Camreta v. Greene

563 U.S. 692 (2011)

Facts

In February 2003, police arrested Nimrod Greene for suspected sexual abuse of a young boy unrelated to him. The boy's parents told police that they suspected Nimrod of molesting his 9-year-old daughter S. G. Camreta (D), a child protective services caseworker was assigned to assess S. G.'s safety. Camreta (D), accompanied Alford (D), a deputy sheriff, went to S. G.'s elementary school and interviewed her about the allegations. Ds did not have a warrant, nor had they obtained parental consent to conduct the interview. S. G. at first denied that her father had molested her, she eventually stated that she had been abused. Nimrod was indicted and stood trial for sexually abusing S. G., but the jury failed to reach a verdict and the charges were later dismissed. P, S. G.'s mother, subsequently sued Ds on S. G.'s behalf under §1983, which authorizes suits against state officials for violations of constitutional rights. P alleged that Ds had breached the Fourth Amendment's proscription on unreasonable seizures. The District Court granted summary judgment to Ds, and the Ninth Circuit affirmed. The Court of Appeals first ruled that the interview violated S. G.'s rights because Ds had “seized and interrogated S. G. in the absence of a warrant, a court order, exigent circumstances, or parental consent. It then held that Ds were entitled to qualified immunity from damages liability because no clearly established law had warned them of the illegality of their conduct. Ds appealed. P claims that Article III bars review because petitions submitted by immunized officials present no case or controversy.