Martin v. United States
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Martin v. United States and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Martin v. United States.
In Martin v. United States, the Supreme Court reviewed a case where the FBI mistakenly raided the wrong house, leading to a lawsuit under the Federal Tort Claims Act (FTCA). The Eleventh Circuit had allowed intentional-tort claims to proceed under a unique interpretation of the FTCA's law enforcement proviso, which the Supreme Court found incorrect. The Court clarified that the proviso only overrides the intentional-tort exception, not the discretionary-function exception. The case was vacated and remanded for further consideration without the Supremacy Clause defense.
Holding
The single most important “bottom line” of what the Court decided in Martin v. United States.
The Court held that the law enforcement proviso in § 2680(h) only overrides the intentional-tort exception, not the discretionary-function exception, and the Supremacy Clause does not provide a defense in FTCA suits.
Constitutional Concepts
These are the Constitution-related themes that appear in Martin v. United States. Click a concept to see other cases that involve the same idea.
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Why Due Process is relevant to Martin v. United States
The case involves the government's liability under the FTCA, which implicates procedural due process in terms of how claims against the government are handled.
Syllabus excerpt (verbatim)The FTCA is the 'supreme' federal law governing the United States' tort liability and serves as the exclusive remedy for damages claims arising from federal employees' official conduct.
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Why Federalism is relevant to Martin v. United States
The case discusses the interaction between federal and state law, particularly how the FTCA incorporates state law as the liability standard.
Syllabus excerpt (verbatim)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.
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Why Search and Seizure is relevant to Martin v. United States
The case involves a mistaken raid by federal officers, which directly relates to the Fourth Amendment's protection against unreasonable searches and seizures.
Syllabus excerpt (verbatim)On October 18, 2017, the FBI raided the wrong house in suburban Atlanta.
Key Quotes
Short excerpts from the syllabus in Martin v. United States that support the summary and concepts above.
The law enforcement proviso in § 2680(h) overrides only the intentional-tort exception in that subsection, not the discretionary-function exception or other exceptions throughout § 2680.
The FTCA is the 'supreme' federal law governing the United States' tort liability and serves as the exclusive remedy for damages claims arising from federal employees' official conduct.
On remand, the Eleventh Circuit should consider whether subsection (a)'s discretionary-function exception bars either the plaintiffs' negligent- or intentional-tort claims.