Background
An Illinois jury convicted Reginald Chapman in 1998 of murdering Angela Butler and their son, C.B. The prosecution introduced blood-spatter evidence from Chapman’s apartment that tested positive for Butler’s DNA, as well as eyewitness evidence and Chapman’s statement that police would find C.B.’s body where they found Butler’s. Other physical evidence—including a baseball bat, car-trunk weather stripping, cords, weights, and a pillowcase—was not DNA tested. Chapman was sentenced to death; his sentence was commuted to life imprisonment in 2003.
In 2014, Chapman sought testing under Illinois’s post-conviction DNA-testing statute, 725 Ill. Comp. Stat. 5/116-3. Although the prosecutor’s office later agreed to testing, the state trial court rejected the proposed agreement and sua sponte denied the motion, reasoning that the trial evidence was overwhelming and further testing would not change the result. Illinois appellate courts left that decision intact.
Chapman then brought this § 1983 action against Cook County State’s Attorney Eileen O’Neill Burke, facially challenging § 116-3 under the Due Process Clause and the Sixth Amendment. He sought declaratory and injunctive relief, including DNA testing. The district court dismissed for lack of jurisdiction under Rooker-Feldman. Chapman appealed, and Burke cross-appealed on standing.
The Court’s Holding
The Seventh Circuit reversed and remanded. Chapman had Article III standing because the alleged continued denial of access to evidence for DNA testing was a concrete injury, a favorable ruling could redress it, and his allegations fairly traced the denial to Burke, who allegedly controlled access to the evidence. Burke’s asserted willingness to permit testing did not defeat causation where Chapman alleged that she continued to deny access based on the challenged statute.
Rooker-Feldman did not bar jurisdiction. Chapman was not asking the federal court to review or overturn the Illinois court’s decision applying § 116-3 to his request. Instead, he asserted an independent facial constitutional challenge to the statute governing post-conviction DNA testing. Under Skinner v. Switzer and Reed v. Goertz, that claim remains cognizable under § 1983 even when the plaintiff previously sought, and was denied, DNA testing in state court.
The court did not decide whether Chapman’s claims are precluded or meritorious. Those issues, along with Burke’s Rule 12(b)(6) arguments, remain for the district court on remand.
Key Takeaways
- A prisoner may use § 1983 to facially challenge a state post-conviction DNA-testing statute after losing a state-court request for testing under that statute.
- Seeking DNA testing in federal court does not alone trigger Rooker-Feldman; the key question is whether the suit seeks review of the state judgment rather than challenges the governing law.
- A prosecutor’s claimed agreement that testing should occur does not necessarily eliminate standing when the prosecutor allegedly retains control over evidence and denies access to it.
Why It Matters
The decision applies the Supreme Court’s narrow view of Rooker-Feldman to post-conviction DNA cases. Federal district courts may hear independent constitutional challenges to state procedures even where state courts have already denied the same prisoner testing under those procedures.
The ruling is jurisdictional only. It preserves Chapman’s opportunity to litigate the constitutionality of Illinois’s statute, while leaving defenses such as preclusion and the merits for remand.