Page 35 of 42 103 Minn. L. Rev. 844, *911 [*912] CONCLUSION All justice systems suffer from pockets of unjustified, even pernicious, underenforcement. All recognize that public prosecutors can be vulnerable to biases and institutional interests that distort enforcement decisions. Especially in recent decades, nearly all have adopted mechanisms to address those risks. Outside the United States, victim rights legislation has included provisions directed at unjustified decisions not to prosecute. In other common law countries and in Europe, most victims may now either seek independent review of prosecutors or initiate prosecutions on their own. Independent review keeps the safeguard against underenforcement in public hands while strengthening the principle that charging decisions should be nonpolitical and ministerial in nature. Victim rights reforms in general manifest a judgment that modern criminal justice had focused excessively on public interests and unduly neglected victims’ private interests in criminal prosecutions. Authorizing victims to challenge declination decisions extends this idea by recognizing victims’ private stake in those decisions and enabling victims to serve the public interest in preventing unjustified failures to prosecute. 737 Virtually all U.S. jurisdictions reject both of those strategies. 738 And rather than insulate their prosecutors from political [*913] influence, most states rely on electoral politics for oversight of prosecution practices. Instead, the U.S. model opts for duplicative federal-state jurisdiction against a background of politically attuned state prosecutors. Both this federalism model of redundant prosecutorial authority - which may be reduced this term by the Supreme Court's decision in Gamble - and the model of politically responsive prosecutors have proven effective at redressing some types of underenforcement. Both serve some victims’ interests without taking the form of victim rights. And both reflect a preference f