Linda R. S. v. Richard D.
410 U.S. 614, 93 S.Ct. 1146, 35 L.Ed.2d 536 (1973)
Rule of Law:
A plaintiff lacks standing to challenge the constitutionality of a state's policy of not prosecuting a certain class of criminal defendants if the plaintiff cannot demonstrate that their injury would be redressed by the prosecution they seek to compel.
Facts:
- Linda R. S. is the mother of a child born out of wedlock.
- Richard D. is the alleged father of the child.
- Richard D. has refused to provide financial support for the child.
- Texas Penal Code Art. 602 made it a criminal misdemeanor for a parent to willfully refuse to provide for the support of their child under eighteen.
- Texas courts had consistently interpreted Art. 602 to apply only to the parents of legitimate children.
- Linda R. S. requested that the local district attorney enforce Art. 602 against Richard D.
- The district attorney refused to prosecute Richard D., citing the express reason that the statute did not apply to fathers of illegitimate children.
Procedural Posture:
- Linda R. S. filed a class action lawsuit against the local district attorney in the U.S. District Court for the Northern District of Texas.
- She sought an injunction to prevent the district attorney from continuing the policy of not prosecuting fathers of illegitimate children under Texas Penal Code Art. 602.
- A three-judge panel of the District Court was convened to hear the case.
- The District Court dismissed the action, ruling that Linda R. S. lacked standing to bring the suit.
- Linda R. S. filed a direct appeal of the District Court's dismissal to the Supreme Court of the United States.
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Issue:
Does the mother of an illegitimate child have standing to bring a federal lawsuit challenging a state's policy of not prosecuting fathers of illegitimate children for criminal non-support, when prosecution of the father would not necessarily result in the mother receiving support payments?
Opinions:
Majority - Justice Marshall
No. A plaintiff lacks standing to challenge a state's criminal prosecution policies unless they can show a direct nexus between their injury and the relief sought. Appellant Linda R. S. has an injury in the form of not receiving child support, but she fails to show that the relief she requests—the prosecution of the child's father—would redress that injury. The prospect that jailing the father would result in him providing support payments is purely speculative. In American jurisprudence, a private citizen lacks a judicially cognizable interest in the prosecution or nonprosecution of another person, as the link between the government action (or inaction) and the citizen's injury is too attenuated.
Dissenting - Justice White
Yes. The mother of an illegitimate child has standing to challenge the discriminatory enforcement of a child support law. The appellant and her class are directly injured by being intentionally excluded from the protections of a state criminal law that benefits mothers of legitimate children. The majority's assertion that the coercive effect of criminal sanctions is merely 'speculative' is contrary to the entire premise of the criminal justice system, which assumes that the threat of punishment influences behavior. Denying the appellant this coercive tool, which the state provides to others, is a clear and cognizable injury sufficient to confer standing.
Dissenting - Justice Blackmun
The Court should not decide the standing issue. The recent decision in Gomez v. Perez, which established a civil duty of support for illegitimate children, may have fundamentally altered the legal landscape and appellant's need to rely on the criminal statute. This intervening circumstance may have rendered the controversy moot or altered the parties' legal positions. Therefore, rather than deciding a difficult constitutional question about standing, the Court should remand the case to the District Court to clarify whether a live controversy still exists.
Analysis:
This case is a foundational decision in the law of standing, specifically clarifying the 'redressability' requirement. It establishes the principle that a plaintiff cannot simply allege an injury and a corresponding unconstitutional government action; they must also demonstrate that a favorable court decision would likely remedy their specific harm. The ruling significantly limits the ability of private citizens to use federal courts to compel or influence prosecutorial discretion, reinforcing the separation of powers by keeping the judiciary out of executive branch enforcement decisions. This precedent makes it exceptionally difficult to challenge a prosecutor's decision not to bring charges against a third party.
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