Question juridique clé
Whether the complainant had standing to appeal the dismissal of the criminal proceedings
Solution extraite
No standing was shown because the complainant did not explain any civil claims arising from the alleged facts, and no such claims were evident.
Motifs extraits
Under Art. 81 para. 1 let. a and b ch. 5 LTF, a complainant must show that the challenged decision may affect civil claims. In a dismissal case, it is enough to plead such claims in the federal appeal, but the appellant still must identify them unless they are obvious. Here, the appellant made no such showing.