The following excerpt is from SR v. Cnty. of San Diego, CASE NO. 15cv0138 JM(RBB) (S.D. Cal. 2016):
Of course, an unconstitutional entry into one's home constitutes "paradigmatic" action under the Fourth Amendment, Michigan v. Tyler, 436 U.S. 499, 504 (1978), whether to obtain evidence or to remove a child from suspect circumstances. Where such an unconstitutional invasion is associated with the unwarranted removal of a child, the parent may argue, with great force, that his Fourteenth Amendment rights of familial association are clearly established. Where, however, the child's removal is from school rather than the home, the parent's right of familial association would appear to be leagues short of being clearly established.
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