Facts of the Case

Provided by Oyez

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 U.S. 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.

Questions

  1. Does the Supremacy Clause prevent individuals from suing the federal government under the Federal Tort Claims Act when federal employees’ actions, even if negligent or wrongful, are related to carrying out federal policy and can be interpreted as following federal laws?

  2. Is the discretionary-function exception, which usually protects the government from being sued for certain decisions made by its employees, always inapplicable when dealing with claims related to law enforcement officers’ actions that fall under the intentional torts category?

Conclusions

  1. The Supremacy Clause does not afford the United States a defense in a suit against it under the Federal Tort Claims Act, 28 U.S.C. § 2671 et seq., and the law enforcement proviso in §2680(h) of the FTCA overrides only the intentional-tort exception in that subsection, not the discretionary-function exception or other exceptions throughout § 2680. Justice Neil Gorsuch authored the unanimous opinion of the Court.

    The proviso’s placement within subsection (h) demonstrates its limited scope. Section 2680 contains 13 discrete exceptions to the Federal Tort Claims Act's sovereign immunity waiver, each forming a separate sentence when combined with the lead-in clause. The law enforcement proviso appears within the same subsection and sentence as the intentional-tort exception, addressing the same subject matter—intentional torts—while other exceptions cover entirely different topics like lost mail, combat injuries, and quarantine impositions. The proviso’s definitional sentence expressly limits the definition of “investigative or law enforcement officer” to “this subsection,” even though the phrase “law enforcement officer” appears elsewhere in §2680. Congress’s choice to embed the proviso within subsection (h) rather than place it at the end of all exceptions confirms its application to subsection (h) alone.

    Furthermore, the Supremacy Clause does not afford the United States a defense in FTCA suits. The FTCA serves as the supreme federal law governing the United States’ tort liability and makes the government liable under state law on the same terms as a private individual. Because the FTCA incorporates state law as the liability standard, there is typically no conflict between federal and state law for the Supremacy Clause to resolve. While federal law may sometimes displace state law where constitutional text or federal statute supplies controlling liability rules, the Eleventh Circuit identified no such provision displacing Georgia tort law. The court’s reliance on In re Neagle was misplaced, as that 19th-century decision involved federal officer immunity from state criminal prosecution, not the federal government's liability under a statute that expressly subjects it to state tort law.

    Justice Sonia Sotomayor authored a concurring opinion, joined by Justice Ketanji Brown Jackson, emphasizing that the Eleventh Circuit’s test for the discretionary-function exception deviates from controlling precedent and highlighting that the exception may not shield careless conduct like that alleged in the mistaken raid at issue.