Clarke v. Holder, 767 F. Supp. 2d 106

petitioners seven former defendants in a hostage-taking case sought to dismiss the indictment and invalidate convictions by challenging Maharaj's naturalization status.
they requested the U.S. Attorney institute a § 1451(a) denaturalization proceeding and cancel Maharaj's certificate based on alleged fraud and concealment.
district court had previously stayed pending criminal proceedings; post-trial, the court now decides the mandamus motion.
petitioners argue § 1451(a) creates a nondiscretionary duty to initiate denaturalization proceedings; respondents argue prosecutorial discretion applies.
court grants respondents' motion to dismiss for lack of standing and failure to state a mandamus claim, concluding § 1451(a) does not impose a clear duty to act and there is no redressable injury.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether petitioners have Article III standing	Demerieux et al. contend their own convictions are injuries	Respondents contend injury is not redressable by mandamus	No Article III standing exists
Whether petitioners have prudential standing (zone of interests) under § 1451	petitioners fall within zone of interests to challenge denaturalization	statute does not create third-party rights	Petitioners lack prudential standing under § 1451
Whether § 1451(a) imposes a nondiscretionary duty to initiate revocation proceedings	§ 1451(a) creates a mandatory duty to act	Heckler v. Chaney preserves discretion; no clear duty	§ 1451(a) does not create a mandatory duty; mandamus unavailable

Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (standing elements)
Heckler v. Chaney, 470 U.S. 821 (1985) (presumption of nonreviewability for enforcement discretion)
Clarke v. Sec. Indus. Ass'n, 479 U.S. 388 (1987) (zone of interest; private rights not created by INA)
Fedorenko v. United States, 449 U.S. 490 (1981) (clear, unequivocal, and convincing standard for denaturalization)