AI Case Brief
Generate an AI-powered case brief with:
Estimated cost: $0.001 - $0.003 per brief
Full Opinion
delivered the opinion of the Court.
We granted review in this case to decide a question presented, but left unresolved, in District Attorneyâs Office for Third Judicial Dist. v. Osborne, 557 U. S. 52, 65-67 (2009): May a convicted state prisoner seeking DNA testing of crime-scene evidence assert that claim in a civil rights action under 42 U. S. C. § 1983, or is such a claim cognizable in federal court only when asserted in a petition for a writ of ha-beas corpus under 28 U. S. C. § 2254? The Courts of Appeals have returned diverse responses. Compare McKithen v. Brown, 481 F. 3d 89, 99 (CA2 2007) (claim seeking DNA testing is cognizable under § 1983); Savory v. Lyons, 469 F. 3d 667, 669 (CA7 2006) (same); and Bradley v. Pryor, 305 F. 3d 1287, 1290-1291 (CA11 2002) (same), with Harvey v. Horan, 278 F. 3d 370, 375 (CA4 2002) (claim is not cognizable under
In Wilkinson v. Dotson, 544 U. S. 74 (2005), we comprehensively surveyed this Courtâs decisions on the respective provinces of § 1983 civil rights actions and §2254 federal ha-beas petitions. Habeas is the exclusive remedy, we reaffirmed, for the prisoner who seeks âimmediate or speedier releaseâ from confinement. Id., at 82. Where the prisonerâs claim would not ânecessarily spell speedier release,â however, suit may be brought under § 1983. Ibid. Adhering to our opinion in Dotson, we hold that a postconviction claim for DNA testing is properly pursued in a § 1983 action. Success in the suit gains for the prisoner only access to the DNA evidence, which may prove exculpatory, inculpatory, or inconclusive. In no event will a judgment that simply orders DNA tests ânecessarily impl[y] the unlawfulness of the Stateâs custody.â Id., at 81. We note, however, that the Courtâs decision in Osborne severely limits the federal action a state prisoner may bring for DNA testing. Osborne rejected the extension of substantive due process to this area, 557 U. S., at 72, and left slim room for the prisoner to show that the governing state law denies him procedural due process, see id., at 71.
I
In 1995, a Texas jury convicted petitioner Henry Skinner and sentenced him to death for murdering his live-in girlfriend, Twila Busby, and her two sons. Busby was bludgeoned and choked with an axe handle and her sons were stabbed to death; the murders were committed in the house Busby shared with Skinner.
Skinner never denied his presence in the house when the killings occurred. He claimed, however, that he was incapacitated by large quantities of alcohol and codeine. The potent alcohol and drug mix, Skinner maintained at trial, rendered him physically unable to commit the brutal murders charged against him. Skinner identified, as a likely
âAs they approached the house . . ., the police noticed a trail of blood spots on the ground running from the front porch to the fence line. There was a blood smear on the glass storm door and a knife on the front porch. Upon entering the residence, the police found Twilaâs dead body on the living room floor.... An ax handle stained with blood and hair was leaning against the couch near her body and a black plastic trash bag containing a knife and a towel with wet brownish stains on it was laying between the couch and the coffee table.
â[One officer] proceeded to the bedroom where [Busbyâs two sons] usually slept in bunk beds. [The officer] found [one] dead body laying face down on the upper bunk, covered by a blood spotted blanket. ... A door leading out of the bedroom and into a utility room yielded further evidence. [He] noticed a bloody hand-print located about 24 inches off the floor on the frame of this door. He also noted a bloody handprint on the door knob of the door leading from the kitchen to the utility room and a handprint on the knob of the door exiting from the utility room into the backyard.
â[When] police arrested [Skinner]... [t]hey found him standing in a closet wearing blood-stained socks and blood-stained blue jeans.â Id., at 536.
In preparation for trial, âthe State tested the blood on [Skinnerâs] clothing, blood and hair from a blanket that partially covered one of the victims, and hairs on one of the victimâs back and cheeks.â Skinner v. State, 122 S. W. 3d 808, 810 (Tex. Crim. App. 2003). The State also tested fingerprint evidence. Some of this evidence â including bloody palm prints in the room where one victim was killed â implicated Skinner, but âfingerprints on a bag containing one of the knivesâ did not. Ibid. Items left untested included the knives found on the premises, the axe handle, vaginal swabs, fingernail clippings, and additional hair samples. See ibid.
In the decade following his conviction, Skinner unsuccessfully sought state and federal postconviction relief. See Skinner v. Quarterman, 576 F. 3d 214 (CA5 2009), cert. denied, 559 U. S. 975 (2010). He also pursued informal efforts to gain access to untested biological evidence the police had collected at the scene of the crime.
In 2001, more than six years after Skinnerâs conviction, Texas enacted Article 64, a statute allowing prisoners to gain postconviction DNA testing in limited circumstances. Tex. Code Crim. Proc. Ann., Art. 64.01(a) (Vernon Supp. 2010). To obtain DNA testing under Article 64, a prisoner must meet one of two threshold criteria. He may show that, at trial, testing either was ânot availableâ or was âavailable, but
Invoking Article 64, Skinner twice moved in state court, first in 2001 and again in 2007, for DNA testing of yet untested biological evidence. See supra, at 527, n. 3. Both motions were denied. Affirming the denial of Skinnerâs first motion, the CCA held that he had failed to demonstrate a âreasonable probability . . . that he would not have been .. . convicted if the DNA test results were exculpatory.â Skinner v. State, 122 S. W. 3d, at 813.
Skinnerâs second motion was bolstered by discovery he had obtained in the interim.
Skinner next filed the instant federal action for injunctive relief under §1983, naming as defendant respondent Lynn Switzer, the District Attorney whose office prosecuted Skinner and has custody of the evidence Skinner would like to have DNA tested. Skinnerâs federal-court complaint alleged that Texas violated his Fourteenth Amendment right to due process by refusing to provide for the DNA testing he requested. Complaint ¶ 33, App. 20-21. The Magistrate Judge recommended dismissal of the complaint for failure to state a claim upon which relief can be granted. App. 24-41. Under the governing Circuit precedent, Kutzner v. Montgomery County, 303 F. 3d 339, the Magistrate Judge observed, postconviction requests for DNA evidence are cognizable only in habeas corpus, not under §1983. App. 39. Adopting the Magistrate Judgeâs recommendation, the District Court dismissed Skinnerâs suit. Id., at 44-45.
On appeal, the United States Court of Appeals for the Fifth Circuit affirmed, 363 Fed. Appx. 302 (2010) (per curiam), reiterating that âan action by a prisoner for post-conviction DNA testing is not cognizable under § 1983 and must instead be brought as a petition for writ of habeas corpus,â id., at 303. On Skinnerâs petition,
II
A
Because this case was resolved on a motion to dismiss for failure to state a claim, the question below was ânot whether
Skinner stated his due process claim in a paragraph alleging that the Stateâs refusal âto release the biological evidence for testing . . . has deprived [him] of his liberty interests in utilizing state procedures to obtain reversal of his conviction and/or to obtain a pardon or reduction of his sentence . ...â Complaint ¶33, App. 20-21. As earlier recounted, see supra, at 528-529, Skinner had twice requested and failed to obtain DNA testing under the only state-law procedure then available to him. See Complaint ¶¶ 22-31, App. 14-20.
B
Respondent Switzer asserts that Skinnerâs challenge is â[j]urisdictionally [bjarredâ by what has come to be known as the Rooker-Feldman doctrine. Brief for Respondent 48-49 (boldface deleted). In line with the courts below, we conclude that Rooker-Feldman does not bar Skinnerâs suit.
As we explained in Exxon Mobil Corp. v. Saudi Basic Industries Corp., 544 U. S. 280 (2005), the Rooker-Feldman doctrine has been applied by this Court only twice, i. e., only in the two cases from which the doctrine takes its name: first, Rooker v. Fidelity Trust Co., 263 U. S. 413 (1923), then 60 years later, District of Columbia Court of Appeals v. Feldman, 460 U. S. 462 (1983). Both cases fit this pattern: The losing party in state court
We observed in Exxon that the Rooker-Feldman doctrine had been construed by some federal courts âto extend far beyond the contours of the Rooker and Feldman cases.â 544 U. S., at 283. Emphasizing âthe narrow groundâ occupied by the doctrine, id., at 284, we clarified in Exxon that Rooker-Feldman âis confined to cases of the kind from which the doctrine acquired its name: eases brought by state-court losers .. . inviting district court review and rejection of [the state courtâs] judgments,â 544 U. S., at 284.
Skinnerâs litigation, in light of Exxon, encounters no Rooker-Feldman shoal. âIf a federal plaintiff âpresents] [an] independent claim,â â it is not an impediment to the exercise of federal jurisdiction that the âsame or a related questionâ was earlier aired between the parties in state court. 544 U. S., at 292-293 (quoting GASH Assocs. v. Rosemont, 995 F. 2d 726, 728 (CA7 1993); first alteration in original); see In re Smith, 349 Fed. Appx. 12, 18 (CA6 2009) (Sutton, J., concurring in part and dissenting in part) (a defendantâs federal challenge to the adequacy of state-law procedures for postconviction DNA testing is not within the âlimited graspâ of Rooker-Feldman).
As earlier noted, see supra, at 530, Skinner does not challenge the adverse CCA decisions themselves; instead, he targets as unconstitutional the Texas statute they authoritatively construed. As the Court explained in Feldman, 460 U. S., at 487, and reiterated in Exxon, 544 U. S., at 286, a state-court decision is not reviewable by lower federal courts, but a statute or rule governing the decision may be challenged in a federal action.
C
When may a state prisoner, complaining of unconstitutional state action, pursue a civil rights claim under § 1983, and when is habeas corpus the prisonerâs sole remedy? This Court has several times considered that question. Path-marking here is Heck v. Humphrey, 512 U. S. 477 (1994). The plaintiff in that litigation was a state prisoner serving time for manslaughter. He brought a § 1983 action for damages, alleging that he had been unlawfully investigated, arrested, tried, and convicted. Although the complaint in Heck sought monetary damages only, not release from confinement, we ruled that the plaintiff could not proceed under § 1983. Any award in his favor, we observed, would ânecessarily implyâ the invalidity of his conviction. See id., at 487. When âa judgment in favor of the plaintiff would necessarily imply the invalidity of his conviction or sentence,â the Court held, § 1983 is not an available remedy. Ibid. âBut if . . . the plaintiffâs action, even if successful, will not demonstrate the invalidity of [his conviction or sentence], the [§ 1983] action should be allowed to proceed .. ..â Ibid.
We summarized the relevant case law most recently in Wilkinson v. Dotson, 544 U. S. 74 (2005). That case involved prisoners who challenged the constitutionality of administrative decisions denying them parole eligibility. They could proceed under § 1983, the Court held, for they sought no âinjunction ordering . . . immediate or speedier release into the community,â id., at 82, and âa favorable judgment
Measured against our prior holdings, Skinner has properly invoked § 1983. Success in his suit for DNA testing would not ânecessarily implyâ the invalidity of his conviction. While test results might prove exculpatory, that outcome is hardly inevitable; as earlier observed, see supra, at 525, results might prove inconclusive or they might further incriminate Skinner. See Nelson v. Campbell, 541 U. S. 637, 647 (2004) (â[W]e were careful in Heck to stress the importance of the term ânecessarily.ââ).
Respondent Switzer nevertheless argues, in line with Fifth Circuit precedent, see Kutzner, 303 F. 3d, at 341, that Skinnerâs request for DNA testing must be pursued, if at all, in an application for habeas corpus, not in a § 1983 action. The dissent echoes Switzerâs argument. See post, at 539. Although Skinnerâs immediate plea is simply for an order requiring DNA testing, his ultimate aim, Switzer urges, is to use the test results as a platform for attacking his conviction. It suffices to point out that Switzer has found no case, nor has the dissent, in which the Court has recognized habeas as the sole remedy, or even an available one, where the relief sought would âneither terminat[e] custody, aecelerat[e] the future date of release from custody, nor reduc[e] the level of custody.â Dotson, 544 U. S., at 86 (Scalia, J., concurring).
Respondent Switzer and her amici forecast that a âvast expansion of federal jurisdiction . . . would ensueâ were we to hold that Skinnerâs complaint can be initiated under §1983. See Brief for National District Attorneys Association as Amicus Curiae 8. In particular, they predict a proliferation of federal civil actions âseeking postconviction discovery of evidence [and] other relief inescapably associ
In the Circuits that currently allow § 1983 claims for DNA testing, see supra, at 524, no evidence tendered by Switzer shows any litigation flood or even rainfall. The projected toll on federal courts is all the more implausible regarding DNA testing claims, for Osborne has rejected substantive due process as a basis for such claims. See supra, at 525.
More generally, in the Prison Litigation Reform Act of 1995 (PLRA), 110 Stat. 1321-66, Congress has placed a series of controls on prisoner suits, constraints designed to prevent sportive filings in federal court. See, e.g., PLRA § 803(d) (adding 42 U. S. C. § 1997e to create new procedures and penalties for prisoner lawsuits under § 1983); PLRA § 804(a)(3) (adding 28 U. S. C. § 1915(b)(1) to require any prisoner proceeding in forma pauperis to pay the full filing fee out of a percentage of his prison trust account); PLRA § 804(c)(3) (adding 28 U. S. C. § 1915(f) to require prisoners to pay the full amount of any cost assessed against them out of their prison trust account); PLRA § 804(d) (adding 28 U. S. C. § 1915(g) to revoke, with limited exception, in forma pau-peris privileges for any prisoner who has filed three or more
Nor do we see any cause for concern that todayâs ruling will spill over to claims relying on Brady v. Maryland, 373 U. S. 83 (1963); indeed, Switzer makes no such assertion. Brady announced a constitutional requirement addressed first and foremost to the prosecutionâs conduct pretrial. Brady proscribes withholding evidence âfavorable to an accusedâ and âmaterial to [his] guilt or to punishment.â Cone v. Bell, 556 U. S. 449, 451 (2009). To establish that a Brady violation undermines a conviction, a convicted defendant must make each of three showings: (1) the evidence at issue is âfavorable to the accused, either because it is exculpatory, or because it is impeachingâ; (2) the State suppressed the evidence, âeither willfully or inadvertentlyâ; and (3) âprejudice . . . ensued.â Strickler v. Greene, 527 U. S. 263, 281-282 (1999); see Banks v. Dretke, 540 U. S. 668, 691 (2004).
Unlike DNA testing, which may yield exculpatory, incriminating, or inconclusive results, a Brady claim, when successful postconviction, necessarily yields evidence undermining a conviction: Brady evidence is, by definition, always favorable to the defendant and material to his guilt or punishment. See Strickler, 527 U. S., at 296. And parties asserting Brady violations postconviction generally do seek a judgment qualifying them for âimmediate or speedier releaseâ from imprisonment. See Dotson, 544 U. S., at 82. Accordingly, Brady claims have ranked within the traditional core of habeas corpus and outside the province of § 1983. See Heck, 512 U. S., at 479, 490 (claim that prosecutors and an investigator had â âknowingly destroyedâ evidence âwhich was exculpatory in nature and could have proved [petitionerâs] innocenceâ â cannot be maintained under § 1983); Amaker v.
Ill
Finally, Switzer presents several reasons why Skinnerâs complaint should fail for lack of merit. Those arguments, unaddressed by the courts below, are ripe for consideration on remand. â[M]indful that we are a court of review, not of first view,â Cutter v. Wilkinson, 544 U. S. 709, 718, n. 7 (2005), we confine this opinion to the matter on which we granted certiorari and express no opinion on the ultimate disposition of Skinnerâs federal action.
* * *
For the reasons stated, the judgment of the Court of Appeals for the Fifth Circuit is reversed, and the case is remanded for further proceedings consistent with this opinion.
It is so ordered.
At trial, a defense witness testified that, on the evening of the killings, Busby had spurned Donnellâs ârude sexual advances.â Skinner v. State, 956 S. W. 2d 532, 535 (Tex. Crim. App. 1997). A neighbor related at a federal posteonviction hearing that she observed Donnell, a day or two after the murders, thoroughly cleaning the carpets and inside of his pickup truck. See Skinner v. Quarterman, 528 F. 3d 336, 345 (CA5 2008).
After Skinnerâs conviction, the State performed DNA tests on certain additional materials, but Skinner took no part in the selection of those materials or their testing. Skinner maintains that these ex parte tests were inconclusive. See Complaint ¶ 19, App. 12 (this âtesting raised more questions than it answeredâ). But see Skinner v. State, 122 S. W. 3d 808, 811 (Tex. Crim. App. 2003) (some findings were âinculpatoryâ).
Skinnerâs trial counsel, although aware that biological evidence remained untested, did not request further testing. Postconviction, Skinner sought DNA testing of vaginal swabs and fingernail clippings taken from Busby, blood and hairs on a jacket found next to Busbyâs body, and biological material on knives and a dish towel recovered at the crime scene. Complaint ¶ 22, App. 14-15.
On the basis of discovery in a federal postconviction proceeding, an expert retained by Skinner concluded that Skinner, Busby, and her two sons could be excluded as sources of a hair collected from Busbyâs right hand after the killings. See Record 190. See also Complaint ¶27, App. 18.
The District Attorney, in response to Skinnerâs second motion, informed the Texas District Court that â[t]o the best of the Stateâs information, knowledge, and belief, the items sought to be tested are still available for testing, the chain of custody is intact, and the items are in a condition to be tested although the State has not sought expert opinion in that regard.â Record 202. See also Complaint ¶ 29, App. 19.
The State of Texas scheduled Skinnerâs execution for March 24, 2010. We granted Skinnerâs application to stay his execution until further action of this Court. 559 U. S. 1033 (2010).
He also persistently sought the Stateâs voluntary testing of the materials he identified. See Complaint ¶ 31, App. 20.
Unlike the respondent in District Attorneyâs Office for Third Judicial Dist. v. Osborne, 557 U. S. 52 (2009), who âattempt[ed] to sidestep state
The judgment assailed in Feldman was rendered by the District of Columbia Court of Appeals, equivalent for this purpose to a Stateâs highest court.
The Court further observed in Exxon Mobil Corp. v. Saudi Basic Industries Corp., 544 U. S. 280, 292-293 (2005), that â[w]hen there is parallel state and federal litigation,â state preclusion law may become decisive, but â[plreclusion ... is not a jurisdictional matter.â
Switzer asserts that Skinner could have raised his federal claim in the Article 64 proceeding. See Tr. of Oral Arg. 48. Even if that were so, âRooker-Feldman is not simply preclusion by another name,â Lance v. Dennis, 546 U. S. 459, 466 (2006) (per curiam), and questions of preclusion unresolved below are âbest left for full airing and decision on remand,â id., at 467 (Ginsburg, J., concurring).
The dissent would muddle the clear line Heck and Dotson drew, and instead would instruct district courts to resort to âfirst principlesâ each time a state prisoner files a § 1983 claim in federal court. Post, at 538, 543.
Unlike the parole determinations at issue in Wilkinson v. Dotson, 544 U. S. 74 (2005), Switzer urges, claims like Skinnerâs require inquiry into the Stateâs proof at trial and therefore lie at âthe core of the criminal proceeding itself.â Tr. of Oral Arg. 41; see id., at 33-34. Dotson declared, however, in no uncertain terms, that when a prisonerâs claim would not ânecessarily spell speedier release,â that claim does not lie at âthe core of habeas corpus,â and may be brought, if at all, under § 1983. 544 U. S., at 82 (majority opinion) (internal quotation marks omitted); see id., at 85-86 (Scalia, J., concurring). Whatever might be said of Switzerâs argument were we to recast our doctrine, Switzerâs position cannot be reconciled with the line our precedent currently draws. Nor can the dissentâs advocacy of a âretur[n] to first principles.â Post, at 543. Given the importance of providing clear guidance to the lower courts, âwe [again] see no reason for moving the line [our] cases draw.â Dotson, 544 U. S., at 84.