rights, may not be vicariously asserted.” Alderman v. United States, 394 U.S. 165, 174, 89 S.Ct. 961, 966-67, 22 L.Ed.2d 176 (1969). The gravamen of plaintiffs’ Fourth Amendment claim in this case is the court-ordered seizure of L.B. The district court was correct in ruling that plaintiff mother, J.B., may not assert a derivative or vicarious claim based on L.B.’s Fourth Amendment injuries. But the court below did not focus on the separate claim of J.B., alleging her own distinct injuries as a result of the seizure of her seven-year-old daughter. While it is clear that constitutional protection afforded a parent against a child’s seizure in these circumstances may be found in the Fourteenth Amendment, Curnow ex rel. Curnow v. Ridgecrest Police, 952 F.2d 321, 325 (9th Cir.1991) (<HOLDING>); Griffin, 983 F.2d at 1547 (holding that
holding that a parent who claims loss of the companionship  of his or her child raises a claim based on the fourteenth not fourth amendment holding that bankruptcy jurisdiction is not within section 5 of the fourteenth amendment holding that fourth amendment claims are not cognizable on habeas review because the fourth amendment exclusionary rule does not relate to the accuracy of the factfinding process holding that the fourteenth amendment only applies to state action holding the fourteenth amendment does not apply to the actions of the federal government