How have we interpreted substantive due process under the Fourth Amendment?

Tenenbaum, 193 F.3d at 599 (brackets and internal quotation marks omitted). We said that "'[s]ubstantive due process analysis is . . . inappropriate . . . if [the] claim is covered by the Fourth Amendment.'" Id. at 600 (quoting Lewis, 523 U.S. at 843) (second brackets in original; other internal quotation marks omitted). We then concluded that the daughter's "removal and her examination constituted a seizure and search, respectively, under the Fourth Amendment," id., and that her claim "therefore 'must be analyzed under the standard appropriate to [the Fourth Amendment], not under the rubric of substantive due process.'" Id. (quoting United States v. Lanier, 520 U.S. 259, 272 n.7 (1997)).²⁹

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