Camreta v. Greene Ex Rel. S. G.

2011-05-26
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Headline: Court says officials protected from damages may seek Supreme Court review but declines review here and vacates the Ninth Circuit’s ruling on warrantless in‑school child interviews, leaving guidance unresolved.

Holding:

Real World Impact:
  • Leaves unclear rules for in‑school interviews of suspected child abuse victims.
  • Allows immunized officials to seek Supreme Court review of adverse constitutional rulings.
  • Vacatur removes Ninth Circuit’s guidance, so future cases can relitigate standards.
Topics: school interviews, child abuse investigations, official immunity, searches and seizures

Summary

Background

In 2003 a child welfare worker, Bob Camreta, and a county deputy sheriff, James Alford, interviewed a nine-year-old girl at her elementary school about allegations against the girl’s father. They had no warrant and no parental consent. The girl’s mother sued on the girl’s behalf for money damages, saying the in‑school interview violated the Fourth Amendment. The Ninth Circuit said the interview was unconstitutional but found the officials immune from damages.

Reasoning

The Supreme Court considered two questions: whether officials who win on immunity can ask the Court to review an appellate court’s constitutional ruling, and whether the Ninth Circuit was right about the Fourth Amendment. The Court said such officials generally may seek review because those lower‑court constitutional statements can have real effects on how officials must do their jobs. The Court did not address the Fourth Amendment issue here because the case became moot after the child moved away and neared adulthood, and so it vacated the Ninth Circuit’s opinion on that point.

Real world impact

The Court left unclear the specific rules for interviewing suspected child-abuse victims at school because the Ninth Circuit’s guidance was vacated. The decision confirms that officials shielded from damages can petition the Supreme Court to challenge constitutional statements attached to immunity rulings. The part of the lower court decision that denied damages remains undisturbed, and the Fourth Amendment question can be decided later in a live case.

Dissents or concurrances

Justice Sotomayor (joined by Justice Breyer) agreed with vacating the ruling but would not decide whether immunized officials may obtain review; Justice Scalia joined the Court; Justice Kennedy dissented, warning against expanding review by prevailing parties.

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