Camreta v. Greene, 563 U.S. 692

S.G., via her mother as next friend, sued Camreta and Alford under 42 U.S.C. § 1983 for a Fourth Amendment seizure claim arising from an in-school interview at S.G.'s Oregon elementary school.
The interview occurred days after police informed Oregon DHS of alleged sexual abuse by S.G.'s father, Nimrod Greene; Camreta (CPS caseworker) and Alford (deputy sheriff) conducted the interview without a warrant or parental consent.
The Ninth Circuit held the interview violated the Fourth Amendment but affirmed immunity, ruling the officials were not liable due to lack of clearly established law.
The Court granted certiorari to decide (1) whether immunized officials may obtain review of a lower court’s constitutional ruling, and (2) whether the Ninth Circuit correctly found a Fourth Amendment violation.
The Court held it generally may review such rulings but the case is moot because S.G. has aged out of the situation and moved away, so it vacated the Fourth Amendment ruling and remanded for proceedings consistent with this opinion.
The judgment below thus survives only to the extent of immunity, while the Fourth Amendment ruling is vacated due to mootness.

Issue	Plaintiff's Argument	Defendant's Argument	Held
May immunized officials obtain review of a lower court’s constitutional ruling?	S.G. argues Article III bars review since immunity precludes live dispute.	Camreta/Alford contend this Court may review under §1254(1) despite immunity.	Yes, the Court may review in this posture.
Was the Ninth Circuit’s Fourth Amendment ruling on the interview correct?	S.G. asserts a constitutional violation occurred.	Officials argue the issue should be resolved later or is not reviewable here due to mootness.	The issue is moot; no merits decision reached on the Fourth Amendment.
What disposition is appropriate given mootness and immunity review?	Vacatur unnecessary if review is inappropriate.	Vacatur necessary to avoid unreviewable constitutional ruling with prospective effect.	Vacate the Fourth Amendment portion and remand; leave immunity ruling intact; case remanded consistent with this opinion.

Deposit Guaranty Nat. Bank v. Roper, 445 U.S. 326 (1980) (standing to review prevailing-party challenges; Article III practices)
Electrical Fittings Corp. v. Thomas & Betts Co., 307 U.S. 241 (1939) (review of judgment when dispositive issues involve only a portion of the decree)
Munsingwear, Inc. v. United States, 340 U.S. 36 (1950) (vacatur to avoid mootness and permit future relitigation)
Lyng v. Northwest Indian Cemetery Protective Assn., 485 U.S. 439 (1988) (judicial restraint and avoidance in certain constitutional questions)
Saucier v. Katz, 533 U.S. 194 (2001) (two-step qualified-immunity framework (constitutional question first))
Pearson v. Callahan, 555 U.S. 223 (2009) (discretion to address qualified immunity in varying orders; not mandatory to decide constitutional question first)
Arizonans for Official English v. Arizona, 520 U.S. 43 (1997) (standing and Article III considerations in jurisdictional analysis)