By LawInspectsFBI mistaken house raid lawsuit concerns a mistaken house raid conducted by a FBI SWAT team against a family living in Atlanta, Georgia, in search of a gangster. Even though the FBI team realised its mistake quickly and left, they had already handled the family members harshly and caused damage to their house. Consequently, the Atlanta family filed a lawsuit against FBI but the same was rejected by the court, citing immunity for the federal employees.
The victim family of the FBI raid had filed a lawsuit under the Federal Tort Claims Act, claiming damages for the trauma they experienced. But an appeals court refused to entertain the lawsuit citing certain exceptions to the FTCA. The matter is now before the US Supreme Court where the decision to block the lawsuit is under review.
Events leading to the Lawsuit
In the pre-dawn hours of an October morning in 2017, an FBI SWAT team dressed in full tactical gear raided the Atlanta home of Hilliard Cliatt and Curtrina Martin where they lived along with Martin’s 7 year old son. The agents were executing a no-knock warrant against a violent gang member, Joseph Riley. However, they mistook Cilatt and Martin’s home for Riley’s residence, the latter being on a different street.
The FBI agents broke down the door and detonated a flash bang grenade at the entrance. Thereafter, they proceeded to handcuff Hilliard Cliatt and pointed guns at Curtrina Martin. The couple took the raid for a burglary attempt and hid in a closet but the agents dragged Hilliard out of the closet and handcuffed him. Martin’s 7 year old son was at home during the raid.
Within five minutes, the agents realised their mistake and left. They eventually arrested Joseph Riley. Later in the day, FBI special agent Lawrence Guerra, who led the raid, returned to apologize and promised compensation for the property damages caused by the mistaken raid. He also left a business card.
Key facts about the Lawsuit
Cliatt and Martin filed a lawsuit against FBI in a federal district court in Georgia. The family asserted that even though insurance covered the property damage, they underwent extreme emotional trauma. The lawsuit was filed under the Federal Tort Claims Act. This particular law allows private citizens to sue federal employees for damages when they commit wrongful acts.
FTCA was enacted by the US Congress in the year 1946 to waive sovereign immunity for federal employees and make them liable for wrongful acts. In the year 1976, the ambit of FTCA was expanded to specifically include wrong house raids.
A federal district court in Georgia dismissed the lawsuit filed by Cliatt and Martin. The family appealed against the decision of the district court. The US Court of Appeals for the 11th Circuit upheld the decision of the district court dismissing the claims made by the family. In its judgment, the court said the actions of the FBI agents involved an element of judgment, thereby falling under the “discretionary-function” exception to the FTCA. Furthermore, the court also relied upon the supremacy clause of the US constitution to block the suit.
Supreme Court Review
Cliatt and Martin appealed against the decision of the 11th Circuit Court of Appeals in the US Supreme Court. The family is represented by the Institute for Justice, a nonprofit libertarian law firm. Their petition is being supported by a group comprising of seven members of US Congress who have filed a friend-of-the-court brief.
On January 27, 2025, the US Supreme Court agreed to review the decision of the 11th Circuit Court of Appeals in the FBI mistaken house raid immunity lawsuit. Granting a review in Martin vs United States, the court ordered fast tracking of the case for oral arguments. The case is likely to be heard in the 2024-25 term itself with a decision presumably by summer.