A Metro Atlanta family whose home was wrongly raided by an FBI SWAT team in October 2017 was back before the 11th U.S. Circuit Court of Appeals on Wednesday, trying once again to hold federal agents to account. The do-over hearing comes after a unanimous U.S. Supreme Court ruling wiped out the appeals court’s earlier dismissal and sent the case back for another look.
During the predawn operation, agents smashed in the front door, detonated a flash-bang and pointed weapons at Trina Martin, her then-partner Toi Cliatt and Martin's 7-year-old son, according to body-camera footage. The team left only after an agent double-checked mailbox numbers and realized they had the wrong house, then moved to the correct target a block away, according to the AP.
What the Supreme Court decided
In June 2025 the Supreme Court unanimously vacated the 11th Circuit's dismissal and sent the case back for further proceedings. The justices held that the Federal Tort Claims Act's law-enforcement proviso applies only to the statute's intentional-tort exception and rejected the appeals court's reliance on the Supremacy Clause as a reason to block the family's claims, according to the Supreme Court.
What's next at the 11th Circuit
On remand, the 11th Circuit now has to tackle the questions the high court left open. The panel must decide whether the FTCA's discretionary-function exception shields the federal government from negligence or intentional-tort claims in this kind of raid, and whether, under Georgia law, a private person would be on the hook for similar conduct.
Judges heard arguments Wednesday as the Martin family pressed the court to let their claims for assault, battery and false imprisonment go to trial, according to local coverage from WSB-TV.
Reaction from the family's lawyers
'Today the Supreme Court confirmed that victims of federal abuse have a powerful tool to seek accountability,' said Patrick Jaicomo of the Institute for Justice, which represents the Martins. Lawyers for the family say the remand gives them a fresh chance to argue that the lead agent's use of a personal GPS device, and the team's failure to check the mailbox number before breaching, were operational blunders rather than protected policy judgments. In their view, that would mean the government should not be able to hide behind immunity, a position the Institute for Justice has laid out in its public statements.
Legal context
Congress amended the Federal Tort Claims Act in 1974 after a wave of wrong-house raids, explicitly allowing lawsuits for certain intentional torts by law-enforcement officers - the change at the center of this fight. The Supreme Court's ruling answered one big threshold question about how that amendment fits with the rest of the statute but left unresolved how far the discretionary-function exception stretches, an issue that could shape federal law-enforcement liability nationwide, according to national coverage.
However the 11th Circuit rules will determine whether the Martin family gets a day in court and could influence how other appeals courts handle FTCA claims tied to mistaken raids. For Atlanta residents, and for anyone following police-accountability law, the case has become a key test of when federal officers can be sued for on-the-ground mistakes during high-risk operations.
