In re Criminal Complaint & Application for Arrest Warrant, 350 Conn. 633

Plaintiffs, three Bridgeport electors, filed applications for arrest warrants under Connecticut General Statutes § 9-368, alleging election law violations during the September 2023 Bridgeport Democratic mayoral primary.
The applications, based on video evidence, sought arrest of two individuals alleged to have deposited absentee ballots illegally.
The trial judge denied the applications, citing constitutional, statutory, and procedural concerns, including a lack of probable cause and improper bypassing of prosecutorial discretion.
Plaintiffs filed a writ of error seeking appellate review of the denial, claiming error in the judge's interpretation of § 9-368 and underlying constitutional questions.
The State argued for dismissal, asserting plaintiffs were not aggrieved parties (either classically or statutorily) and had no cognizable interest in prosecutorial actions regarding others.
The Supreme Court transferred the writ from the Appellate Court and ultimately dismissed the case, addressing standing and aggrievement rather than the statute's constitutionality.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Must plaintiffs show statutory aggrievement to bring a writ of error?	Phillips et al.: No, writ of error can be brought on common law aggrievement.	State: Legislature must expressly grant right to seek appellate review here.	No statutory aggrievement is required for writ of error.
Do electors have a specific, personal, legal interest in the prosecution/nonprosecution of alleged election violators?	Phillips et al.: Directly harmed as victims, thus aggrieved parties.	State: Private citizens lack judicially cognizable interest in prosecution.	Plaintiffs have no specific, personal, legal interest—no aggrievement.
Can denial of an arrest warrant application for alleged election law violation be appealed via writ of error?	Phillips et al.: Yes, court misapplied the law and denied statutory rights.	State: Denial does not confer appellate standing/aggrievement.	Denial does not yield appellate rights; writ of error dismissed.
Does § 9-368 create a right to appellate review if the judge denies issuance of a warrant?	Phillips et al.: Statute places them within zone of interest for review.	State: Statute only allows filing, not right to appeal denial.	No substantive entitlement to appellate review is created.

Linda R.S. v. Richard D., 410 U.S. 614 (U.S. 1973) (private citizens lack standing to seek prosecution of others)
Younger v. Harris, 401 U.S. 37 (U.S. 1971) (standing requires a personal stake in enforcement or threat thereof)
Briggs v. McWeeny, 260 Conn. 296 (Conn. 2002) (classical aggrievement requires a direct personal legal interest)
Monroe v. Horwitch, 215 Conn. 469 (Conn. 1990) (public at large lacks unique harm from government handling of complaints)
Lazar v. Ganim, 334 Conn. 73 (Conn. 2019) (zone of interest for statutory standing)
Massameno v. Statewide Grievance Committee, 234 Conn. 539 (Conn. 1995) (prosecutorial discretion central to criminal process)