Camreta v. Greene Ex Rel. S. G.
131 S. Ct. 2020
| SCOTUS | 2011Background
- In Feb 2003, Camreta, a CPS caseworker, and Alford, a county deputy, interviewed S.G. at school about alleged abuse without a warrant or parental consent.
- S.G.'s mother sued Camreta and Alford under 42 U.S.C. § 1983 alleging Fourth Amendment seizure/interrogation in-school violated rights.
- The district court and Ninth Circuit held the interview violated the Fourth Amendment but shielded the officials with qualified immunity.
- The Ninth Circuit provided constitutional guidance to future officials, concluding that in-school interviews require traditional Fourth Amendment protections and cannot rely on a 'special need' justification.
- This Court granted certiorari to review whether immunized officials may challenge a lower court’s constitutional ruling and whether the Ninth Circuit erred on the Fourth Amendment issue.
- Ultimately, the Court held the case moot because S.G. had moved away and would not be subject to the same interviewing practices; it vacated the Fourth Amendment portion and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether immunized officials may obtain review of an appellate ruling | S.G. argues Article III bars review by immunized officials. | Camreta contends this Court may review due to injury from the ruling's prospective effects. | Yes, review is permitted in this posture. |
| Whether the Ninth Circuit’s Fourth Amendment ruling was correct | S.G. asserts violation of Fourth Amendment protections in-school interview. | Officials argue the ruling was improper to review or not clearly established. | The issue is moot; not resolved on the merits. |
| Whether mootness requires vacatur of the lower-court ruling | S.G. seeks vacatur to prevent non-reviewable ruling from shaping future conduct. | Camreta argues vacatur may undermine the court’s merit ruling. | Vacatur of the Fourth Amendment portion is appropriate; remand for further proceedings. |
| Whether the Court should review a merits ruling in qualified-immunity cases | S.G. asserts precedents permit review of constitutional rulings in immunized cases. | Camreta asserts policy reasons to review the meris ruling. | Limited exception adopted; Court may review in this special posture. |
| What is the proper disposition given mootness and reviewability | S.G. wants merits addressed despite mootness. | Camreta wants relief limited to vacatur of moot issue. | Vacate the Fourth Amendment portion; remand; leave immunity ruling intact. |
Key Cases Cited
- Munsingwear, Inc. v. United States, 340 U.S. 36 (1950) (mootness vacatur to avoid unreviewable decisions)
- Deposit Guaranty Nat. Bank v. Roper, 445 U.S. 326 (1980) (prevailing-party review limited to procedural issues)
- Electrical Fittings Corp. v. Thomas & Betts Co., 307 U.S. 241 (1939) (judgment scope and review limits for a prevailing party)
- Pearson v. Callahan, 555 U.S. 223 (2009) (two-step qualified-immunity framework and court discretion)
- County of Sacramento v. Lewis, 523 U.S. 833 (1998) (avoidance vs. clarification in qualified-immunity contexts)
- Saucier v. Katz, 533 U.S. 194 (2001) (initially required to decide constitutional question before immunity)
- Electrical Fittings Corp. v. Thomas & Betts Co. (duplicate), 307 U.S. 241 (1939) (see above for context)