What is the test for standing to appeal a finding that a party who is not a party to a criminal prosecution has been injured in a motor vehicle accident?

MultiRegion, United States of America

The following excerpt is from United States v. Kovall, 857 F.3d 1060 (9th Cir. 2017):

In order to meet the "irreducible constitutional minimum of standing," three elements must be met: (1) a party must have suffered an "injury in fact," which is an actual or imminent invasion of a legally protected, concrete, and particularized interest, (2) "there must be a causal connection between the injury and the conduct complained of," and (3) it must be likely that the injury will be redressable by a favorable decision. Lujan v. Defs. of Wildlife , 504 U.S. 555, 56061, 112 S.Ct. 2130, 119 L.Ed.2d 351 (1992).

The general rule is that non-parties to a criminal prosecution have no standing to appeal the judgment. See Diamond v. Charles , 476 U.S. 54, 56, 106 S.Ct. 1697, 90 L.Ed.2d 48 (1986) ("Because a private party whose own conduct is neither implicated nor threatened by a criminal

[857 F.3d 1066]

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