Question juridique clé
Whether the appellant had standing to challenge the refusal to open criminal proceedings without asserted civil claims.
Solution extraite
The court left this question open because the complaint failed in any event on the merits and on the requirement to challenge all independent reasons of the lower court.
Motifs extraits
Where the challenged decision rests on two independent grounds, each must be shown to violate federal law; the appellant did not successfully attack the alternative reasoning.