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
- 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.
- 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.