## Facts

- Linda R. S., the mother of an out-of-wedlock child, alleged that Richard D. was the child’s father and refused to provide support.
- Texas Penal Code art. 602 made it a misdemeanor for any parent to desert, neglect, or refuse to support a child under 18.
- Texas courts had construed art. 602 to apply only to parents of legitimate children, not to fathers of out-of-wedlock children.
- The local district attorney declined to prosecute Richard D., stating that fathers of out-of-wedlock children were outside the statute’s scope.
- Linda filed a federal action against the prosecutor and other Texas officials seeking an injunction requiring enforcement of art. 602 against fathers of out-of-wedlock children on equal protection grounds.

## Issues

1. Whether the mother had Article III standing to seek injunctive relief compelling a prosecutor to enforce a criminal non-support statute against an alleged father.
2. Whether the alleged discriminatory non-enforcement supplied a sufficient causal connection and likely redressability between the plaintiff’s injury (lack of child support) and the requested relief (prosecution).

## Decision

- The Supreme Court affirmed dismissal for lack of standing.
- The Court held that a private citizen lacks a judicially cognizable interest in the prosecution or nonprosecution of another.
- The Court concluded the requested relief would not likely redress the plaintiff’s asserted injury because prosecution under the statute would result in criminal punishment, not support payments.
- Because the standing defect was dispositive, the Court did not reach the merits of the equal protection claim regarding discriminatory application of art. 602.

## Legal Principles

- Article III standing requires a sufficient connection between the plaintiff’s injury and the challenged government action, and it must be likely that the requested relief will remedy the injury.
- A private party ordinarily cannot obtain judicial relief aimed at compelling criminal prosecution decisions, which are committed to executive discretion.
- When the remedy sought is prosecution, the plaintiff must show more than an interest in enforcement; the relief must plausibly address the concrete harm alleged.

## Conclusion

The Court held that the mother lacked standing to force criminal enforcement of a child-support statute because she could not show that prosecution would likely produce support payments, and private citizens generally have no judicially cognizable interest in another person’s prosecution or nonprosecution.


Linda R. S. v. Richard D., 410 U.S. 614 (1973)