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Page 9 of 42 103 Minn. L. Rev. 844, *858 to assess conduct as non-negligent rather than reckless. °° Yet even those relatively benign affinities can lead to sub-optimal enforcement policies that might benefit from redundant evaluation of charging decisions. B. Other Contributions to Underenforcement It is worth noting that prosecutors themselves might not share those biases so much as take account of them in a local community and jury pool. Expecting juries will be unreceptive to a case is one reason that some prosecutors cite for not charging in some cases. There is evidence for this with regard to hate [*859] crimes against LGBT victim groups, for example, *! and the difficulty prosecutors have faced in convicting police officer defendants is a well-recognized hurdle in police violence cases. *” The same considerations can cut against prosecutions when victims are undocumented immigrants, sex workers, prisoners, and suspects in custody. >? Redundant enforcement authority can do less to redress this barrier, although depending on its form, it is not powerless. A separate prosecuting authority might bring better investigation and fact development, or different jurisdictional rules that change the composition of jury venires. *4 Inadequate funding for criminal justice agencies can also play a role in aggravating areas of unjustified underenforcement. Lack of public resources is an accepted (and inevitable) justification for declining to prosecute in some cases where evidence is sufficient to prove guilt. °° But funding constraints are [*860] not an affirmative good on par with other policy-based, public- interest justifications for non-prosecution, such as judgments finding that civil, regulatory, or public-health remedies are preferable to criminal sanctions, or concluding that third-party harms outweigh prosecution's benefits. *° Resource constraints are a problem justice systems would like to minimize. Two of the three primary forms of enforcement redundancy do ex

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