COFFIN, Circuit Judge.
This case concerns a wide-ranging search conducted at the Massachusetts Correctional Institution at Framingham (Framing-ham), a medium security prison for women and men. Plaintiffs-appellees, nine female inmates, claim inter alia violations of their federal constitutional rights by twelve officers and officials of the Massachusetts Department of Correction, the Massachusetts State Police Department, and the Office of the Middlesex County District Attorney.1
[166]*166The district court granted defendants’ motion for summary judgment as to most of the claims,2 but denied the motion as to the plaintiffs’ fourth amendment claim that they were unreasonably searched. The court also rejected the defendants’ assertion that they were entitled to qualified immunity on that claim. Defendants appeal the denial of their claim of immunity. Although appeals from denials of summary judgment are generally not permitted, the Supreme Court in Mitchell v. Forsyth, 472 U.S. 511, 105 S.Ct. 2806, 86 L.Ed.2d 411 (1985), created a narrow exception allowing interlocutory review of denials of immunity for government officials. We therefore have jurisdiction, subject to the Mitchell constraints. After reviewing those constraints, we discuss the narrow issue before us and, finding that the constitutional right to be free from an abusive strip search was clearly established at the time of the search, we affirm.
I.
Our jurisdiction in this case is premised on the district court’s denial of the defendants’ claim of qualified immunity. Government officials performing discretionary functions may be shielded from liability for civil damages in a § 1983 action by the doctrine of qualified immunity. Harlow v. Fitzgerald, 457 U.S. 800, 818, 102 S.Ct. 2727, 2738, 73 L.Ed.2d 396 (1982); Davis v. Scherer, 468 U.S. 183, 104 S.Ct. 3012, 3020 n. 12, 82 L.Ed.2d 139 (1984) (immunity standard of Harlow applies in § 1983 actions). An official is entitled to immunity if, at the time of the challenged action, the statutory or constitutional right allegedly violated was not “clearly established”. Harlow, 457 U.S. at 818, 102 S.Ct. at 2738; Blackburn v. Snow, 771 F.2d 556, 569 (1st Cir.1985). The district court found that the right allegedly violated was clearly established at the time, and it therefore denied defendants’ claim of immunity.
In Mitchell v. Forsyth, 472 U.S. 511, 105 S.Ct. 2806, 86 L.Ed.2d 411 (1985), the Supreme Court carved out a narrow exception to the general rule that a case should be carried to conclusion before asserted errors can be reviewed. Recognizing the collateral and conclusive nature of the question of qualified immunity, id. 105 S.Ct. at 2816-17, as well as the fact that the policy behind immunity would be vitiated if an official was required to stand trial for violating a right that was not clearly established at the time, id. at 2815-16, the Court determined that a denial of qualified immunity, “to the extent that it turns on an issue of law”, id. at 2817, was an appealable final decision. Thus, if scrutiny of a plaintiff’s allegations indicates that, even if the alleged acts are proven, qualified immunity exists, the official should be spared the burden of further proceedings.3
In creating this exception to the final-judgment rule, the Mitchell Court carefully circumscribed the role of the appellate court. We are not to “consider the correctness of the plaintiffs facts, nor even determine whether the plaintiff’s allegations actually state a claim.” Mitchell v. Forsyth, 472 U.S. 511, 105 S.Ct. 2806, 2816, 86 L.Ed.2d 411 (1985). Instead, the issue before us is purely legal: “whether the legal norms allegedly violated by the defendant were clearly established at the time of the challenged actions”. Id. 105 S.Ct. at 2816 & n. 9. Thus, we must determine whether, assuming plaintiffs are able to prove the acts attributed to each defendant, the de[167]*167fendants are nonetheless immune because at the time of the alleged abusive strip search plaintiffs’ right to be free from such a search was not clearly established. See Ricci v. Key Bancshares of Maine, Inc., 768 F.2d 456, 466 (1st Cir.1985) (for purposes of Mitchell review, “we must assume that there is liability upon the part of the defendants”).
The dissent concludes that our review should encompass another question: whether each defendant’s conduct violated clearly established law. Two factors persuade us, however, that the qualified immunity inquiry focuses not on the defendant’s actions but on the right allegedly violated. First, the focus in Mitchell is on the alleged harm, and not on the defendant’s precise conduct. The Court observed that “[t]he question of Mitchell’s immunity turns on whether it was clearly established in November, 1970 ... that such wiretaps were unconstitutional,” id. 105 S.Ct. at 2818, and it found that “[t]he legality of the warrantless domestic security wiretap Mitchell authorized ... was, at that time, an open question,” id. at 2820. At another point, the Court noted that “[t]he legal determination that a given proposition of law was not clearly established at the time the defendant committed the alleged act does not entail a determination of the ‘merits’ of the plaintiff’s claim that the defendant’s actions were in fact unlawful.” Id. at 2817 n. 10.
Second, to focus on conduct in the context of this case is really to address the issue of causation. With respect to defendant Shaughnessy, who had a minimal connection to the alleged abusive strip search, the dissent claims the proper question is “whether the law was ‘clearly established’ that doing those limited, preliminary things that are all Shaughnessy did was a violation of a constitutional right.” But no one is suggesting that doing those preliminary actions is, in the abstract, a constitutional violation. The alleged violation is the abusive strip search. Thus, what the dissent is asking, in effect, is whether it was clearly established that Shaughnessy’s actions were closely enough connected to the alleged search to be deemed the equivalent of actually doing it. And that, we suggest, is really to ask whether it was clearly established that Shaughnessy could be deemed a cause of the search. As discussed in Section IV, infra, we have no doubt that we are not to consider causation at this stage — even if it could be decided as a matter of law on undisputed facts. Indeed, we think Harlow represented a deliberate shift in focus away from an individual defendant’s conduct — including whether he caused the harm — to the narrow issue of the right at stake, so that the immunity decision could be made by referring solely to the plaintiffs’ allegations. We therefore do not accept the dissent’s interpretation of Mitchell, which in this case would restore the issue of causation to the immunity inquiry.
The dissent questions not only our characterization of the qualified immunity question, but also our approach of considering only the plaintiffs’ allegations rather than the undisputed facts as revealed by depositions, affidavits and other discovery materials. We think our reading of Mitchell — setting a narrow boundary on interlocutory review of a defendant’s entitlement to immunity — is supported by both the Supreme Court’s language and its goals. In footnote 9 of Mitchell the Court emphasizes that “the appealable issue is a purely legal one: whether the facts alleged (by the plaintiff, or, in some cases, the defendant) support a claim of violation of clearly established law (emphasis added).” 105 S.Ct. at 2816. The only deviation Mitchell allows from the focus on the facts as alleged in the complaint is in a case where the district court accepted the defendant’s view of the facts and, even then, found that plaintiffs had a clearly established right to be free from the described harm. Id.
This interpretation — accepting at face value the facts as presented by one party and limiting the immunity inquiry to the clarity of the right violated — is consistent with the Supreme Court’s instruction to resolve the immunity question before dis[168]*168covery or trial, Harlow, 457 U.S. at 816-18, 102 S.Ct. at 2737-38. It does not, of course, foreclose the defendant from raising the issue of qualified immunity again, on appeal from final judgment, if the facts revealed through discovery or proven at trial diverge from the plaintiffs’ allegations. The critical point for us is that Mitchell envisions the interlocutory appeal of qualified immunity as a straightforward matter of assessing the law and not as a procedure for sorting out facts — even for the purpose of determining whether they are undisputed.
Moreover, we do not believe that limiting review to the alleged facts is as problematic as the dissent suggests. The dissent’s difficulty stems from its contention that the qualified immunity question involves scrutiny of each defendant’s conduct. But since, in our view, immunity depends only upon the clarity of the right allegedly violated, the only “facts” we need to know are those that constitute the harm alleged by the plaintiff. It does not matter if the facts as alleged overstate the involvement of an individual defendant. If so, and if the defendant is later found not to have caused the alleged harm, that defendant will win on the merits. What concerns us in our narrow interlocutory review is whether, if what the plaintiff says happened really happened, is the defendant nevertheless immune because the harm was not a clearly established constitutional or statutory violation. Although limiting the immunity inquiry to the allegations and to the clarity of the alleged right may mean that fewer officials are entitled to interlocutory appellate review of their claims of no liability, we nevertheless think this approach represents the balance struck by the Supreme Court in resolving a complicated problem.4
[169]*169We therefore confine our inquiry to the question of whether it was clearly established that plaintiffs had a constitutional right to be free from the alleged abusive strip search. Before examining this issue, we will briefly recite the relevant facts.
II.
Plaintiffs allege the following circumstances of the search. Early in 1981, Framingham correction officials provided the local district attorney’s office with information concerning possible drug violations, prostitution, gambling, and staff corruption at Framingham. The district attorney’s office undertook an investigation, which involved interviewing informants, reviewing institutional records, and examining telephone records and newspaper articles.
In December 1981, the defendants began planning an extensive search at Framing-ham. They obtained a search warrant providing that the search would be conducted according to an operational plan, incorporated by reference in the warrant. The plan provided for a search of the entire institution by a combined force of state police troopers and correction officers.
At approximately 3:00 a.m. on January 6, 1982, approximately two hundred state police officers dressed in “riot gear” entered the plaintiffs and other inmates’ rooms, awakened them, removed them from their cells, and handcuffed them. The officers refused to allow plaintiffs to put on clothing over their nightwear, and did not permit them to go to the bathroom. Officers searched plaintiffs' rooms for evidence of suspected drug use, gaming, and tax evasion, destroying plaintiffs’ property and leaving the rooms in disarray.
While the room searches were being conducted, male officers brought plaintiffs individually to closets, shower stalls, and laundry rooms, where female officers conducted body-cavity searches. The officers did not follow prison instructions that required internal examinations of body cavities to be conducted by medical personnel in a hygienic and respectful manner.5 None of the female officers were medical personnel, and no medical personnel were present. Several officers touched the plaintiffs’ body cavities during the searches, including putting their fingers in the plaintiffs’ noses, mouths, anuses, and vaginas. Officers did not change their gloves during a search of an inmate or between searches of different inmates. Indeed, each officer was provided with only one pair of gloves and thus could not have changed their gloves during the search procedure. Provisions were not made for menstruating women; for example, one plaintiff was not permitted to attend to the blood trickling down her leg during the search. The search procedures were visible to male officers who peered through open doors or openings in closed doors. At one point, a female officer threatened to bring a male officer into the room to conduct a strip search when an inmate expressed reluctance at disrobing.
After all searches were completed several hours later, plaintiffs were returned to their cells. Two plaintiffs were then taken to a separate building and questioned by state police detectives. They were not advised of their Miranda rights or allowed to consult counsel. Officers also removed five plaintiffs from their cells, and placed them in cold rooms formerly occupied by male inmates. These plaintiffs were returned to their own cells the following afternoon. All plaintiffs were locked in their cells until the evening meal on January 7, with telephone and visitation rights suspended.
III.
Plaintiffs seek to impose liability on the defendants as supervisory officials respon[170]*170sible for the January 6,1982 search. Plaintiffs allege that the defendants planned, supervised, and conducted the search, which involved an abusive and unreasonable body-cavity examination, in violation of the plaintiffs’ fourth amendment rights.6 As we have already discussed, the question before us is whether such acts violated rights that were clearly established at the time.
Specifically, we must determine whether it was clearly established that plaintiffs had a fourth amendment right to be free from a body-cavity search as alleged in this case. It was well-established in 1982 that inmates did not forfeit all constitutional protections by virtue of their confinement in prison. Bell v. Wolfish, 441 U.S. 520, 545, 99 S.Ct. 1861, 1877, 60 L.Ed.2d 447 (1979); Jones v. North Carolina Prisoners’ Labor Union, 433 U.S. 119, 129, 97 S.Ct. 2532, 2539, 53 L.Ed.2d 629 (1977); Meachum v. Fano, 427 U.S. 215, 225, 96 S.Ct. 2532, 2538, 49 L.Ed.2d 451 (1977); Wolff v. McDonnell, 418 U.S. 539, 555-56, 94 S.Ct. 2963, 2974, 41 L.Ed.2d 935 (1974); Pell v. Procunier, 417 U.S. 817, 822, 94 S.Ct. 2800, 2804, 41 L.Ed.2d 495 (1974). It was also recognized that “[l]awful incarceration brings about the necessary withdrawal or limitation of many privileges and rights, a retraction justified by the considerations underlying our penal system.” Price v. Johnston, 334 U.S. 266, 285, 68 S.Ct. 1049, 1060, 92 L.Ed. 1356 (1948).
In Bell v. Wolfish, 441 U.S. 520, 99 S.Ct. 1861, 60 L.Ed.2d 447 (1979), pretrial detainees at the Metropolitan Correctional Center (MCC) in New York challenged the constitutionality of numerous conditions of their confinement. Relevant for our purposes is the inmates’ fourth amendment claim that the institution’s practice of conducting visual body-cavity searches of the detainees following contact visits constituted an unreasonable search of their persons. After “assuming for present purposes that inmates, both convicted prisoners and pretrial detainees, retain some Fourth Amendment rights upon commitment to a corrections facility,” id. 441 U.S. at 558, 99 S.Ct. at 1884, the Supreme Court analyzed the reasonableness of the search.
The Court stated that the “test of reasonableness under the Fourth Amendment ... requires a balancing of the need for the particular search against the invasion of personal rights that the search entails.” Id. at 559, 99 S.Ct. at 1844. The MCC had “significant and legitimate security interests”, id. at 560, 99 S.Ct. at 1885, in preventing inmates from smuggling contraband into the facility by concealing it in body cavities. The Court stated, however, that a body-cavity search “instinctively gives us the most pause.” Id. at 558, 99 S.Ct. at 1884. Rather than set forth rules for evaluating particular body-cavity searches, the Court phrased its holding narrowly, going no further than necessary to reverse the lower court’s ruling. It concluded that “visual body-cavity inspections as contemplated by the MCC rules” could in some cases be conducted on less than probable cause. Id. at 560, 99 S.Ct. at 1885.
In analyzing the body-cavity searches, the Court emphasized certain factors. First, the searches were visual; they did not involve touching or physical penetration of the inmates’ bodily surfaces. The Court stressed that “[t]he inmate is not touched by security personnel at any time during the visual search procedure.” Id. at 558 n. 39, 99 S.Ct. at 1884 n. 39 (emphasis in original).7 Second, the [171]*171searches were conducted on inmates after contact visits that were not closely or constantly monitored, id. at 560 n. 40, 99 S.Ct. at 1885 n. 40, and were thus necessary to halt the introduction of contraband into the facility. Third, the Court made clear that it was not providing license for correction officers to conduct strip searches in an abusive manner: “Nor do we doubt, as the District Court noted, that on occasion a security guard may conduct the search in an abusive fashion. Such abuse cannot be condoned. The searches must be conducted in a reasonable manner.” Id. at 560, 99 S.Ct. at 1885 (citation omitted). Thus, the Court envisioned recourse for a prisoner who had been only visually strip searched, even when necessary for prison security purposes, if the search was conducted in an abusive manner.
That inmates retained some fourth amendment protection from unreasonable searches of their persons was also the uniform view of the courts of appeals and the local district court8 at the time of the search in question. See Note, Constitutional Limitations on Body Searches in Prisons, 82 Col.L.Rev. 1033, 1043 & n. 79 (1982). Most circuits had considered detainees’ and inmates’ fourth amendment challenges to prison practices, and, although the formulations varied, all courts agreed that some fourth amendment protection was available to inmates as to their persons. See e.g., Logan v. Shealy, 660 F.2d 1007, 1013 (4th Cir.1981) (strip search of detainee unreasonable under Bell v. Wolfish); Olson v. Klecker, 642 F.2d 1115, 116-17 (8th Cir.1981) (“Prisoners enjoy at least minimal fourth amendment protection in cell-search situations”); Hurley v. Ward, 584 F.2d 609, 611 (2d Cir.1978) (the “gross violation of personal privacy” involved in visual anal/genital searches of inmate, “especially in view of the physical and verbal abuse incident to the procedure”, outweighs state’s interest in the “prison security measure”); United States v. Lilly, 576 F.2d 1240, 1244 (5th Cir.1978) (“searches or seizures conducted on prisoners must be reasonable under all the facts and circumstances in which they are performed”); Bonner v. Coughlin, 517 F.2d 1311, 1317 (7th Cir.1975) (Stevens, J.) (“prisoner enjoys the protection of the Fourth Amendment against unreasonable searches, at least to some minimal extent”), cert. denied, 435 U.S. 932, 98 S.Ct. 1507, 55 L.Ed.2d 529 (1978); Daughtery v. Harris, 476 F.2d 292, 294-95 (10th Cir.) (rectal examination of inmates subjected to fourth amendment reasonable analysis), cert. denied, 414 U.S. 872, 94 S.Ct. 112, 38 L.Ed.2d 91 (1973). See also United States v. Chamorro, 687 F.2d 1, 4 (1st Cir.) (“The courts are generally in accord that what remains of fourth amendment protection behind prison gates is the prohibition of unreasonable searches and seizures.”) (citing Bonner, Lilly, United States v. Savage, 482 F.2d 1371, 1372 (9th Cir.1973) (“prisoner is entitled to fourth amendment’s protection from unreasonable searches and seizures”)), cert. denied, 459 U.S. 1043, 103 S.Ct. 462, 74 L.Ed.2d 613 (1982).
In addition, the local district court had determined that an inmate had stated a cause of action under § 1983 for a fourth amendment violation when he claimed that he was subject to visual rectal body-cavity searches conducted in an abusive fashion. Arruda v. Berman, 522 F.Supp. 766, 768 (D.Mass.1981) (Caffrey, C.J.) (“While Bell v. Wolfish clearly allows the administration of reasonable body-cavity searches, the plaintiff’s allegations, if proven, may be found to be the type of unreasonable body cavity searches which the Supreme Court ruled in Bell are forbidden by the Fourth Amendment.”). Nor has this view changed since the time of the search in question. This circuit, for example, several months after the search, held that “an inmate retains some residuum of fourth amendment [172]*172protection.” United States v. Chamorro, 687 F.2d 1, 4 (1st Cir.1982).
Although it was clearly established at the time of the Framingham search that body-cavity searches had to be reasonable, we must still determine whether the particular search alleged in this case was considered unreasonable by the then-prevailing case law. For a legal norm to be clearly established, it does not require “specific judicial articulation.” Blackburn, 771 F.2d at 570 (quoting King v. Higgins, 702 F.2d 18, 20 (1st Cir.), cert. denied, 464 U.S. 965, 104 S.Ct. 404, 78 L.Ed.2d 344 (1983)).9 As the Court stated in Mitchell, an official is not always “immune from liability or suit for a warrantless search merely because the warrant requirement has never explicitly been held to apply to a search conducted in identical circumstances.” 105 S.Ct. at 2820 n. 12. But where a “legitimate” or “open” question existed at the time, an official is entitled to qualified immunity. Id. at 2820 & n. 12.
In the instant case, we find that the reasonableness of the search complained of was not an open question at the time of the alleged violation. All courts that had considered the issue had recognized “the severe if not gross interference with a person’s privacy that occurs when guards conduct a visual inspection of body cavities”. Arruda v. Fair, 710 F.2d 886, 887 (1st Cir.) (emphasis added), cert. denied, 464 U.S. 999, 104 S.Ct. 502, 78 L.Ed.2d 693 (1983). See e.g., Wolfish, 441 U.S. at 558, 99 S.Ct. at 1884 (body-cavity searches “give[] us the most pause”); Hurley, 584 F.2d at 611 (“gross violation of personal privacy”); Lilly, 576 F.2d at 1246 (“few searches are more intrusive”).
The searches to which the plaintiffs were allegedly subject did not involve only the visual inspection of body cavities present in each of the previously cited cases. It is alleged in this case that police officers touched and placed their fingers in the noses, mouths, anuses, and vaginas of the plaintiffs. This distinction is significant and has been noted by courts. See e.g., Wolfish, 441 U.S. at 558 n. 39, 99 S.Ct. at 1884 n. 39 (“visual search procedure”) (emphasis in original); Blackburn, 771 F.2d at 565 n. 5 (“Even courts that have upheld body cavity searches of inmates ... have emphasized that those searches included no touching at all”) (citations omitted); Arruda v. Fair, 710 F.2d 886, 887 (1st Cir.1983) (“visual inspection of body cavities”); Thome v. Jones, 765 F.2d 1270, 1271 n. 1 (5th Cir.1985) (“In a strip search, the naked body of the subject is very thoroughly inspected, but not touched”); Security and Law Enforcement Employees v. Carey, 737 F.2d 187, 192 (2d Cir.1984) (“It is important for analytical purposes to note that none of the searches of the correction officers herein involved any touches, probes or other bodily intrusions.”); Bono v. Saxbe, 527 F.Supp. 1182, 1186 (S.D.Ill.1980) (the “redeeming quality of the search is its visual, non-contact nature”), aff'd in part and remanded in part, 620 F.2d 609 (7th Cir. 1980).
Apart from the touching that was claimed to be involved, the body-cavity searches were further aggravated in this case. The searches of the female inmates were conducted in the presence of male officers; police officers, not medical personnel, performed the searches; and each officer was provided with only one pair of gloves for the entire procedure. In reviewing the reasonableness of particular body-cavity searches, courts have stressed that they were conducted in a private area and in a hygienic manner. See e.g., Thome, 765 F.2d at 1271 n. 1 (search conducted by [173]*173prison personnel of same sex and conducted in private); Hurley, 584 F.2d at 610 n. 1 (if body-cavity search is needed, inmate shall be examined by “facility health staff member”); Lilly, 576 F.2d at 1247 (“body cavity search was conducted by a female medical officer in the prison clinic in the presence of only the medical officer and a female correctional officer”); Daughtery, 476 F.2d at 295 (search “carried out by trained paraprofessional medical assistants in a designated area and under sanitary conditions”, and no attempt made by “officials or medical personnel to humiliate or degrade” inmates).
In light of the then-prevailing case law from the Supreme Court, the courts of appeals, and the local district court, we find that a body-cavity search of female inmates conducted by police officers, involving touching, conducted in a non-hygienic manner and in the presence of male officers, was a clearly established violation of the inmates’ fourth amendment right to be free from an unreasonable search.10
IV.
In a separate brief to this court, defendant-appellant William Shaughnessy raises two additional arguments both related to his claim that he did not cause the alleged fourth amendment violation.11 First, Shaughnessy claims that the plaintiffs did not raise a genuine issue as to whether he in fact committed the acts complained of, and that we should now review the district court’s conclusion to the contrary. We find that we do not have jurisdiction to review that question on this appeal.
The fact that we have jurisdiction over a district court order on an interlocutory basis does not permit us to review other claims raised below. Abney v. United States, 431 U.S. 651, 663, 97 S.Ct. 2034, 2042, 52 L.Ed.2d 651 (1977). Any additional claim presented to and rejected by the district court must independently satisfy the collateral-order exception to the final-judgment rule in order for us to address it on an interlocutory appeal. Id. “Any other rule would encourage [parties] to seek review of, or assert frivolous [appealable] claims in order to bring more serious, but otherwise nonappealable questions to the attention of the courts of appeals [prior to final judgment].” Id. 431 U.S. at 663, 97 S.Ct. at 2042. Thus, in order for us to review the denial of Shaughnessy’s motion for summary judgment on this interlocutory appeal, Shaughnessy must show that the denial meets the requirements of an interlocutory appeal.
The district court’s denial of Shaughnessy’s motion for summary judgment does not satisfy any of the three requirements for interlocutory appeal set forth in Cohen v. Beneficial Industrial Loan Corp., 337 U.S. 541, 546, 69 S.Ct. 1221, 1225, 93 L.Ed. 1528 (1941). In Mitchell, the Court described Cohen’s three-part test: to be immediately appealable, the or[174]*174der must (1) be effectively unreviewable on appeal from a final judgment; (2) conclusively determine the disputed question; and (3) resolve an important issue completely separate from the merits of the action. Mitchell, 105 S.Ct. at 2815.
As to the first requirement, a denial of a claim that discovery has not uncovered facts sufficient to raise a genuine issue as to whether defendant caused the alleged wrong is not “essentially unreviewable”. This claim, like a defense based on statute of limitations, collateral estoppel, or lack of jurisdiction, is a defense to liability, which need not be reviewed before the proceedings terminate in order to be reviewed at all. Id. A defense to liability is not effectively lost if a case is erroneously permitted to go to trial.
Pretrial motions relating to liability are quite distinct from the qualified immunity claim addressed in Mitchell. When a government official asserts a defense of qualified immunity, his argument is that, even assuming the plaintiff’s allegations are true, he is immune from suit because the law allegedly violated was not clearly established at the time. Immunity from suit is an entitlement not to stand trial, “rather than a mere defense to liability”. Id. at 2816. Thus, the entitlement is “effectively lost if a case is erroneously permitted to go to trial.” Id.
In contrast, Shaughnessy’s claim that he did not in fact cause the alleged wrong is not an argument that he is entitled to immunity, but rather is an argument that he is not liable. That claim is not effectively unreviewable. Of course, any dispositive, pretrial motion, if erroneously decided against government officials, would necessarily have the unfortunate effect of requiring them to proceed to trial. But we are not prepared to create, and do not think the Supreme Court would countenance, an approach completely eliminating the final-decision requirement for public officials, granting them the right to immediately appeal any adverse pretrial ruling. Id. at 2830 (opinion of Brennan, J., dissenting) (“I hardly think the Court is prepared to hold that a government official suffering an adverse ruling on any [dispositive preliminary issue] would be entitled to an immediate appeal.”).
Moreover, the district court’s denial of summary judgment for Shaughnessy clearly fails to satisfy Cohen’s second and third criteria, which an appealable interlocutory decision must satisfy. Mitchell, 105 S.Ct. at 2816. The second criterion is that the decision must “conclusively determine the disputed question”. Id. (quoting Coopers & Lybrand v. Livesay, 437 U.S. 463, 468, 98 S.Ct. 2454, 2458, 57 L.Ed.2d 351 (1978)). In this case, the subsequent course of the proceedings could alter the district court’s conclusion that a genuine issue exists as to whether the defendant in fact committed the alleged acts. Either after more discovery or after the presentation of the plaintiff’s case at trial, the court may grant Shaughnessy’s motion for summary judgment or directed verdict by finding that a genuine issue no longer exists as to his involvement in the alleged wrong. Thus, the court’s denial of summary judgment on these grounds does not finally and conclusively determine the defendant’s claim.
Shaughnessy’s claim also fails to satisfy the third criterion, which is that the “question must involve a ‘clai[m] of right separable from, and collateral to, rights asserted in the action’ ”. Mitchell, 105 S.Ct. at 2816 (quoting Cohen, 337 U.S. at 546, 69 S.Ct. at 1225) (brackets in original). Quite obviously, the defendant’s claim that he did not in fact commit the alleged acts cannot be described as “conceptually distinct from the merits of the plaintiff’s claim that his rights have been violated.” Id. at 2816. Unlike the claim of qualified immunity, this claim requires the appellate court to “consider the correctness of the plaintiff’s version of the facts” and “whether the plaintiff’s allegations actually state a claim”. Id. Thus, the denial of Shaughnessy’s Rule 56 motion is an interlocutory order from which no appeal is available until the entry of judgment following the trial on the merits. See, e.g., Wright, Miller & [175]*175Kane, Federal Practice and Procedure: Civil 2d § 2715, at 636 (1983).
Shaughnessy’s second argument is that the district court erred in denying his claim of qualified immunity because “another officer, standing in [his] shoes and having the same information [he] had, would [not] reasonably have come to the conclusion that by assisting in developing [the search plan], he was thereby violating a constitutional right of the plaintiffs.”12 Although we have difficulty discerning the precise nature of this argument, we believe Shaughnessy is claiming that he is entitled to qualified immunity because he should not reasonably have known that his conduct would be deemed cause-in-fact of the alleged violation. As we shall now discuss, this argument no longer fits within the immunity inquiry.
Prior to Harlow, the immunity standard had both an “objective” and a “subjective” aspect. See Wood v. Strickland, 420 U.S. 308, 322, 95 S.Ct. 992, 1001, 43 L.Ed.2d 214 (1975) (official not immune if “he knew or reasonably should have known that the action he took within his sphere of official responsibility would violate the constitutional rights [of the plaintiff], or if he took the action with malicious intention to cause a deprivation of constitutional rights____”). The objective aspect itself had three components: was “the constitutional right allegedly infringed by [the official] clearly established at the time of the[] challenged conduct”; did the official know, or should he have known, of that right; and did the official know, or should he have known, that his conduct violated the constitutional norm. Procunier v. Navarette, 434 U.S. 555, 562, 98 S.Ct. 855, 859, 55 L.Ed.2d 24 (1978). Shaughnessy’s argument is, in effect, the last question under the objective prong, which focuses on the causal link between his conduct and the violation. But the Court in Harlow eliminated this question from the immunity inquiry.
In Harlow, the Supreme Court narrowed the inquiry to the sole question of whether the statutory or constitutional rights allegedly violated were clearly established. The purpose behind this new formulation was to allow for the resolution of many complaints before discovery or trial. 457 U.S. at 816-18,102 S.Ct. at 2737-38. The Court eliminated from the immunity standard questions such as causation, which depended upon the facts of the individual case, so that immunity could be granted or denied on the basis of the allegations in the complaint. While Mitchell provided that decisions denying qualified immunity could be immediately appealed, it expressly limited the scope of the appeal to Harlow’s “purely legal” question of “whether the legal norms allegedly violated” were clearly established. Mitchell, 105 S.Ct. at 2816 & n. 9.
Whether phrased as an appeal from the district court’s finding that genuine issues existed as to causation, or as an appeal from the district court’s denial of the immunity claim, Shaughnessy’s argument that he did not cause the alleged violation is not properly before us on this Mitchell appeal. As the D.C. Circuit stated in Hob-son v. Wilson, 737 F.2d 1, 29 (D.C.Cir. 1984), “we must consider in this action only whether the right that plaintiffs alleged to have been violated was well-established at the time the alleged acts occurred. We consider irrelevant to this inquiry defendants’ assertions that the evidence does not support those allegations; such evidence is properly considered as an element of our inquiry into the sufficiency of the evidence, not qualified immunity.”
We acknowledge that it is superficially tempting, in the interests of judicial economy, to address on interlocutory appeal any issue that might be dispositive of a defendant official’s freedom from liability, such as his causal connection with the acts charged, a statute of limitations defense, or collateral estoppel. Mitchell’s deliberately [176]*176narrow focus, however, is amply justified by the implications of a broad-ranging review. Factually based interlocutory appeals from denial of summary judgment typically involve the reading of lengthy depositions, answers to interrogatories, documents, and record material, often filled with ambiguous and unclear statements. Deciding whether there is, or is not, sufficient evidence to warrant placing a factual question before a jury is often excruciatingly difficult. Trial judges often err on the side of submission, for a jury verdict, after all, typically washes out the summary judgment question, turning it into the easier question of the legitimacy of the verdict in light of all the evidence placed before the jury. To require appellate courts to investigate and to answer such questions before trial would, of course, occasionally save a government defendant the onerous burden of unnecessarily standing trial, but it would also interfere with the opportunities of other litigants to obtain justice by significantly slowing down the appellate process. We are not willing to believe that the Supreme Court has told us to undertake on a routine basis this onerous, unwieldy task of reviewing factually based trial court rulings that might otherwise never be presented for review without a clear statement to that effect.
Finally, we note that a defendant such as Shaughnessy, believing that plaintiffs can show no factual link between him and the complained of conduct, is not without a remedy. He can ask the district court for summary judgment; he can ask the jury for a verdict; he can, if necessary, ask for a directed verdict and a judgment n.o.v. Eventually, he can obtain appellate review of any adverse jury verdict. We note that in this case plaintiffs have not specifically stated the connections they intend to prove between the particular conduct complained of and each of the defendants they have sued. We believe that it should still be open to defendants to ask the district court to order such a specific statement and to reconsider, in light of that statement and the evidence in the record, the individual defendants’ requests for summary judgment. See Mitchell, 105 S.Ct. at 2816 (even when “plaintiff’s complaint adequately alleges the commission of acts that violated clearly established law, the defendant is entitled to summary judgment if discovery fails to uncover evidence sufficient to create a genuine issue as to whether the defendant in fact committed those acts.”).
The order of the district court denying defendants qualified immunity as to the alleged fourth amendment violation is affirmed.