Linda R.S. v. Richard D.
Citation and Court
410 U.S. 614 (1973), Supreme Court of the United States
Facts
An unmarried mother sought to compel a district attorney to prosecute the father of her illegitimate child for failure to pay child support, arguing a Texas statute was unconstitutionally applied to exempt fathers of illegitimate children from criminal prosecution. She claimed standing based on her financial interest in having the father prosecuted and jailed.
Issue
Whether a private citizen has standing to seek judicial compulsion of a criminal prosecution against another person.
Holding
A private citizen lacks standing to challenge the non-prosecution of another person because such a plaintiff has no judicially cognizable interest in the prosecution or non-prosecution of another.
Rule / Doctrine
In American jurisprudence, the decision whether to prosecute lies within the exclusive discretion of the executive branch. A private citizen suffers no legally cognizable injury from a prosecutor’s decision not to bring charges; any connection between the requested prosecution and the plaintiff’s injury is too speculative and attenuated to confer Article III standing.
Significance
Linda R.S. is the foundational case for the principle that victims and third parties have no enforceable right to demand criminal prosecution. It also reflects the constitutional separation of powers — prosecutorial discretion is an executive function insulated from judicial compulsion.