Leeke v. Timmerman - 454 U.S. 83, 102 S. Ct. 69 (1981)

Rule:

A private citizen has no judicially cognizable right to prevent state officials from presenting information, through intervention of the state solicitor, that will assist a magistrate in determining whether to issue an arrest warrant.

Facts:

South Carolina prison inmates who claimed that they had been unnecessarily beaten by prison guards during a prison uprising sought criminal arrest warrants against the guards from a state court magistrate. After the magistrate expressed his intent to issue the warrants, the state solicitor--as a result of a meeting with the legal advisor to the state's department of corrections, the prison warden, the county sheriff, and deputy attorney--wrote the magistrate a letter which requested that the warrants not be issued and stated that the solicitor intended to ask state officials to conduct an investigation concerning the charges made against the officers involved. The magistrate did not issue the warrants, and no investigation was conducted. Subsequently, the inmates filed suit in the United States District Court for the District of South Carolina contending, among other claims, that the state correctional officials had conspired in bad faith to block the issuance of the arrest warrants and thereby violated 42 USCS 1983 and 1985(3). The District Court ultimately concluded that the state correctional officials denied the inmates their right to a meaningful ability to set in motion the governmental machinery, because the officials' activity stopped the machinery unlawfully, not in a proper way, as for example, upon a valid determination of lack of probable cause, and the court awarded the inmates compensatory and punitive damages. The United States Court of Appeals for the Fourth Circuit affirmed, concluding that even though a private citizen lacked a judicially cognizable interest in the prosecution or non-prosecution of another, that did not foreclose the inmates' right to seek an arrest warrant. The Court granted a writ of certiorari. 

Issue:

Under the circumstances, did the inmates have the right to challenge the actions of the correctional officials and to consequently seek an arrest warrant against them?

Answer:

No.

Conclusion:

The Court reversed the judgment and ruled that its holding in Linda R. S. v. Richard D. controlled the disposition of the case. The threshold inquiry was whether the inmates had standing to challenge the actions of the correctional officials. The Court held that a private citizen had no judicially cognizable right to prevent state officials from presenting information, through intervention of the state solicitor, that would assist a magistrate in determining whether to issue an arrest warrant.