Trina Martin FBI Lawsuit, Appeals Court Lets Fourth Amendment Claim Against Agent Continue After Wrong-House Raid

Updated October 8, 2026

A federal appeals court has issued a major new ruling in Trina Martin’s lawsuit over the FBI’s 2017 raid on the wrong Atlanta home, allowing Martin, her son and Toi Cliatt to continue pursuing a constitutional claim against the FBI agent who led the raid.

The 11th U.S. Circuit Court of Appeals ruled October 7, 2026, that FBI Special Agent Lawrence Guerra is not entitled to qualified immunity at this stage of the case. The court found that, viewing the evidence in the family’s favor, a reasonable jury could conclude that Guerra failed to take reasonable steps to make sure the FBI raided the correct house.

But the ruling is not a complete victory for the family.

The appeals court upheld the dismissal of the family’s claims against the United States under the Federal Tort Claims Act (FTCA). That means the federal government itself remains protected from liability in this lawsuit because of the FTCA’s discretionary-function exception.

The case now returns to the lower court on the remaining claim against Guerra.

Trina Martin FBI Lawsuit — Quick Facts

Detail	Information
Case	Curtrina Martin, et al. v. United States, et al.
Federal case number	No. 1:19-cv-04106-JPB
Appeal	No. 23-10062
Court	U.S. Court of Appeals for the 11th Circuit
Original court	U.S. District Court for the Northern District of Georgia
Location	Atlanta, Georgia
Plaintiffs	Curtrina “Trina” Martin, her son G.W., and Hilliard Toi Cliatt
Federal defendants	United States, FBI Special Agent Lawrence Guerra and other FBI agents
Underlying incident	FBI SWAT team mistakenly raided the plaintiffs’ home in October 2017
Supreme Court ruling	June 12, 2025
Latest appeals ruling	October 7, 2026
Latest result	FTCA claims against the United States remain dismissed; qualified immunity reversed for Agent Guerra
Settlement	None found
Claim form	None
Class action	No
Current status	Remanded for further proceedings

What Happened to Trina Martin and Her Family?

The lawsuit began after an FBI SWAT team went to the wrong Atlanta home during a predawn operation on October 18, 2017.

The FBI was supposed to execute search and arrest warrants connected to Joseph Riley, whom authorities had identified as a suspected gang member. Riley’s home was at 3741 Landau Lane.

Instead, the SWAT team went to 3756 Denville Trace, where Trina Martin lived with her then-fiancé, Hilliard Toi Cliatt, and her 7-year-old son. The two homes were several houses apart and were located on different streets. (Supreme Court)

At about 5 a.m., a six-member FBI SWAT team broke through the front door of Martin’s home and detonated a flash-bang grenade.

The agents entered the bedroom carrying rifles and wearing tactical equipment. Cliatt was pulled from a closet, forced onto the floor and handcuffed.

Martin was held at gunpoint.

Her young son was in another room and was terrified by the sounds of the raid.

The agents eventually realized they had the wrong address. The team left and proceeded to the actual target home, where Riley was arrested.

The FBI’s explanation for the mistake centered on Agent Guerra’s use of a personal Garmin GPS device, which he said directed him to the wrong location.

The appeals court also noted that the agents failed to notice obvious identifying information, including the street sign and house number.

Why Did the FBI Go to the Wrong Atlanta House?

The latest Eleventh Circuit opinion provides considerably more detail about how the mistake happened.

According to the record discussed by the court, Guerra had prepared for the operation and was supposed to know what the target residence looked like.

The target was at 3741 Landau Lane. Martin’s family lived at 3756 Denville Trace.

The court noted several differences between the homes, including their colors, exterior features, windows, landscaping and roof structures. The two properties were also separated by a cross street.

The court said Guerra claimed that his personal Garmin GPS directed him to the wrong house.

But the GPS itself was later discarded.

The court also examined conflicting evidence about whether Guerra had conducted a site survey or drive-by of the target residence before the raid.

For purposes of deciding qualified immunity, the appeals court was required to view disputed evidence in the plaintiffs’ favor.

Under that standard, the court concluded that the record could support a finding that Guerra had not conducted the claimed advance site survey or drive-by.

What Did the Supreme Court Decide in Trina Martin’s Case?

The latest appeals court decision follows a unanimous 2025 U.S. Supreme Court ruling that revived the family’s lawsuit after the Eleventh Circuit had previously rejected it.

In Martin v. United States, the Supreme Court ruled on June 12, 2025, that the Eleventh Circuit had applied the Federal Tort Claims Act incorrectly.

The Supreme Court rejected two important defenses previously relied upon by the government.

First, the Court held that the FTCA’s law-enforcement proviso does not override every exception in the statute. It specifically modifies the intentional-tort exception in 28 U.S.C. § 2680(h), rather than eliminating the separate discretionary-function exception in § 2680(a).

Second, the Supreme Court rejected the Eleventh Circuit’s use of a separate Supremacy Clause defense to defeat the FTCA claims.

The Supreme Court therefore sent the case back to the Eleventh Circuit for further consideration. (Supreme Court)

That distinction became extremely important in the October 2026 decision.

Why the October 2026 Eleventh Circuit Decision Matters

The new decision essentially produces a split result.

The United States won on the FTCA claims

The Eleventh Circuit affirmed the dismissal of Counts I through V against the United States.

Those claims included allegations involving:

• false arrest and false imprisonment;
• assault and battery;
• trespass and interference with private property;
• negligent and intentional infliction of emotional distress; and
• negligence.

The court concluded that the FTCA’s discretionary-function exception, 28 U.S.C. § 2680(a), protected the government from those claims under binding Eleventh Circuit precedent.

Agent Guerra lost on qualified immunity

The more significant development for Martin and the other plaintiffs came on the separate constitutional claim against Guerra.

The Eleventh Circuit reversed the lower court’s decision granting Guerra qualified immunity.

That means Guerra cannot rely on qualified immunity to end the Fourth Amendment claim at this stage.

It does not mean a jury has already found Guerra liable.

It also does not mean Martin has won damages.

Instead, the court determined that the evidence, viewed in the plaintiffs’ favor, could support a finding that Guerra violated a clearly established constitutional right.

What Is Qualified Immunity in the Trina Martin Case?

Qualified immunity is a legal protection that can shield government officials sued personally for constitutional violations.

Generally, an official can receive qualified immunity unless the plaintiff can show that:

1. the official violated a constitutional right; and
2. that right was clearly established under existing law.

The Eleventh Circuit examined earlier precedent involving officers who mistakenly entered or searched the wrong residence.

One particularly important case was Hartsfield v. Lemacks, 50 F.3d 950 (11th Cir. 1995).

In Hartsfield, the Eleventh Circuit said that, absent probable cause and exigent circumstances, officers must make reasonable efforts to avoid searching the wrong home.

The court concluded that precedent was important here.

Why the Eleventh Circuit Said Agent Guerra Could Lose Qualified Immunity

The appeals court identified several pieces of evidence that could support Martin’s position.

The court noted that:

• the target home and Martin’s home were separated by several houses;
• the homes were on different streets;
• a cross street separated the properties;
• the street signs identified different streets;
• house numbers were visible on the mailboxes;
• the homes had noticeable physical differences;
• Guerra had access to GPS and other mapping technology;
• the FBI had photographs and intelligence concerning the target property; and
• there were disputed questions about whether Guerra actually conducted the claimed advance site survey.

The court also considered evidence concerning Guerra’s disposal of the personal GPS device after the raid.

Importantly, the court was not making a final factual finding that every allegation against Guerra was proven.

It was deciding whether the evidence, when viewed under the summary-judgment standard, could support the plaintiffs’ constitutional claim.

The court said it could.

What Fourth Amendment Right Did Trina Martin Say the FBI Violated?

The plaintiffs’ constitutional claim arises under the Fourth Amendment, which protects people against unreasonable searches and seizures.

The original complaint alleged that the FBI agents entered the Martin family’s home without a warrant authorizing entry into that residence and detained the occupants without adequate legal justification.

The complaint brought the constitutional claim against the individual FBI agents under Bivens v. Six Unknown Named Agents of the Federal Bureau of Narcotics, 403 U.S. 388 (1971). (clearinghouse-umich-production.s3.amazonaws.com)

The complaint specifically alleged illegal entry, detention and false arrest under the Fourth Amendment.

It also cited Hartsfield v. Lemacks as precedent showing that officers must make reasonable efforts to identify the correct residence before executing a warrant.

What Claims Did Trina Martin Originally File?

The original complaint contained six counts.

Count I: False Arrest and False Imprisonment

Martin and the other plaintiffs brought these claims against the United States under the FTCA.

They alleged the FBI detained them without reasonable suspicion or probable cause.

Count II: Assault and Battery

The plaintiffs alleged that FBI agents held them at gunpoint during the mistaken raid.

The claims were brought against the United States under the FTCA.

Count III: Trespass and Interference With Private Property

The plaintiffs alleged that the FBI unlawfully entered and interfered with their property.

Count IV: Emotional Distress

The complaint included negligent and intentional infliction of emotional distress claims.

Count V: Negligence

The plaintiffs alleged that FBI agents failed to use reasonable care when executing the warrant.

Count VI: Fourth Amendment Violations

The plaintiffs sued the individual FBI agents under Bivens, alleging illegal entry, detention and false arrest.

The latest Eleventh Circuit ruling specifically addressed the qualified-immunity issue involving Agent Guerra under this constitutional claim.

What Is the Federal Tort Claims Act Doing in the Trina Martin Lawsuit?

The Federal Tort Claims Act, commonly called the FTCA, is the statute that allows people in certain circumstances to sue the United States for torts committed by federal employees acting within the scope of their employment.

The statute generally waives federal sovereign immunity for qualifying claims, but Congress included several exceptions.

The most important one in this case is the discretionary-function exception, 28 U.S.C. § 2680(a).

That exception can protect the federal government from liability for claims based on discretionary governmental functions.

The Supreme Court’s 2025 decision clarified that the law-enforcement proviso does not automatically eliminate that exception.

The Eleventh Circuit’s October 2026 ruling then applied its existing precedent and concluded that the exception barred the Martin family’s FTCA claims against the United States. (Supreme Court)

For a broader explanation of how the FTCA works and its limits, see Can You Sue the Federal Government for Wrongful Death? Federal Tort Claims Act Rules, Deadlines and the Renee Good Case.

Why the Supreme Court’s 2025 Ruling Did Not Guarantee Martin a Win

One important point is easy to miss when reading headlines about the case.

The Supreme Court did not rule that the Martin family was entitled to compensation.

It ruled that the Eleventh Circuit had used the wrong legal approach when it dismissed the case.

The Supreme Court specifically instructed the Eleventh Circuit to determine whether the discretionary-function exception could still block the family’s claims.

That is exactly the issue the Eleventh Circuit addressed after the case returned. (Supreme Court)

The result was unfavorable to the family’s FTCA claims against the United States but favorable to the constitutional claim against Agent Guerra.

Can Trina Martin Still Sue the FBI?

This requires an important distinction.

The lawsuit is not currently proceeding against the FBI as an agency in the same way a consumer might sue a private company.

The United States was sued under the FTCA.

Agent Guerra and other individual FBI agents were sued over alleged constitutional violations.

The October 2026 ruling affirmed the dismissal of the FTCA claims against the United States, but reversed qualified immunity for Guerra.

So the remaining path is primarily the constitutional claim against the individual agent, rather than a finding that the FBI itself must pay Martin damages.

Does Trina Martin Have a Settlement or Claim Form?

No.

There is no verified settlement announced in the Martin case, no settlement administrator, no consumer claim form and no deadline for members of the public to submit claims.

This is also not a class action.

The case involves the specific family whose home was mistakenly raided.

People who experienced unrelated FBI or law-enforcement raids cannot simply join the Martin lawsuit.

Can Trina Martin Receive Money From the Lawsuit?

Potentially, but there is no guaranteed payment.

The original complaint sought economic and compensatory damages for alleged injuries, including emotional distress, as well as other relief. It also sought punitive damages against the individual defendants. (clearinghouse-umich-production.s3.amazonaws.com)

The complaint did not specify a fixed dollar amount.

And the October 2026 appeals court ruling did not award damages.

The case still has to proceed through the remaining litigation before any determination of liability or damages can be made.

What Happens Next in the Trina Martin FBI Lawsuit?

The case has been remanded to the lower court.

The Eleventh Circuit’s October 7 opinion says:

• the FTCA claims against the United States remain dismissed;
• Agent Guerra’s qualified immunity has been reversed;
• the Fourth Amendment claim against Guerra can continue;
• the case returns to the district court for further proceedings.

The ruling therefore does not end the litigation.

It moves the case into another phase focused on the constitutional claim against the individual agent.

There could still be additional motions, further factual proceedings, settlement discussions or later appellate review.

The Institute for Justice, which represents the Martin family, has indicated that it views the ruling on Guerra’s immunity as a victory while considering further review of the ruling protecting the United States from FTCA liability. (Institute for Justice)

Could the Martin Family Ask the Full Eleventh Circuit to Reconsider the Government’s Immunity?

Possibly.

Judge Adalberto Jordan wrote a concurrence in the October 2026 decision and expressed serious concerns about the Eleventh Circuit’s existing interpretation of the discretionary-function exception.

The concurrence described the doctrine as particularly difficult to apply and suggested that the full Eleventh Circuit could reconsider the circuit’s approach.

The panel itself, however, said it was bound by existing Eleventh Circuit precedent and could not simply disregard earlier published decisions.

That leaves open the possibility of further proceedings concerning the government’s FTCA immunity.

But that possibility should not be described as a guaranteed next step.

What Does the Trina Martin Case Mean for Other Wrong-House Raids?

The case could have implications beyond Martin’s family.

The central legal question is how federal courts should treat government liability when federal law-enforcement officers mistakenly raid the wrong home.

The October 2026 decision is especially important because the Eleventh Circuit concluded that the individual agent could potentially face a Fourth Amendment claim even though the United States itself remains protected by the FTCA’s discretionary-function exception.

The court relied heavily on existing precedent requiring officers to make reasonable efforts to identify the correct residence.

That creates an important distinction between:

Government liability under the FTCA:
The United States remains protected in this case by the discretionary-function exception.

Individual-agent liability:
Agent Guerra cannot obtain qualified immunity at this stage because the evidence could support a finding that he failed to make reasonable efforts to avoid the wrong-house raid.

Trina Martin FBI Lawsuit Timeline

Date	Development
Oct. 18, 2017	FBI SWAT team mistakenly raids Martin family’s Atlanta home
Oct. 25, 2018	Martin’s side says it submitted administrative tort claims to the FBI
Sept. 11, 2019	Martin and her son file their federal complaint
Sept. 23, 2022	District court grants summary judgment on several claims and grants Guerra qualified immunity
Dec. 30, 2022	District court grants reconsideration after Eleventh Circuit precedent changes
Apr. 22, 2024	Eleventh Circuit affirms dismissal under its then-existing legal framework
Sept. 27, 2024	Martin and the other plaintiffs petition the U.S. Supreme Court
Apr. 29, 2025	Supreme Court hears oral arguments
June 12, 2025	Supreme Court unanimously vacates the Eleventh Circuit’s decision and remands
Mar. 25, 2026	Eleventh Circuit hears arguments after remand
Oct. 7, 2026	Eleventh Circuit affirms dismissal of FTCA claims against the United States but reverses qualified immunity for Agent Guerra
Current	Case remanded for further proceedings

The federal court records identify the district case as No. 1:19-cv-04106-JPB and the appeal as No. 23-10062.

Frequently Asked Questions About the Trina Martin FBI Lawsuit

Did Trina Martin win her FBI lawsuit?

Not completely. The October 2026 Eleventh Circuit ruling was partly favorable and partly unfavorable. The court affirmed dismissal of the claims against the United States under the FTCA but reversed qualified immunity for FBI Agent Lawrence Guerra, allowing the Fourth Amendment claim against him to continue.

Did the Supreme Court rule that the FBI must pay Trina Martin?

No. The Supreme Court’s 2025 decision revived the litigation and rejected the legal defenses previously used by the Eleventh Circuit, but it did not award damages.

Can Trina Martin still pursue Agent Guerra?

Yes. The Eleventh Circuit reversed the grant of qualified immunity to Guerra and remanded the case for further proceedings.

Did the court find Agent Guerra liable?

No. The appeals court held that qualified immunity should not end the claim at this stage. A finding that qualified immunity does not apply is not the same as a final finding of liability.

Did the court find that the FBI intentionally raided the wrong house?

No. The court addressed competing evidence about how the mistake occurred. The opinion discussed Guerra’s explanation that his GPS led him to the wrong location and evidence concerning whether he conducted an advance site survey. The court did not enter a final judgment finding intentional misconduct.

Was the FBI search warrant valid?

The FBI had warrants targeting another residence, 3741 Landau Lane. The central problem was that the agents executed the warrant at Martin’s residence, 3756 Denville Trace, instead. (Supreme Court)

Is there a Trina Martin FBI settlement?

No verified settlement exists. There is no settlement fund, claim form or public settlement deadline for the Martin case.

Can other people join Trina Martin’s lawsuit?

No. This is an individual lawsuit, not a class action.

What law is at the center of the lawsuit?

Several federal laws and constitutional doctrines are involved, but the major issues are the Federal Tort Claims Act, the Fourth Amendment, the FTCA’s discretionary-function exception under 28 U.S.C. § 2680(a), the law-enforcement proviso in § 2680(h) and qualified immunity for the individual FBI agent.

What did the latest court ruling actually change?

The biggest change is that Agent Guerra can no longer rely on qualified immunity to end the Fourth Amendment claim at the summary-judgment stage. The FTCA claims against the United States, however, remain dismissed.

Bottom Line on the Trina Martin FBI Lawsuit

The October 7, 2026 Eleventh Circuit decision is a significant new development, but it is not a complete win for Trina Martin.

The court drew a sharp line between the family’s claims against the federal government and its claim against the individual FBI agent.

The United States remains protected by the FTCA’s discretionary-function exception, so the government’s dismissal stands.

But Agent Lawrence Guerra lost qualified immunity after the appeals court concluded that the evidence, viewed in the family’s favor, could allow a reasonable jury to find that he failed to take reasonable steps to avoid raiding the wrong home.

That means the constitutional claim against Guerra can continue.

The case therefore remains unresolved.

There has been no settlement, no damages award and no claim program.

The next major development will likely come from the further proceedings following the Eleventh Circuit’s remand, or from any request for additional appellate review.

Sources and primary legal authorities: U.S. Supreme Court, Martin v. United States, No. 24-362 (June 12, 2025); U.S. Court of Appeals for the Eleventh Circuit, Curtrina Martin, et al. v. United States, et al., No. 23-10062 (Oct. 7, 2026); original complaint in No. 1:19-cv-04106-JPB; 28 U.S.C. §§ 1346(b), 2671–2680; U.S. Constitution, Fourth Amendment; Hartsfield v. Lemacks, 50 F.3d 950 (11th Cir. 1995); United States v. Gaubert, 499 U.S. 315 (1991); Bivens v. Six Unknown Named Agents, 403 U.S. 388 (1971).

This article is for informational purposes only and is not legal advice. Allegations made in court filings are not necessarily established facts. The October 2026 appellate ruling resolved certain legal issues but did not determine that Agent Guerra or the United States is ultimately liable for damages.