Inmates of Attica Correctional Facility v. Rockefeller
477 F.2d 375 (1973)
Rule of Law:
The decision of whether to investigate and prosecute an alleged crime is a discretionary power of the executive branch, and federal courts may not compel federal or state prosecutors to initiate a criminal prosecution at the request of a private citizen.
Facts:
- In September 1971, a prisoner revolt occurred at New York's Attica Correctional Facility.
- During the state's recapture of the prison, 32 inmates were killed and many others were wounded.
- Inmates alleged that state police and corrections officers intentionally killed, assaulted, and beat prisoners without provocation, both during and after the recapture when inmates had surrendered.
- Inmates further alleged that their personal property was destroyed and that medical assistance was maliciously denied to over 400 wounded prisoners.
- A special state prosecutor, Robert E. Fischer, was appointed to investigate crimes related to the uprising.
- The inmates alleged that Fischer had no intention of investigating or prosecuting any of the state officers involved in the alleged crimes.
- The inmates also alleged that the United States Attorney for the Western District of New York had failed to investigate or prosecute any state officers for violations of federal civil rights laws.
Procedural Posture:
- Plaintiffs, including present and former inmates of Attica, filed a class action lawsuit in the U.S. District Court for the Southern District of New York.
- The defendants included various New York state officials and the U.S. Attorney for the Western District of New York.
- Plaintiffs sought an order in the nature of mandamus to compel defendants to investigate and prosecute state officers for alleged criminal conduct.
- The federal and state defendants filed motions to dismiss the complaint for failure to state a claim upon which relief could be granted.
- The district court granted the defendants' motions and dismissed the complaint without an opinion.
- Plaintiffs (appellants) appealed the dismissal to the U.S. Court of Appeals for the Second Circuit.
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Issue:
Does the federal judiciary have the authority to compel federal and state prosecutors, through an order of mandamus, to investigate and prosecute state officials for alleged criminal acts at the request of the alleged victims?
Opinions:
Majority - Mansfield
No, the federal judiciary does not have the authority to compel prosecutors to initiate criminal prosecutions. This decision rests within the discretionary power of the executive branch, a power protected by the constitutional doctrine of separation of powers. The court explained that federal courts have uniformly refrained from interfering with the discretionary decisions of federal prosecutors. This judicial reluctance is grounded in the separation of powers doctrine, which recognizes the prosecutor as an executive official exercising discretion that courts should not control. The court found that there are no manageable judicial standards for reviewing such decisions, as they involve complex factors like the sufficiency of evidence, grand jury secrecy, and allocation of limited prosecutorial resources. Forcing judicial review would place courts in the untenable position of being 'superprosecutors.' The court also held that 42 U.S.C. § 1987, which 'requires' U.S. Attorneys to prosecute certain civil rights violations, does not remove their traditional prosecutorial discretion, as similar mandatory language in other statutes has not been interpreted to do so. The court similarly found no basis to compel state prosecutors, as New York law also grants them discretion not subject to judicial review.
Analysis:
This case strongly affirms the principle of prosecutorial discretion as a core executive function protected by the separation of powers. The ruling establishes a high barrier for private citizens, even direct victims of severe alleged crimes, seeking to use the judiciary to compel criminal prosecutions. By declining to create a standard for judicial review of prosecutorial inaction, the court solidifies the prosecutor's role as the primary, and largely unchecked, authority on whether to bring criminal charges. This decision significantly limits the avenues for challenging a prosecutor's refusal to act, cementing the executive branch's control over the initiation of criminal proceedings in both state and federal systems.
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