In NCLA Amicus Win, Supreme Court Revives Innocent Family’s Suit over FBI’s Wrong-House Raid

Curtrina Martin, et al. v. United States of America, et al.

/EIN News/ -- Washington, DC, June 13, 2025 (GLOBE NEWSWIRE) -- The U.S. Supreme Court unanimously reversed the Eleventh U.S. Circuit Court of Appeals’ dismissal of Martin v. United States, an Atlanta family’s Federal Tort Claims Act (FTCA) suit against the government for a wrong-house raid in 2017. FBI agents invaded the home of Trina Martin and her family, shackling her partner on the floor and holding a half-naked Ms. Martin at gunpoint, while she expressed concern for her seven-year-old son’s safety elsewhere in the house. One big problem: the FBI SWAT team had knocked down the door of the wrong home, on the wrong street, because the agent in charge had failed to verify its clearly marked address. The Justices remanded the case to the Eleventh Circuit for reconsideration. As NCLA’s amicus curiae brief urged, the Eleventh Circuit should ultimately rule on remand that the FTCA does not shield the government from liability when federal law enforcement officers raid the wrong house.

Ms. Martin and her family filed FTCA claims against the government for assault, battery, and false imprisonment, as well as Fourth Amendment claims against the individual FBI agents. The Eleventh Circuit below upheld the district court’s dismissal of the case, concluding that the agents’ actions violated no “clearly established” law. It ruled that the family suffered harm resulting from an agent’s “discretionary act” (i.e., failing to check the house address), warranting total governmental immunity and no path to relief for the Martin family. The Eleventh Circuit also determined that the Supremacy Clause of the Constitution could shield the FBI and its agents from FTCA suits. NCLA’s amicus brief forcefully argued that the Eleventh Circuit’s mode of inquiry—which departed from the analytical process employed by all sister circuits—was inconsistent with the language and intent of the FTCA. Congress amended the FTCA in 1974 expressly to ensure that innocent people subjected to wrong-house raids and similar abuses by federal law enforcement officers would have a cause of action to sue.

By expanding the FTCA’s discretionary-function exception to encompass wrong-house raids such as this one, the Eleventh Circuit’s decision effectively nullified the 1974 law. As Justice Sotomayor underscored in her concurrence (joined by Justice Jackson), “Courts … should not ignore the existence of the [1974 amendment], or the factual context that inspired its passage, when construing the discretionary-function exception. … [A]ny interpretation should allow for liability in the very cases Congress amended the FTCA to remedy.”

Today’s Supreme Court ruling does not decide whether the “discretionary function” exception applies in this case, an issue that the Court ordered the Eleventh Circuit to resolve, but the Justices found that the Supremacy Clause is not a defense the government may invoke in FTCA lawsuits. Justice Gorsuch explained in his opinion for the Court: “The FTCA is the ‘supreme’ federal law addressing the United States’ liability for torts committed by its agents. It supplies the ‘exclusive remedy’ for damages claims arising out of federal employees’ official conduct.” 

NCLA released the following statements:

“The Supreme Court rightly held that innocent civilians should not be stripped of any meaningful remedy when they suffer abuse at the hands of federal law enforcement. The Martin family deserves their day in court. On remand, NCLA trusts that the Eleventh Circuit will carefully evaluate what qualifies as ‘reasonable’ law enforcement—and recognize that a trained FBI agent who fails to check a clearly marked house number before commencing a raid because ‘it was dark outside’ does not qualify.”
— Casey Norman, Litigation Counsel, NCLA

“Law enforcement officers should not be able to evade accountability for entering the wrong house and terrorizing an innocent family in the middle of the night when Congress intentionally provided for redress in cases against the federal government in such circumstances. Thankfully, the Supreme Court’s decision reaffirms that the Eleventh Circuit was wrong to preclude relief in this case and others like it.”
— Jenin Younes, Litigation Counsel, NCLA

“All too often, court-created doctrines are used to reduce the government’s liability to people whose civil liberties it has violated. Congratulations to our friends at the Institute for Justice for convincing the Supreme Court to clip the wings of such a doctrine in this case—at least where Congress had explicitly created a cause of action to sue.”
— Mark Chenoweth, President, NCLA

For more information visit the amicus page here.

ABOUT NCLA

NCLA is a nonpartisan, nonprofit civil rights group founded by prominent legal scholar Philip Hamburger to protect constitutional freedoms from violations by the Administrative State. NCLA’s public-interest litigation and other pro bono advocacy strive to tame the unlawful power of state and federal agencies and to foster a new civil liberties movement that will help restore Americans’ fundamental rights.

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Joe Martyak
                    New Civil Liberties Alliance
                    703-403-1111
                    joe.martyak@ncla.legal