Brief Fact Summary. A civil suit was filed against New York State officials and the local U.S. Attorney by a mother of a deceased former inmate and several other inmates of the New York’s Attica Correctional Facility, after the inmate uprising at the prison in 1971.
Synopsis of Rule of Law. Prosecutors cannot be compelled by the courts to investigate and initiate criminal prosecutions.
Issue. can prosecutors be compelled by the courts to investigate and initiate criminal prosecutions?
Held. (Mansfield, J.) No. Prosecutors cannot be compelled by the courts to investigate and initiate criminal prosecutions. Although federal mandamus lie only “to compel an officer or employee of the United States………to perform a duty owed to the plaintiff”, a prosecutor’s discretionary decision not to prosecute at the request of a private plaintiff have never been upturned by the federal courts. Also, statute that imposed a mandatory duty on the state officials to perform the desired prosecutions was not identified by the plaintiffs. The ruling of the trial court ruling was thereby sustained.
Discussion. rosecutorial discretion is held in high esteem and as such, it is deeply enshrined in American law largely for separation-of-powers considerations. With reference to the defendants in this case, the defendants were not “officer(s) or employee(s) of the United State,” as stipulated in the federal mandamus. The court dismissal against the state defendants would have been proper on the premise that federal courts meddles in state’s officials’ performance of discretionary duties. This would have grossly violated the most basic principles of federalism.