From the United States Supreme Court

Martin, Individually and as Parent and Next Friend of G.W., a Minor, ET AL., v. United States ET AL. 2025 U.S. LEXIS 2281 (6/12/2025)

Procedurally, this Case has NO impact on Local Law Enforcement and only applies to Federal Law Enforcement.  

The facts suggest that hitting the wrong house with a warrant as well as force used during the execution in such a circumstance may be actionable by a plaintiff as many lower courts have concluded.

 The United States Supreme Court outlined the facts of the law enforcement event as follows:

In the predawn hours of October 18, 2017, the Federal Bureau of Investigation raided the wrong house in suburban Atlanta. Officers meant to execute search and arrest warrants at a suspected gang hideout, 3741 Landau Lane. Instead, they stormed a quiet family home, 3756 Denville Trace, occupied by Hilliard Toi Cliatt, his partner Curtrina Martin, and her 7-year-old son G. W. App. to Pet. for Cert.  3a–4a.

A six-member SWAT team, led by FBI Special Agent Lawrence Guerra, breached the front door and detonated a flash-bang grenade. Id., at 7a–8a. Fearing a home invasion, Mr. Cliatt and Ms. Martin hid in a bedroom closet. Id., at 8a. But the SWAT team soon found the couple’s hiding spot, dragged Mr. Cliatt from the closet, “threw [him] down on the floor,” handcuffed him, and began “bombarding [him] with questions.” Id., at 79a. Meanwhile, another officer trained his weapon on Ms. Martin, who was lying on the floor half-naked, having fallen inside the closet. Id., at 8a, 89a. Only then did another officer stumble across some mail with the home’s address on it and realize the team had the wrong house. Id., at 8a.

The cause of the officers’ mistake? In preparation for the raid, Agent Guerra visited the correct house to document its features and identify a staging area for the SWAT team. Id., at 5a. But, he says, when he used his personal GPS to navigate to 3741 Landau Lane on the day of the raid, it led him to 3756 Denville Trace. 631 F. Supp. 3d 1281, 1287 (ND Ga. 2022). No one could confirm as much later because Agent Guerra “threw . . . away” his GPS device “not long after” the raid. Id., at 1288. And it seems the agents neither noticed the street sign for “Denville Trace,” nor the house number, which was visible on the mailbox at the end of the driveway. Ibid.; Tr. of Oral Arg. 38. Apparently, too, Agent Guerra failed to appreciate that a different car was parked in the driveway, one “not present . . . during [his] previous visit.” 631 F. Supp. 3d, at 1288.

Left with personal injuries and property damage—but few explanations and no compensation—Mr. Cliatt and Ms. Martin sued the United States. They did so under the Federal Tort Claims Act, 28 U. S. C. §2671 et seq., alleging that the officers had committed various negligent and intentional torts, App. 8–14.

The decision focuses on how the United States Court of Appeals for the 11th Circuit analyzed the Federal Tort Claims act, specifically whether the Supremacy Clause and the discretionary function exception protected the United States from the civil claims.  The Supremacy Clause has protected federal officers from criminal charges in cases where their actions were consistent with federal law and they were acting under the authority of the federal government yet state authorities brought criminal charges against the federal officers.

The Court also noted that the plaintiff’s intentional tort claims could be brought because of a provision in the law that an officer is not protected from certain intentional torts that include assault and battery.

The Court noted that on remand, the lower courts had to determine whether the discretionary function exception to liability under the Federal Tort Claims Act would bar the plaintiffs’ negligent or intentional-tort claims.  The Court noted, “Should some or all of the plaintiffs’ claims survive the discretionary-function exception, the Eleventh Circuit must then ask whether, under Georgia state law, a “private individual under like circumstances” would be liable for the acts and omissions the plaintiffs allege, subject to the defenses discussed in §2674—not a Supremacy Clause defense nowhere mentioned there.”

The Court declined to go further as to whether or not the discretionary function could apply to the facts of this case.  The Court responded:

Having resolved that much, the plaintiffs ask us to decide more still. See Brief for Petitioners 19–40. In particular, they call on us to determine whether and under what circumstances the discretionary-function exception bars suits for wrong-house raids and similar misconduct. 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. Id., at 36 (quoting Shivers v. United States, 1 F. 4th 924, 931 (CA11 2021)). And that approach, the plaintiffs insist, is both seriously mistaken and at odds with how other circuits understand the exception. Brief for Petitioners 36. Some courts, for instance, have held that the discretionary-function exception does not protect conduct “marked by individual carelessness or laziness,” rather than “policy considerations.” Rich v. United States, 811 F. 3d 140, 147 (CA4 2015). Some courts do not apply the exception when law enforcement officers violate the plaintiffs’ constitutional rights. Xi, 68 F. 4th, at 839 (“government officials never have discretion to violate the Constitution”). And some have indicated that the exception does not protect “ministerial” tasks. See id., at 843 (Bibas, J., concurring). The plaintiffs ask us to endorse decisions like these, apply their reasoning to this case, and hold it survives the discretionary- function exception. Brief for Petitioners 39–40

We readily acknowledge that different lower courts have taken different views of the discretionary-function exception. We acknowledge, too, that important questions surround whether and under what circumstances that exception may ever foreclose a suit like this one. But those questions lie well beyond the two we granted certiorari to address. 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.

The judgment of the Eleventh Circuit is vacated, and the case is remanded for further proceedings consistent with this opinion.

Bottom Line:

This case only applies to the proper analysis a court must undertake when a claim is filed by a citizen against federal law enforcement personnel under the Federal Tort Claims Act and has no bearing on claims filed against local law enforcement, which are generally brought under 42 U.S.C. § 1983.

That said, a number of Circuits have addressed wrong house warrant executions and the use of force as well as continued searching and allowed such cases to go forward against individual officers as civil rights claims under 42 U.S.C. § 1983.