Reginald Chapman v Eileen O'Neill Burke, 25-1392
U.S. Court of Appeals, Seventh Circuit Civil Civil Rights and Section 1983
Holdings
- Seventh Circuit holds Rooker-Feldman does not bar § 1983 facial challenges to state DNA testing statutes, even after losing in state court
- A prosecutor's professed willingness to allow DNA testing does not defeat Article III standing when she still controls and withholds the evidence
- Useful for civil rights and post-conviction attorneys litigating § 1983 challenges to state DNA testing statutes or facing Rooker-Feldman/standing dismissals
Summary
Reginald Chapman filed a § 1983 suit against Cook County State's Attorney Eileen O'Neill Burke, facially challenging Illinois's post-conviction DNA testing statute (725 Ill. Comp. Stat. 5/116-3) after Illinois trial, appellate, and supreme courts rejected his motion for DNA testing under that statute. The district court dismissed for lack of subject matter jurisdiction under the Rooker-Feldman doctrine, and Chapman appealed while Burke cross-appealed on both Rooker-Feldman and standing grounds.
The Seventh Circuit reversed on both issues. On standing, the court held Chapman's injury—denial of access to DNA evidence—was fairly traceable to Burke's post-judgment refusal to release the evidence, even though she had earlier expressed willingness to agree to testing; allowing a prosecutor's stated agreement to defeat standing would improperly leave plaintiffs able to sue only judges, who enjoy absolute immunity. The court also criticized an improper post-argument submission by Burke's counsel raising a new justification inconsistent with oral argument. On Rooker-Feldman, applying the five-part test from Gilbank v. Wood County, the court held Chapman's claim was an independent facial constitutional challenge to the statute itself, not an invitation to review or reject the state court judgment—following Skinner v. Switzer and Reed v. Goertz, which permit such federal challenges even where the plaintiff lost under the same statute in state court and seeks identical relief.
The case is significant for attorneys litigating post-conviction DNA access claims and jurisdictional challenges: it clarifies that facial statutory challenges brought via § 1983 survive Rooker-Feldman despite adverse state court rulings, and that prosecutors cannot defeat standing merely by professing openness to relief while withholding evidence. The court remanded without addressing preclusion or the merits.
In short
A plaintiff has Article III standing to sue a prosecutor for denial of access to DNA evidence when the prosecutor controls and withholds the evidence, even if she earlier expressed willingness to allow testing.
Rooker-Feldman does not bar a § 1983 facial constitutional challenge to a state post-conviction DNA testing statute, even where the plaintiff previously lost under that statute in state court.
Challenging a state court's application of a statute is barred by Rooker-Feldman, but challenging the constitutionality of the statute itself is not.
A prosecutor's alternative justifications for denying evidence access (raised for the first time post-argument) do not defeat a plaintiff's standing to sue.
This summary was drafted by AI and verified against the slip opinion. It may contain errors and is not legal advice — always read the original before relying on it.