At issue is the legal notion of “Sovereign Immunity,” a doctrine that prevents individuals from pursuing lawsuits against the local, state, and federal governments concerning law enforcement actions.
As reported by NPR, in October 2017, federal agents forcibly entered the home of Trina Martin, where she, her 7-year-old son Gabe, and her partner Toi Cliatt were sleeping. The household was awoken by the sudden explosion of a grenade blowing their front door in.
Federal agents, flanked by SWAT, then stormed in to serve a lawful arrest warrant… on the wrong house. According to the outlet, as agents charged upstairs, they handcuffed Cliatt and left Martin in her bedroom. Gabe, cut off from his mother, hid under his bed. "It's just so, so loud … I'm crying … I'm calling for my mom … I was on my own, and I had no clue what to do," the boy told reporters.
The three were held at gunpoint and separated for a time until agents realized their error. The officers then released the family and left to execute the warrant, with an officer returning later to apologize.
In 2019, Martin sued the federal government on allegations that the agents committed assault and battery, false arrest, and other violations, according to WCNC. The case was dismissed by a U.S. District Judge in Atlanta in 2022, and the dismissal was upheld by the 11th Circuit Court of Appeals in 2024. But in January, SCOTUS agreed to hear the case Martin v. United States.
SCOTUS Blog reports that the issue at the case’s heart is,
“Whether the Constitution’s supremacy clause bars claims under the Federal Tort Claims Act 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; and 2) whether the discretionary-function exception is categorically inapplicable to claims arising under the law enforcement proviso to the intentional torts exception.”
The outlet reported that FBI Atlanta spokesperson Tony Thomas responded to emails that the bureau cannot comment on pending litigation, but attorneys representing the government argued that the judicial branch should not engage in “second-guessing” the decisions of law enforcement agencies. The 11th Circuit Court found that the FBI did carry out due diligence to find the correct address, making the incident distinct from a “no-knock warrant,” and agreed with the government’s argument, saying the courts can’t second-guess “honest mistakes” from law enforcement.
Martin's lawyers wrote in a brief to the Supreme Court, “If the Federal Tort Claims Act provides a cause of action for anything, it’s a wrong-house raid like the one the FBI conducted here,” per WCNC.
In the 11th Circuit Court’s ruling, as noted by Reason, the Judges wrote that the FBI has “discretion” on how it prepares for warrant execution. The court also cited the Supremacy Clause, finding that because the agents held “some nexus with furthering federal policy" and could "reasonably be characterized as complying with the full range of federal law." Therefore, relief under the Federal Tort Claims Act couldn’t go forward.
