Case Explained: FinalOpinion in case# 25-1392

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’s post-conviction DNA testing statute, 725 Ill. Comp. Stat. 5/116-3. The court held that Chapman possesses Article III standing to sue the Cook County State’s Attorney because his injury—the denial of access to evidence for DNA testing—is fairly traceable to the prosecutor’s control over and refusal to release the evidence, regardless of whether the prosecutor personally agreed to testing. Furthermore, the court ruled that the Rooker-Feldman doctrine does not divest the federal district court of subject matter jurisdiction. Applying the standard established in *Skinner v. Switzer* and *Reed v. Goertz*, the court determined that Chapman’s claim is an independent constitutional challenge to the statute itself under the Fourteenth Amendment’s Due Process Clause and the Sixth Amendment’s right to a jury trial, rather than a suit inviting federal review of the state court’s judgment denying his specific motion. Consequently, the case was remanded for further proceedings consistent with this opinion, allowing Chapman’s facial constitutional challenge to proceed in federal court. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.