is itself the supreme federal law governing the government's tort liability, and because it directs courts to apply state tort law on the same terms as a private individual, there is typically no conflict between federal and state law for the Supremacy Clause to resolve. The Court rejected the Eleventh Circuit's reliance on the 19th-century case In re Neagle — which shielded a federal marshal from state criminal prosecution — because that decision involved a federal officer's immunity from criminal charges, not a situation where Congress has expressly subjected the government to state tort liability on the same terms as a private party.
Constitutional question
Does the Federal Tort Claims Act's "law enforcement proviso" override all exceptions to the government's immunity from suit — including the discretionary-function exception — and may the United States defeat such a suit by invoking the Supremacy Clause to show its officers were furthering federal policy?
Precedent changed
The Court did not explicitly overrule any prior Supreme Court precedent, but it rejected and corrected the Eleventh Circuit's distinctive two-part framework established in Denson v. United States, 574 F.3d 1318 (2009), and narrowed the Eleventh Circuit's application of In re Neagle, 135 U.S. 1 (1890), holding that Neagle does not supply a defense for the federal government in FTCA tort suits.