My suspicion is that anyone can be considered a "private citizen" in a certain context. Trump certainly thought he could throw away his notes while in office. W

My suspicion is that anyone can be considered a "private citizen" in a certain context. Trump certainly thought he could throw away his notes while in office. What do you want to bet that TX judges will recognize some county-registrar-who discovers-an-abortion's right to bring suit as an individual? At least when the state itself is officially bringing suit, there are a limited number of individuals who can decide to sue you. In reality, what will happen is that if the TX supreme court disallows an to state employee from participating in the suit, there will be a network of state employees who are able to inform others who are able to sue.