Case Explained: FinalOpinion in case# 25-1311

Court: United States Court of Appeals for the Seventh Circuit Filed: 2026-08-13 The Seventh Circuit reversed the district court’s dismissal of Reginald Chapman’s § 1983 complaint challenging the facial constitutionality of Illinois post-conviction DNA testing statute 725 Ill. Comp. Stat. 5/116-3 under the Fourteenth Amendment’s Due Process Clause and the Sixth Amendment’s right to a jury trial. The court held that Chapman possesses Article III standing because his injury—the denial of access to evidence for DNA testing—is fairly traceable to the defendant, Cook County State’s Attorney Eileen O’Neill Burke, who controls the evidence and denied his request based on the challenged statute, regardless of her subsequent agreement to testing. Furthermore, the court ruled that the Rooker-Feldman doctrine does not divest the district court of subject matter jurisdiction because Chapman is not seeking to review or reverse the Illinois state court’s judgment denying his motion; rather, he is asserting an independent claim challenging the constitutionality of the underlying state statute itself. Consequently, the case was remanded to the district court for further proceedings consistent with this opinion, allowing the merits of the constitutional challenge to be addressed. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.