Page 23 of 42 103 Minn. L. Rev. 844, *889 authority developed as part of the modern model U.S. federalism has much in common, in functional terms, with private prosecution and review of prosecutorial declination decisions. All are mechanisms to guard against unjustified nonenforcement, or underenforcement, by jurisdictions' primary prosecution agencies. The next Part examines the relative strengths of these alternatives. IH. PROS AND CONS OF FEDERALISM-BASED ENFORCEMENT REDUNDANCY A. Comparative Limits of Enforcement-Oversight Strategies Each of the institutional approaches to reducing underenforcement of criminal law by public prosecutors has comparative strengths and weaknesses. All three share the common virtue of being a means to reduce instances of bias, favoritism, or other misjudgments that result in unjustified nonenforcement. All three enable outside reevaluation of declination decisions. Private prosecution empowers motivated private parties - crime victims - to initiate the challenge to a public prosecutor's decision not to charge by filing charges themselves. The same is true in jurisdictions that subject declination decisions to formal administrative or judicial review; victims trigger that process by petitioning for an independent evaluation. Both of those practices harness the motivations of interested private parties to, in effect, screen which declination decisions should be subject to reassessment, although private prosecution poses a significant cost barrier for victims who want to take advantage of it. At the same time, both of these practices give public officials the final [*890] word on whether a prosecution (public or private) will proceed. The federalism route to prosecutorial oversight, by contrast, gives private parties no formal role, although victims can file complaints and lobby federal prosecutors just as they can with local police and prosecutors for any alleged crime. Put differently, federal prosecution as check on state underenforc