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Yahoo
13-06-2025
- Yahoo
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. 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 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. ### CONTACT: Joe Martyak New Civil Liberties Alliance 703-403-1111 in retrieving data Sign in to access your portfolio Error in retrieving data Error in retrieving data Error in retrieving data Error in retrieving data
Yahoo
12-06-2025
- Yahoo
The FBI Raided This Innocent Georgia Family's Home. The Supreme Court Just Revived Their Lawsuit.
It's been almost eight years since an FBI SWAT team arrived at Curtrina Martin and Toi Cliatt's home, detonated a flash grenade inside, ripped the door off, and stormed into the couple's bedroom with guns drawn. Agents handcuffed Cliatt at gunpoint, and Martin, who had tried to barricade herself inside of her closet, says she fell on a rack amid the mayhem. But law enforcement would not find who they were looking for there, because that suspect, Joseph Riley, lived in a nearby house on a different street. The issue is still a relevant one for Martin and Cliatt, along with Martin's son, Gabe—who was 7 years old at the time of the raid—as the group has fought for years, unsuccessfully, for the right to sue the government over the break-in. The Supreme Court on Thursday resurrected that lawsuit, unanimously ruling that the U.S. Court of Appeals for the 11th Circuit had settled on a faulty analysis when it barred Martin and Cliatt from suing in April 2024. But the plaintiffs' legal battle is still far from over. "If federal officers raid the wrong house, causing property damage and assaulting innocent occupants, may the homeowners sue the government for damages?" wrote Justice Neil Gorsuch. "The answer is not as obvious as it might be." The issue before the Court did not pertain to immunity for any individual law enforcement agent, whom the 11th Circuit shielded from liability in its decision last year. The justices instead considered if the lower court had erred when it also blocked the lawsuit from proceeding under the Federal Tort Claims Act (FTCA), the law that allows individuals to bring certain state-law tort claims against the federal government for damages caused by federal workers acting within the scope of their employment. There are many exceptions to the FTCA, however, that allow the feds to evade such claims—a microcosm of the convoluted maze plaintiffs must navigate to sue the government. One of those, the intentional tort exception, dooms suits that allege intentional wrongdoing, including assault, battery, false imprisonment, and false arrest, among several others. Yet the FTCA also contains a law enforcement proviso—essentially an exception to the exception—that permits claims to get around that carve-out when the misconduct in question is committed by "investigative or law enforcement officers." Notably here, Congress passed that addition in the 1970s in response to two highly publicized wrong-house raids. The 11th Circuit accordingly observed that the proviso would allow Martin and Cliatt's intentional tort claims to survive the exception. The court killed those claims anyway. It cited the Supremacy Clause, which the judges said protected the government from liability if its employees' actions had "some nexus with furthering federal policy and [could] reasonably be characterized as complying with the full range of federal law." Not so, said the Supreme Court. Somewhat surprisingly, that put it in agreement with the government—which, prior to oral arguments, conceded the 11th Circuit's conclusion there was incorrect, and that it did not care to defend it. "We find the government's concession commendable and correct," writes Gorsuch. "The FTCA does not permit the Eleventh Circuit's Supremacy Clause defense." Arguably the bigger question before the Court pertained to a different FTCA carve-out: the discretionary function exception, which, true to its name, precludes claims from proceeding if the alleged misconduct came from a duty that involves discretion. The 11th Circuit dismissed Martin and Cliatt's claims alleging negligent wrongdoing—distinctive under the law from intentional torts—writing that "the FBI did not have stringent policies or procedures in place that dictate how agents are to prepare for warrant executions." Lawrence Guerra, a former FBI special agent and the leader of the raid, thus had discretion, the judges said. But the 11th Circuit took its discretionary analysis a step further, ruling that, for acts of wrongdoing that have intentionality, the law enforcement proviso trumps the discretionary exception outright. The justices rejected that. "The law enforcement proviso…overrides only the intentional-tort exception in that subsection," the Court said, "not the discretionary-function exception or other exceptions." So where does that leave Martin and Cliatt? "On remand, the 11th Circuit will need to decide whether raiding the wrong house is a 'discretionary function,'" says Patrick Jaicomo, an attorney at the Institute for Justice, who represented the pair. Jaicomo was hoping the Court would address that very confusion. The plaintiffs "call on us to determine whether and under what circumstances the discretionary-function exception bars suits for wrong-house raids and similar misconduct," writes Gorsuch. "Unless we take up that further question, they worry, the Eleventh Circuit on remand may take too broad a view of the exception and dismiss their claims again. After all, the plaintiffs observe, in the past that court has suggested that the discretionary-function exception bars any claim 'unless a source of federal law "specifically prescribes" a course of conduct' and thus deprives an official of all discretion." The Supreme Court, however, ultimately opted for a narrow approach, though the justices acknowledged "that important questions surround whether and under what circumstances that exception may ever foreclose a suit like this one." In a concurring opinion, Justice Sonia Sotomayor, joined by Justice Ketanji Brown Jackson, said there are no such circumstances when considering the fact pattern presented in Martin and Cliatt's suit. "Like driving, executing a warrant always involves some measure of discretion," she wrote. "Yet it is hard to see how Guerra's conduct in this case, including his allegedly negligent choice to use his personal GPS and his failure to check the street sign or house number on the mailbox before breaking down Martin's door and terrorizing the home's occupants, involved the kind of policy judgments that the discretionary-function exception was designed to protect." That would seem like the right conclusion, particularly when considering the genesis of that law enforcement proviso, which Congress enacted to give recourse to victims who suffered at the hands of near-identical misconduct. Those lawmakers clearly did not think the discretionary exception would doom their claims. That the law was meant to protect people like Martin, Cliatt, and Martin's son is why a bipartisan group of lawmakers—including Sens. Rand Paul (R–Ky.), Ron Wyden (D–Ore.), and Cynthia Lummis (R–Wyo.), along with Reps. Thomas Massie (R–Ky.), Nikema Williams (D–Ga.), and Harriet Hageman (R–Wyo.)—had urged the Court to take up their case. Sotomayor's description of Guerra's negligence is also salient and was the subject of one of the more interesting exchanges when the Supreme Court heard the case. Arguing for the Justice Department, Frederick Liu, assistant to the solicitor general, said it was too much for Martin and Cliatt to expect "that the officer should have checked the house number on the mailbox." "Yeah, you might look at the address of the house before you knock down the door," Gorsuch responded. Liu countered that such a decision "is filled with policy tradeoffs." "Really?" Gorsuch replied. The post The FBI Raided This Innocent Georgia Family's Home. The Supreme Court Just Revived Their Lawsuit. appeared first on
Yahoo
12-06-2025
- Politics
- Yahoo
Supreme Court revives FBI 'wrong house' raid lawsuit
WASHINGTON — The Supreme Court on Thursday revived a lawsuit against the FBI in a damages claim arising from an incident in which agents raided the wrong house in Atlanta. The ruling marks a narrow win for Toi Cliatt, his former girlfriend Trina Martina and her son Gabe Watson, who were all present in the house during the October 2017 encounter. The unanimous decision written by Justice Neil Gorsuch means they can continue to press claims alleging assault, battery and false imprisonment under a law called the Federal Tort Claims Act (FTCA), one of the few avenues to hold federal officials accountable. Litigation will now continue in the Atlanta-based 11th U.S. Circuit Court of Appeals. "We look forward to continuing this fight with the Martins in the Eleventh Circuit and making it easier for everyday people to hold the government accountable for its mistaken and intentional violations of individual rights," Patrick Jaicomo, a lawyer at the libertarian Institute for Justice who represents the plaintiffs, said in a statement. The case highlights the problem of law enforcement raiding the wrong house, which has happened in several high-profile cases. A district court judge and the appeals court ruled for the government. The legal question touched upon on whether a particular provision of the law, which allows claims concerning the actions of federal law enforcement officers, is trumped in this instance by another provision called 'the discretionary function exception,' which protects certain judgment calls from liability. The court did not resolve that question, but did remove a barrier to the plaintiffs being able to argue it in lower courts. "We readily acknowledge that different lower courts have taken different views of the discretionary function exception," Gorsuch wrote. "We acknowledge, too, that important questions surround whether and under what circumstances that exception may ever foreclose a suit like this one." In a separate concurring opinion, Justice Sonia Sotomayor wrote that "there is a reason to think" that the discretionary function exception should not bar the plaintiffs' claims. Her opinion was joined by Justice Ketanji Brown Jackson. During the raid in question the agents had guns drawn and used flash-bang grenades as they entered the house. Cliatt was handcuffed and thrown on the floor. Martin wanted to rush to her son but wasn't allowed to move. Watson, then 7, woke up to see agents with guns in his bedroom. The agents quickly left the house upon realizing their error and a supervisor returned later to apologize. The Justice Department in court papers said that a Garmin GPS device that FBI agent Lawrence Guerra used to lead the team to the house had indicated the agents had arrived at the correct location. The FBI was seeking to arrest a man named Joseph Riley, who lived nearby. After they left the wrong house, the agents raided the correct home. Riley was arrested and later convicted. This article was originally published on
Yahoo
12-06-2025
- Politics
- Yahoo
Supreme Court revives lawsuit over mistaken FBI raid
The Supreme Court on Thursday revived an Atlanta family's lawsuit over a botched FBI raid on its home in 2017 but put off deciding the case's ultimate fate. In a unanimous decision, the justices instead sent the case back to a lower court to take another crack at deciding whether the lawsuit can move forward. Federal agents smashed through Trina Martin's front door in 2017 while executing a search warrant at the wrong address, believing it was the home of an alleged violent gang member. Martin and her boyfriend at the time were startled out of bed with a flash-bang grenade and guns raised, as her 7-year-old son screamed from another room. She sued the government in 2019, accusing the agents of assault and battery, false arrest and other violations, under the Federal Tort Claims Act (FTCA), which waives the government's sovereign immunity and lets people injured by certain actions of federal officers bring some claims for damages against it under state law. But a federal judge in Atlanta dismissed the suit, and the 11th U.S. Circuit Court of Appeals upheld that decision. The justices now say the lower courts erred, ordering the appeals court to reexamine the case. The justices clarified two principles and said the 11th Circuit Court should consider on remand whether the FTCA's discretionary-function exception bars two of Martin's claims. 'It is work enough for the day to answer the questions we took this case to resolve, clear away the two faulty assumptions on which that court has relied in the past and redirect it to the proper inquiry,' Justice Neil Gorsuch wrote in the court's opinion. Patrick Jaicomo, Martin's lawyer, argued before the justices that 'innocent victims' of the government's mistakes must have an available legal remedy. The FTCA was amended in 1974 after a pair of wrong-house raids made headlines, which he suggested makes clear that Martin's lawsuit should be allowed to proceed. Exceptions to the law make it more complicated. Frederick Liu, who argued for the government, said an exception to the FTCA preventing plaintiffs from suing the government for damages that arise out of an officer's discretionary acts applies to the case. He also suggested entering the wrong home was a 'reasonable mistake' and an example of the 'policy trade-offs' officers make when placed in risky situations. In the court's opinion, Gorsuch acknowledged lower courts have taken different views on the discretionary-function exception and that 'important questions' must be weighed regarding under which circumstances they apply. 'But those questions lie well beyond the two we granted certiorari to address,' Gorsuch wrote. 'And before addressing them, we would benefit from the Eleventh Circuit's careful reexamination of this case in the first instance. Justice Sonia Sotomayor wrote a concurring opinion, joined by Justice Ketanji Brown Jackson, meant to 'underscore' that the exception regarding officer discretion may not apply here. She pointed to the historical context in which the exception was passed to suggest that the exception does not apply 'reflexively.' 'Whatever else is true of that exception, any interpretation should allow for liability in the very cases Congress amended the FTCA to remedy,' Sotomayor wrote. In a statement following the decision, Jaicomo said the court was right to revive the Martin family's case. 'The Court's decision today acknowledged how far the circuit courts have strayed from the purpose of the Federal Tort Claims Act, which is to ensure remedies to the victims of federal harms—intentional and negligent alike,' he said. 'We look forward to continuing this fight with the Martins in the Eleventh Circuit and making it easier for everyday people to hold the government accountable for its mistaken and intentional violations of individual rights.' Updated at 11:32 a.m. EDT Copyright 2025 Nexstar Media, Inc. All rights reserved. This material may not be published, broadcast, rewritten, or redistributed.
The Hill
12-06-2025
- Politics
- The Hill
Supreme Court revives lawsuit over mistaken FBI raid
The Supreme Court on Thursday revived an Atlanta family's lawsuit over a botched FBI raid on their home in 2017 but put off deciding its ultimate fate. In a unanimous decision, the justices instead sent the case back to a lower court to take another crack at deciding whether the lawsuit can move forward. Federal agents smashed through Trina Martin's front door in 2017 while executing a search warrant at the wrong address, believing it was the home of an alleged violent gang member. Martin and her boyfriend at the time were startled out of bed with a flash-bang grenade and guns raised, as her 7-year-old son screamed from another room. She sued the government in 2019, accusing the agents of assault and battery, false arrest and other violations, under the Federal Tort Claims Act (FTCA), which waives the government's sovereign immunity and lets people injured by certain actions of federal officers bring some claims for damages against it under state law. But a federal judge in Atlanta dismissed the suit and the 11th U.S. Circuit Court of Appeals upheld that decision. The justices now say the lower courts erred. 'Where does all that leave the case before us?' Justice Neil Gorsuch asked in the court's opinion. 'We can say this much: The plaintiffs' intentional-tort claims survive their encounter with subsection (h) thanks to the law enforcement proviso, as the Eleventh Circuit recognized. But it remains for that court on remand to consider whether subsection (a)'s discretionary-function exception bars either the plaintiffs' negligent or intentional-tort claims,' he wrote. Patrick Jaicomo, Martin's lawyer, argued before the justices that 'innocent victims' of the government's mistakes must have an available legal remedy. The FTCA was amended in 1974 after a pair of wrong-house raids made headlines, which he suggested makes clear that Martin's lawsuit should be allowed to proceed. Exceptions to the law make it more complicated. Frederick Liu, who argued for the government, said that an exception to the FTCA preventing plaintiffs from suing the government for damages that arise out of an officer's discretionary acts applies to the case. He also suggested that entering the wrong home was a 'reasonable mistake' and an example of the 'policy trade-offs' officers make when placed in risky situations. In the court's opinion, Gorsuch acknowledged that lower courts have taken different views on the discretionary-function exception and that 'important questions' must be weighed regarding under which circumstances they apply. 'But those questions lie well beyond the two we granted certiorari to address,' Gorsuch wrote. 'And before addressing them, we would benefit from the Eleventh Circuit's careful reexamination of this case in the first instance. 'It is work enough for the day to answer the questions we took this case to resolve, clear away the two faulty assumptions on which that court has relied in the past and redirect it to the proper inquiry,' he said. DEVELOPING
