Martin v. United States decision ends decades of legal protection for federal agents in wrong-house raid cases
After decades of legal confusion that has shielded federal agents from consequences, the Supreme Court unanimously ruled this week that victims of wrong-house raids can more easily hold the government accountable for the trauma and damage inflicted by botched law enforcement operations.
The Case That Changed Everything
The decision stems from a horrifying 2017 incident that reads like a nightmare scenario for any American family. In the predawn hours of October 18, 2017, a six-member FBI SWAT team smashed down the door of 3756 Denville Trace in suburban Atlanta, detonated a flash-bang grenade, and terrorized the innocent occupants—Hilliard Toi Cliatt, his partner Curtrina Martin, and her 7-year-old son.
The agents were supposed to be at 3741 Landau Lane, a suspected gang hideout. Instead, they assaulted a quiet family in their own home.
The cause? FBI Special Agent Lawrence Guerra relied on his personal GPS device and failed to notice the street sign or house number on the mailbox. When the family hid in a bedroom closet, fearing a home invasion, agents dragged Cliatt out, threw him to the floor, handcuffed him, and trained weapons on Martin as she lay half-naked on the closet floor. Only when another officer found mail with the home’s address did they realize their catastrophic mistake.
Guerra later threw away his GPS device, making it impossible to verify his claims about the navigation error.
The Legal Maze That Protected Federal Agents
For years, victims of such raids faced a bewildering legal obstacle course when trying to sue the federal government. The Federal Tort Claims Act (FTCA) theoretically allows lawsuits against the government for employee misconduct, but it contains numerous exceptions that courts have interpreted differently across the country.
The Eleventh Circuit Court of Appeals had developed a particularly problematic approach that seemed to give victims hope, only to snatch it away. While that court allowed certain intentional tort claims (like assault and battery) to proceed initially, it then permitted the government to invoke a broad “Supremacy Clause defense” that essentially said federal agents couldn’t be held liable if their actions had “some nexus with furthering federal policy.”
This Catch-22 meant that even when federal agents clearly committed assault, battery, or other intentional torts during botched raids, the government could escape liability simply by arguing the agents were trying to enforce federal law—no matter how negligently or recklessly they did so.
A Unanimous Rejection of Government Immunity
The Supreme Court’s June 12, 2025 decision in Martin v. United States demolishes these barriers with remarkable clarity. Justice Neil Gorsuch, writing for a unanimous Court, rejected the government’s attempts to shield federal agents from accountability on two crucial fronts.
First, the Court clarified that the FTCA’s “law enforcement proviso”—which allows suits against federal agents for assault, battery, false imprisonment, false arrest, abuse of process, and malicious prosecution—applies only to intentional tort claims, not to every type of government misconduct claim. This technical ruling actually helps victims by providing clearer guidance on which claims can proceed.
More importantly, the Court emphatically rejected the Eleventh Circuit’s “Supremacy Clause defense.” The justices made clear that when Congress passed the FTCA, it intended for the federal government to be held liable under state law “on the same terms as a private individual would be liable.” There is no special federal immunity shield that agents can hide behind simply because they were attempting to enforce federal law.
As Justice Gorsuch wrote, the FTCA “incorporates state law as the liability standard,” meaning “there is typically no conflict between federal and state law for the Supremacy Clause to resolve.”
Why This Matters in 2025
It’s sobering that we needed a Supreme Court decision in 2025 to clarify that federal agents can be held accountable for terrorizing innocent families in their homes. Wrong-house raids have plagued American law enforcement for decades, with countless families suffering trauma, property damage, and physical harm due to police negligence and recklessness.
The fact that it took until now to get this basic clarification reveals how extensively our legal system has been rigged to protect government agents from the consequences of their actions, even when those actions devastate innocent lives.
The Court’s decision references the 1973 Collinsville raids, where federal agents terrorized two innocent families based on a “bad tip,” tying them up at gunpoint and threatening to shoot them. Congress amended the FTCA in response to that incident, intending to ensure victims of such raids could seek justice. Yet here we are, over 50 years later, finally getting clarity on what Congress meant.
FTCA vs. Section 1983: Different Tools for Different Fights
It’s important to understand that this ruling specifically addresses Federal Tort Claims Act (FTCA) lawsuits, which allow victims to sue the federal government itself for money damages when federal agents commit misconduct. This is different from Section 1983 lawsuits, which are typically used against local and state police officers personally for constitutional violations.
While Section 1983 allows victims to sue individual officers directly, it has been severely weakened by qualified immunity doctrine that protects officers unless they violate “clearly established” law. The FTCA, by contrast, targets the federal government rather than individual agents, but has its own maze of exceptions and immunity defenses.
The Martin decision strengthens the FTCA pathway by eliminating key government defenses, potentially making it easier for victims of federal misconduct to obtain compensation than victims of local police misconduct who face the qualified immunity wall in Section 1983 cases.
The Path Forward
The Supreme Court sent the Martin case back to the Eleventh Circuit for reconsideration under the correct legal standards. The family will now have a real opportunity to hold the FBI accountable for the trauma inflicted on them and their 7-year-old child.
More broadly, this decision provides a clearer roadmap for other victims of wrong-house raids and police misconduct. While legal challenges remain—particularly around the “discretionary function exception” that can still protect some government decisions—the Supreme Court has eliminated two major barriers that have historically shielded federal agents from accountability.
Justice Sonia Sotomayor’s concurring opinion hints that even more clarity may be coming, noting that “it is long past time for this Court to weigh in on the [discretionary function] exception’s scope.”
For families like the Martins, and for everyone who believes that badge and gun don’t place someone above the law, this unanimous decision represents a long-overdue step toward real accountability for federal law enforcement misconduct.
YouTube video from the Institute for Justice prior to the decision from the Supreme Court.