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Camreta v. Greene

563 U.S. 692, 131 S. Ct. 2020 (2011)

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Camreta v. Greene

United States Supreme Court

563 U.S. 692, 131 S. Ct. 2020 (2011)

Facts

In 2003, child protection service agents Bob Camreta and James Alford (defendants) interviewed a child (S.G.) at her elementary school concerning sexual abuse claims against her father. Camreta and Alford did not have a warrant and did not seek parental consent for the interview. S.G. made claims of abuse, and her father was indicted, but the charges were later dismissed. S.G.’s mother, Sarah Greene (plaintiff), then sued Camreta and Alford, alleging that the interview violated S.G.’s Fourth Amendment rights against unreasonable seizures. The district court granted summary judgment for Camreta and Alford, and the United States Court of Appeals for the Ninth Circuit affirmed. The court of appeals upheld the ruling of qualified immunity, finding there was no clearly established law warning Camreta and Alford that their actions were illegal. The court of appeals also ruled on the merits of the constitutional claim, ruling that the defendants had violated S.G.’s rights by interrogating her without a warrant or parental consent. The purpose of the constitutional ruling was to provide guidance to government officials in similar situations in the future. Even though Camreta and Alford were the prevailing parties, the United States Supreme Court granted their request for certiorari on the issue of whether their conduct violated the Fourth Amendment. At the time the Supreme Court heard the case, nine years after it was filed, S.G. had moved to Florida and was almost 18 years old.

Rule of Law

Issue

Holding and Reasoning (Kagan, J.)

Concurrence (Sotomayor, J.)

Concurrence (Scalia, J.)

Dissent (Kennedy, J.)

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