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 addressed the application of the Federal Tort Claims Act (FTCA) in a case involving a mistaken FBI raid. The Court vacated the Eleventh Circuit's decision, which had applied a unique approach to FTCA claims, and remanded the case for reconsideration of the discretionary-function exception and the applicability of state law. The Court clarified that the law enforcement proviso in § 2680(h) overrides only the intentional-tort exception, not other exceptions like the discretionary-function exception.
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 and not the discretionary-function exception. The Eleventh Circuit's Supremacy Clause defense was also rejected.
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 Preemption is relevant to Martin v. United States
The case involves the application of federal law over state law in the context of the Federal Tort Claims Act, which is a form of preemption.
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 State–Federal Power is relevant to Martin v. United States
The case discusses the allocation of authority between state and federal governments, particularly in the context of federal officers' actions and liability under state tort law.
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 implicates Fourth Amendment concerns regarding unreasonable searches and seizures.
Syllabus excerpt (verbatim)Officers meant to execute search and arrest warrants at a suspected gang hideout... but instead stormed... a quiet family home occupied by petitioners.
Key Quotes
Short excerpts from the syllabus in Martin v. United States that support the summary and concepts above.
The FTCA waives the federal government's sovereign immunity from suit as to certain torts committed by federal employees acting within the scope of their employment.
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 Supremacy Clause does not afford the United States a defense in FTCA suits.
