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Linda R. S. v. Richard D.
Citation: 410 U.S. 614Docket: No. 71-6078
Court: Supreme Court of the United States; March 5, 1973; Federal Supreme Court; Federal Appellate Court
Mr. Justice Marshall delivered the Court's opinion regarding an action brought by the mother of an illegitimate child, seeking to challenge the application of Art. 602 of the Texas Penal Code, which criminalizes the willful desertion or neglect of child support. The statute has been interpreted by Texas courts to apply only to the parents of legitimate children, exempting those of illegitimate children from support obligations. The appellant claimed that the local district attorney refused to enforce this law against the father of her child, Richard D., on the grounds that it did not apply to him. She argued that this interpretation creates unconstitutional discrimination against illegitimate children, violating the Equal Protection Clause of the Fourteenth Amendment. The Court affirmed the lower court's dismissal based on a lack of standing, emphasizing that the appellant must demonstrate a personal stake in the outcome to invoke judicial process. The critical threshold is whether the appellant's allegations present a “case or controversy” that ensures concrete adverseness necessary for the court to address the constitutional issues raised. Recent case law has broadened the understanding of what constitutes a sufficient personal stake for standing, yet the appellant must still meet this requirement before the merits of her claims can be considered. Broadening the categories of injury for standing does not eliminate the requirement that the party seeking review must demonstrate personal injury. Over the past decade, while standing laws have evolved, federal plaintiffs still need to allege a threatened or actual injury resulting from the challenged action to establish jurisdiction. In this case, the appellant failed to demonstrate a sufficient connection between her injury and the government action she disputes. Although she experienced injury due to the non-payment of support by her child's father, this alone does not satisfy the standing requirement. The appellant must show direct injury from the enforcement of the statute in question. The Texas statute in this case creates an offense with immediate penalties for non-support, rather than a civil contempt scenario, meaning that simply obtaining relief would not ensure her father’s compliance. The likelihood of future compliance from prosecution remains speculative. Previous court decisions confirm that a citizen cannot contest prosecutorial policies if they are not personally involved in the prosecution. While the appellant has a vested interest in her child’s support, there is insufficient evidence to link her interest directly to the enforcement of criminal laws. The District Court's decision to dismiss the case for lack of standing is therefore affirmed. The District Court examined a challenge to Article 4.02 of the Texas Family Code, which holds 'spouses' civilly liable for supporting their minor children. The petitioner contended that the statute violated equal protection by not imposing similar liabilities on parents of illegitimate children. However, the three-judge court determined that the challenge was improperly presented, as the appellant did not seek an injunction against any state official regarding the statute. Consequently, this aspect of the case was remanded to a single district judge. The court clarified that the petitioner’s claim concerning Article 4.02 was not currently under review. An affidavit from an assistant district attorney indicated that the state could not initiate prosecution due to case law interpreting Article 602 of the Penal Code as not applicable to fathers of illegitimate children. While Congress cannot grant federal courts jurisdiction to issue advisory opinions, it can establish statutes that create legal rights, which, if violated, can confer standing, even if no injury exists without the statute. The court noted that a party must demonstrate a personal stake in the matter to have standing. It emphasized that the appropriate party to challenge the constitutionality of Article 602 would be a parent of a legitimate child prosecuted under that statute, as they could argue that the law discriminates against them by not holding parents of illegitimate children liable. The court emphasized that its ruling on lack of standing does not reflect any opinion on the merits of the appellant’s claim.