Background
An Illinois jury convicted Reginald L. Chapman in 1998 of murdering Angela Butler and their son, C.B. His death sentence was later commuted to life imprisonment. Chapman maintains his innocence and sought DNA testing of evidence that had not been tested, as well as newer testing of evidence previously tested.
Chapman sought testing under Illinois’s post-conviction DNA-testing statute, 725 Ill. Comp. Stat. 5/116-3. Although the prosecutor’s office agreed to testing, the state trial court sua sponte denied the request, finding the trial evidence overwhelming. State appellate review ended when the Illinois Supreme Court denied leave to appeal. Chapman then brought this § 1983 action, facially challenging the statute under the Due Process Clause and Sixth Amendment. The district court dismissed under Rooker-Feldman.
The Court’s Holding
The Seventh Circuit reversed and remanded. Chapman had Article III standing because the alleged denial of access to evidence for DNA testing was a concrete injury, and his allegations that Cook County State’s Attorney Eileen O’Neill Burke controlled access to the evidence and refused testing sufficiently traced that injury to her. Her asserted willingness to test the evidence did not defeat standing.
Rooker-Feldman did not strip the district court of jurisdiction. Chapman challenged the constitutionality of the Illinois statute governing post-conviction DNA testing, rather than seeking appellate review of the state court’s decision applying that statute. Under Skinner v. Switzer and Reed v. Goertz, a § 1983 challenge to a DNA-testing statute remains an independent federal claim even if the plaintiff previously sought—and was denied—the same testing in state court.
Key Takeaways
- A prisoner may have standing to challenge a DNA-testing statute by suing the prosecutor alleged to control access to the evidence.
- Rooker-Feldman narrowly applies and does not bar an independent constitutional attack on the statute or rule governing a state-court decision.
- The Seventh Circuit did not decide preclusion, the merits of Chapman’s constitutional claims, or whether he is entitled to testing; those issues remain for the district court.
Why It Matters
The decision confirms that federal courts may hear § 1983 challenges to state post-conviction DNA-testing laws after an unsuccessful state-court testing request. The requested relief’s overlap with the relief denied in state court does not itself turn the federal case into an impermissible appeal of the state judgment.