Reginald Chapman v. Eileen O'Neill Burke
CourtCourt of Appeals for the Seventh Circuit
Date FiledAugust 13, 2026
Docket25-1392
JudgePryor
StatusPublished
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Full Opinion
In the
United States Court of Appeals
For the Seventh Circuit
____________________
Nos. 25-1311 & 25-1392
REGINALD L. CHAPMAN,
Plaintiff-Appellant/Cross-Appellee,
v.
EILEEN O’NEILL BURKE,
Defendant-Appellee/Cross-Appellant.
____________________
Appeals from the United States District Court for the
Northern District of Illinois, Eastern Division.
No. 22-cv-5510 — Jeffrey I. Cummings, Judge.
____________________
ARGUED FEBRUARY 18, 2026 — DECIDED AUGUST 13, 2026
____________________
Before SCUDDER, JACKSON-AKIWUMI, and PRYOR, Circuit
Judges.
PRYOR, Circuit Judge. An Illinois state court jury convicted
Reginald Chapman of murdering Angela Butler and her son,
C.B. Years later, in Illinois state court, Chapman sought post-
conviction DNA testing of evidence law enforcement recov-
ered during its investigation. To do so, he filed suit under 725
Ill. Comp. Stat. 5/116-3, which provides the statutory frame-
work under Illinois law by which a person can seek post-
2 Nos. 25-1311 & 25-1392
conviction DNA testing of evidence. The Illinois state court
denied his motion, the state appellate court affirmed, and the
Illinois Supreme Court denied review.
Chapman then sued Eileen O’Neill Burke, the Cook
County State Attorney, in federal court, invoking 42 U.S.C.
§ 1983 to challenge the facial constitutionality of 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 district court dismissed Chapman’s complaint for
lack of subject matter jurisdiction on Rooker-Feldman grounds,
pursuant to Rule 12(b)(1) of the Federal Rules of Civil Proce-
dure. Rooker-Feldman, a narrow doctrine, reinforces the bed-
rock principle that Congress authorized only the Supreme
Court with appellate jurisdiction to review state court judg-
ments, divesting lower federal courts of subject matter juris-
diction over such cases. T.M. v. Univ. of Maryland Med. Sys.
Corp., 146 S. Ct. 1739, 1746–48 (2026).
Chapman appeals, arguing the district court erred in dis-
missing his complaint for lack of subject matter jurisdiction
under Rooker-Feldman. Burke cross-appeals. In addition to
contending Rooker-Feldman bars Chapman’s complaint, Burke
claims Chapman lacks standing to sue. Because Chapman has
standing and Rooker-Feldman does not prevent the district
court from exercising subject matter jurisdiction, we reverse.
I. BACKGROUND
A. Chapman’s Murder Convictions
Our account of the following facts draws from Chapman’s
second amended complaint in this federal lawsuit and the Il-
linois Supreme Court’s recitation of facts in its affirmance of
Nos. 25-1311 & 25-1392 3
Chapman’s convictions on direct review. See People v. Chap-
man, 743 N.E.2d 48 (Ill. 2000).
On September 4, 1994, law enforcement found Angela But-
ler dead, floating facedown in the Calumet River. When
found, her body was bloated, discolored, decomposing,
wrapped in an electrical cord, and attached to 75 pounds of
free weights. Eight days later, on September 12, 1994, they
found C.B.’s body, also wrapped in electrical cords and at-
tached to 40 pounds of free weights, in the same river. Law
enforcement’s search for the perpetrator led them to Chap-
man, a man Butler previously dated and who had fathered
C.B. After further investigation, the state charged Chapman
in Illinois state court with a variety of crimes, including, as
relevant here, two counts of first-degree murder for the
deaths of Angela and C.B.
In 1998, Chapman went to trial. The government argued
Chapman killed Butler and C.B. at his apartment because he
was jealous that Butler and C.B. were moving to Iowa so that
they could live with Butler’s new fiancé. After murdering
them, Chapman placed their bodies into the trunk of his car
and disposed of them in the river. As part of its case, the gov-
ernment introduced evidence recovered from Chapman’s
apartment that had blood spatters, which tested positive for
Butler’s DNA. Other physical evidence from Chapman’s
apartment, his car, and the crime scene were introduced but
not tested for DNA—including a baseball bat, a blood stain
on the weather stripping of the car’s trunk, the weights and
cords that were tied to the victims’ bodies, and a black pillow-
case recovered near C.B.’s body. Additionally, the govern-
ment presented eyewitness testimony placing Chapman with
Butler and C.B. immediately prior to their deaths and
4 Nos. 25-1311 & 25-1392
provided a confession from Chapman to a state prosecutor
that the police would find C.B.’s body in the same place they
found Butler’s body.
On March 18, 1998, the jury convicted Chapman of mur-
dering Butler and C.B., and he was sentenced to death, which
was later commuted to life in prison in 2003. Chapman main-
tains his innocence.
B. State Post-Conviction Proceedings
In October 2014, Chapman filed a motion in the Illinois
state court where he was convicted, seeking post-conviction
DNA testing of certain evidence law enforcement gathered
during their investigation, pursuant to § 116-3 of the Illinois
Code of Criminal Procedure. 725 ILL. COMP. STAT. 5/116-3. 1
Chapman argued for DNA testing of certain evidence that
had not been tested and more sophisticated DNA testing—
that was unavailable at the time of his trial—of previously
tested evidence. Chapman contended this DNA evidence
would establish his innocence. On September 19, 2018, the
county prosecutor’s office informed the Illinois state court
that it agreed to DNA testing and submitted to the court an
1
Section 116-3 permits an Illinois state court to issue an order for DNA
testing of evidence secured in relation to a prior criminal trial if: (1) the
evidence was not previously tested or the evidence can now be tested us-
ing methods “not scientifically available at the time of trial that provides
a reasonable likelihood of more probative results”; (2) the defendant has
made a prima facie case that identity was the issue in the trial resulting in
his conviction; and (3) the defendant has made a prima facie case that the
evidence to be tested has been subject to a chain of custody sufficient to
establish that it has not been substituted, tampered with, replaced, or al-
tered in any material aspect. 725 ILL. COMP. STAT. 5/116-3(a)(1)–(2), (b)(1)–
(2).
Nos. 25-1311 & 25-1392 5
agreed order to that effect. The state, in the alternative, ad-
vised the court that it could dismiss the petition sua sponte.
At the post-conviction proceeding on Chapman’s motion
for DNA testing, the Illinois state court refused to accept the
parties’ agreement and sua sponte dismissed Chapman’s
§ 116-3 motion, finding the evidence presented at trial was
“beyond overwhelming” and any further forensic testing
would not have changed the outcome of the trial. Chapman
appealed, and the state appellate court affirmed. On Septem-
ber 28, 2022, the Illinois Supreme Court denied Chapman’s
petition for leave to appeal.
C. Federal Court Proceedings
After the Illinois Supreme Court denied the motion, Chap-
man filed suit in federal district court against Burke, the Cook
County State’s Attorney who, as alleged, has “control over ac-
cess to the evidence” Chapman “seeks to test.” Chapman as-
serted that Illinois’s post-conviction DNA testing statute is
unconstitutional on its face. Chapman contended the statute
is ambiguous, arbitrary, and impossible to administer under
the Fourteenth Amendment and violates the Sixth Amend-
ment’s right to a jury trial. He sought a declaratory judgment
that 725 Ill. Comp. Stat. 5/116-3 is unconstitutional, an injunc-
tion against enforcement of the statute, a declaration that he
is entitled to DNA testing, and an order directing DNA test-
ing of certain evidence.
Burke moved to dismiss Chapman’s complaint under Fed-
eral Rule of Civil Procedure 12(b)(1) for lack of subject matter
6 Nos. 25-1311 & 25-1392
jurisdiction under the Rooker-Feldman doctrine. 2 In her view,
Chapman’s injury stemmed from the state court judgment
denying his motion for testing, and he was seeking to reverse
that judgment in an action before a lower federal court even
though only the Supreme Court has jurisdiction to do so.
Moreover, she claimed Chapman lacked standing to sue.
The district court dismissed Chapman’s complaint on
Rooker-Feldman grounds. See generally Gilbank v. Wood Cnty.
Dep’t of Hum. Servs., 111 F.4th 754 (7th Cir. 2024) (en banc). In
its view, Chapman was asking the court to nullify the Illinois
state court’s judgment on his post-conviction motion, which
it found Rooker-Feldman prohibited. While Chapman had not
requested the federal district court to reverse the state court
judgment, the district court concluded he was seeking the
same relief in federal court that the state court had denied—
an order directing DNA testing of the evidence. And granting
that relief would reverse the state court judgment, which
Rooker-Feldman barred. At bottom, the federal district court
decided “there [was] no way that Chapman can obtain the re-
lief he [sought] here without nullifying the state court judg-
ment.” Consequently, pursuant to Rooker-Feldman, it dis-
missed Chapman’s complaint for lack of subject matter juris-
diction.
The parties cross-appealed.
II. ANALYSIS
On appeal, Chapman argues the district court erred in dis-
missing his case on Rooker-Feldman grounds. Burke responds
2
Burke also moved to dismiss Chapman’s complaint for failure to state a
claim under Federal Rule of Civil Procedure 12(b)(6).
Nos. 25-1311 & 25-1392 7
that the district court correctly did so, but, in the alternative,
Burke also argues that Chapman lacks standing to sue.
We review dismissal of claims for lack of subject matter
jurisdiction on standing grounds de novo. Satanic Temple, Inc.
v. Rokita, 163 F.4th 1061, 1066 (7th Cir. 2026). The same is true
for Rooker-Feldman. Gilbank, 111 F.4th at 765.
A. Standing
Burke argues Chapman does not have standing to chal-
lenge the constitutionality of the Illinois post-conviction DNA
testing statute because she did not cause his injury. In Burke’s
view, her initial representation to the Illinois state court dur-
ing the post-conviction proceedings that she agreed to DNA
testing shows she did not cause Chapman’s injury. Thus, she
insists Chapman lacks standing because he sued the wrong
party.
“Individuals convicted of crimes in state court ‘have a lib-
erty interest in demonstrating [their] innocence with new ev-
idence under state law.’” Gutierrez v. Saenz, 606 U.S. 305, 314
(2025) (alteration in original) (quoting Dist. Atty’s Off. for Third
Jud. Dist. v. Osborne, 557 U.S. 52, 68 (2009)). “For that reason,
a state-created right to post[-]conviction procedures can, ‘in
some circumstances, beget yet other rights to procedures es-
sential to the realization of the parent right.’” Id. (quoting Os-
borne, 557 U.S. at 68). To that end, where state law permits
post-conviction testing of DNA evidence, an individual can
file suit in federal court under § 1983 “against a prosecutor
who refuse[s] ‘to release … biological evidence for testing’” if
he alleges the state law “unconstitutionally prevented him
from obtaining such testing.” Id. (second alteration in
8 Nos. 25-1311 & 25-1392
original) (first quoting Skinner v. Switzer, 562 U.S. 521, 530
(2011); and then quoting Skinner, 562 U.S. at 532).
To seek the withheld evidence, the individual, like all
other plaintiffs, must have standing. “Federal courts are
courts of limited subject matter jurisdiction, meaning we have
authority to hear cases only where authorized by statute and
permitted by the Constitution.” Satanic Temple, 163 F.4th at
1066. Article III of the Constitution requires a plaintiff to have
a personal stake in the litigation—“in other words, standing
to sue.” Id. If a party lacks standing, we lack power to hear the
case. Id. at 1066–67.
To establish standing, the plaintiff has the burden of estab-
lishing that he has (1) suffered an injury in fact that is con-
crete, particularized, and actual or imminent; (2) that is fairly
traceable to the challenged conduct of the defendant; and (3)
that is likely to be addressed by a favorable judicial decision.
Id. at 1067 (citing TransUnion LLC v. Ramirez, 594 U.S. 413, 423
(2021)). And he must support his standing “in the same way
as any other matter on which the plaintiff bears the burden of
proof, i.e., with the manner and degree of evidence required
at the successive stages of the litigation.” Id. (quoting Apex
Digit., Inc. v. Sears, Roebuck & Co., 572 F.3d 440, 444 (7th Cir.
2009)). While we recognize two types of standing challenges,
only one is relevant here. Id. at 1068. And that is “[a] facial
challenge,” which “asserts that a plaintiff fails to satisfy the
requirements of standing on the pleadings, even if the com-
plaint’s well-pleaded allegations are taken as true.” Id.
Burke does not argue Chapman’s complaint fails to meet
the injury-in-fact and redressability prongs of the standing in-
quiry—for good reason. The denial of Chapman’s request to
conduct DNA testing of evidence is sufficient to constitute an
Nos. 25-1311 & 25-1392 9
injury in fact. Reed v. Goertz, 598 U.S. 230, 234 (2023). And the
relief Chapman seeks “would redress that injury by ordering
a change in the legal status of the parties and eliminating” an
“unlawful justification for denying DNA testing.” Gutierrez,
606 U.S. at 315–16 (citation modified).
Instead, Burke contests Chapman’s ability to meet the re-
quirements of the second prong, typically referred to as cau-
sation. See TransUnion, 594 U.S. at 423. A “causal connection
between the injury and the conduct complained of” must exist
for a plaintiff to have standing. Lujan v. Defs. of Wildlife, 504
U.S. 555, 560 (1992). That means “the injury has to be ‘fairly
… trace[able] to the challenged action of the defendant, and
not … th[e] result [of] the independent action of some third
party not before the court.’” Id. (alterations in original) (quot-
ing Simon v. E. Kentucky Welfare Rts. Org., 426 U.S. 26, 41–42
(1976)). The causal chain cannot be too attenuated or rest on
conjecture. Dep’t of Educ. v. Brown, 600 U.S. 551, 567 (2023). But
“[s]tanding is not always lost when the causal connection is
weak, and a defendant’s action need not be ‘the very last step
in the chain of causation.’” Doe v. Holcomb, 883 F.3d 971, 978
(7th Cir. 2018) (internal citation omitted) (quoting Bennett v.
Spear, 520 U.S. 154, 168–69 (1997)).
A plaintiff challenging the constitutionality of a state’s
post-conviction DNA testing statute under § 1983 satisfies the
causation prong of standing where the “named defendant” is
“[t]he state prosecutor” who denies the plaintiff’s request for
DNA testing, “thereby caus[ing] [the plaintiff’s] injury.” Reed,
598 U.S. at 234; see also Gutierrez, 606 U.S. at 315. A plaintiff
seeking post-conviction DNA testing under § 1983, then, has
established causation where he sues the “prosecutor” whose
10 Nos. 25-1311 & 25-1392
“denial of his request for DNA testing deprive[s] him of his
liberty interests.” Gutierrez, 606 U.S. at 315 (citation modified).
Given these principles, Burke’s position that Chapman’s
injury is not fairly traceable to her fails. It is of no moment that
she supposedly agrees DNA testing of the evidence should
occur. The focus, instead, is whether she has “denied” Chap-
man “access to the evidence,” Reed, 598 U.S. at 234, or “his
request for DNA testing,” Gutierrez, 606 U.S. at 315. Despite
Burke’s purported willingness to have the evidence tested,
Chapman alleges that Burke “has control over access to the
evidence” he “seeks to test” and has denied access to test it
based on an allegedly unconstitutional statute. Put another
way, Burke can agree that the evidence should be tested but
still deny Chapman’s request to do so for one reason or an-
other. “That a prosecutor might eventually find another rea-
son, grounded in [state law] or elsewhere, to deny a prisoner’s
request for DNA testing,” however, “does not vitiate his
standing to argue that the cited reasons violated his rights un-
der the Due Process Clause.” Id. at 319. 3 Burke’s argument,
3
We pause to note that at oral argument when pressed about Burke’s rea-
son for not testing the evidence despite her supposed readiness to do so,
counsel offered nothing more than a verbal shrug. (Oral Argument at
11:00–22:16). Then, without an order from this Court, Burke’s counsel filed
a post-argument memorandum, explaining that the evidence is im-
pounded and can only be lifted by a judge’s order. As an initial matter,
counsel filed the memorandum under the guise of Federal Rule of Appel-
late Procedure 28(j), which provides that “[i]f pertinent and significant au-
thorities come to a party’s attention after the party’s brief has been filed—
or after oral argument but before decision—a party may” file citations to
the supplemental authority. Counsel has provided no reason why these
citations could not have been brought to his attention prior to oral argu-
ment. Rule 28(j) is not a mechanism by which a party can shore up her
position after oral argument once weaknesses in the case have been
Nos. 25-1311 & 25-1392 11
taken to its logical end, would leave Chapman with only the
state court to sue, which is cloaked in absolute immunity for
such judicial acts. Forrester v. White, 484 U.S. 219, 225–28
(1988). “Article III mandates no such result.” Accord Gutierrez,
606 U.S. at 321.
Taken together, as alleged, Chapman’s injury is fairly
traceable to Burke’s post-state-court-judgment refusal to turn-
over the evidence for DNA testing. That is enough to establish
causation for standing purposes here. Reed, 598 U.S. at 234;
Gutierrez, 606 U.S. at 314–16.
B. Rooker-Feldman
Next, the parties dispute whether the district court had
subject matter jurisdiction over Chapman’s claims on what
has become known as the Rooker-Feldman doctrine.
Under 28 U.S.C. § 1257(a), Congress vested the Supreme
Court with the power to review state court judgments. Gil-
bank, 111 F.4th at 765. “The Rooker-Feldman doctrine recog-
nizes that Congress has not authorize[d] ‘district courts to ex-
ercise appellate jurisdiction over state-court judgments.’” Id.
(alteration in original) (quoting Verizon Maryland, Inc. v. Pub.
Serv. Comm’n of Maryland, 535 U.S. 635, 644 n.3 (2002)). Ac-
cordingly, if the plaintiff’s alleged injury resulted from a state
exposed. Moreover, the Rule 28(j) memorandum here runs directly con-
trary to counsel’s position at oral argument that it would be legal for Burke
to test the evidence despite the state court judge’s denial of Chapman’s
motion under the terms of 725 Ill. Comp. Stat. 5/116-3. (Oral Argument at
22:05–22:16). In any event, as noted above, that a state prosecutor points
to another reason, like other state laws, for denying access to, or testing of,
the evidence, it does not defeat a plaintiff’s standing to challenge the con-
stitutionality of the state’s post-conviction DNA testing statute. Gutierrez,
606 U.S. at 319–20.
12 Nos. 25-1311 & 25-1392
court judgment, federal district courts lack subject matter ju-
risdiction “to reverse.” Gilbank, 111 F.4th at 792. That author-
ity lies only with the Supreme Court. Id. at 791–92. Named for
the duo of cases holding as such, the Rooker-Feldman doctrine
effectuates this statutory limitation on federal court jurisdic-
tion. See Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S.
280, 291 (2005).
By illustration, in Rooker v. Fidelity Trust Co., the plaintiff
commenced suit in federal district court seeking to have an
adverse state court judgment “declared null and void.” 263
U.S. 413, 414 (1923). And in District of Columbia Court of Ap-
peals v. Feldman, the plaintiffs litigated before and lost in the
D.C. Court of Appeals, the district’s equivalent to a state su-
preme court. 460 U.S. 462, 468–70 (1983). They then sued that
court in federal district court, seeking review of final judicial
determinations the D.C. Court of Appeals made. Id.; see also
Exxon, 544 U.S. at 285–86 (describing Feldman).
In both cases, the Supreme Court noted the parties’ federal
complaints, under the pretext of federal question jurisdiction,
“essentially invited federal courts of first instance to review
and reverse unfavorable state-court judgments.” Exxon, 544
U.S. at 283; see also id. at 291–92. Such suits are properly dis-
missed for want of subject matter jurisdiction because appel-
late jurisdiction to reverse or modify state court judgments is
lodged exclusively in the Supreme Court. Id. at 283–84. Con-
sequently, lower federal courts lack subject matter jurisdic-
tion over “cases brought by state-court losers complaining of
injuries caused by state-court judgments rendered before the
district court proceedings commenced and inviting district
court review and rejection of those judgments.” Id. at 284.
Nos. 25-1311 & 25-1392 13
This doctrine applies only in “limited circumstances.” Id.
at 291; Gilbank, 111 F.4th at 765 (citation modified). Narrow
application recognizes our “virtually unflagging obligation to
exercise the jurisdiction that Congress has granted” and en-
sures that issues are properly resolved under comity, absten-
tion, preclusion, or other grounds where at all possible. Gil-
bank, 111 F.4th at 765–66 (citation modified).
To strike the right balance, we have held that lower federal
courts lack subject matter jurisdiction where (1) a federal
plaintiff lost in state court; (2) the state court judgment has
become final before the federal proceedings began; (3) the
state court judgment caused the alleged injury underlying the
federal claim; (4) the claim must invite the federal district
court to review and reject the state court judgment; and (5) a
federal plaintiff had a reasonable opportunity to raise her fed-
eral issue in the state courts. Id. at 766. All prongs must be
satisfied to divest the federal district court of subject matter
jurisdiction. Id. at 792.
With respect to the third prong, jurisdiction is lacking only
“where … the state-court judgment itself caused the alleged
injury underlying the claim.” Id. at 766 (emphasis added). So,
jurisdiction exists when there is “an independent prior injury
that the state court failed to remedy.” Id. at 767 (quoting Sykes
v. Cook Cnty. Cir. Ct. Prob. Div., 837 F.3d 736, 742 (7th Cir.
2016)); see also Ghelf v. Town of Wheatland, 132 F.4th 456, 470
n.26 (7th Cir. 2025) (recognizing Rooker-Feldman does not bar
“claims” that “are independent of the state-court judgment”).
In other words, the doctrine does not apply “[i]f a federal
plaintiff ‘present[s] [an] independent claim,’” even if “the
‘same or related question’ was earlier aired between the
14 Nos. 25-1311 & 25-1392
parties in state court.” Skinner, 562 U.S. at 532 (second and
third alteration in original) (quoting Exxon, 544 U.S. at 292–
93).
As for the fourth prong, the inquiry turns on determining
whether the remedy sought invites the district court to review
and reject the state court judgment. Exxon, 544 U.S. at 284. We
focus “on what the plaintiff asks the federal court to do.” Gil-
bank, 111 F.4th at 792 (emphasis in original). Rooker-Feldman
may kick in when “the plaintiff asks a federal court to ‘over-
turn’ or ‘undo’ the state court judgment.” Id. (quoting Exxon,
544 U.S. at 287 n.2, 292–93). On the other hand, Rooker-Feldman
does not divest lower courts of subject matter jurisdiction
simply because a plaintiff’s requested remedy in federal court
is the same as what she sought in state court. Skinner, 562 U.S.
at 528, 534. It is only where, “given the relief sought, a plaintiff
… seek[s] to reverse a state court judgment” that Rooker-Feld-
man might apply. Gilbank, 111 F.4th at 793.
The Supreme Court has twice affirmed these principles in
§ 1983 cases like Chapman’s here. In Skinner, the plaintiff lost
his bid under the terms of a Texas statute to have DNA testing
done on evidence he claimed would exonerate him. 562 U.S.
at 528–29. Invoking § 1983, he then challenged the constitu-
tionality of the Texas statute in federal court. Id. at 529. Rooker-
Feldman posed no barrier because the plaintiff, in his federal
action, brought a claim independent of the state court judg-
ment. Id. at 532–53. That was true even though the plaintiff
requested “an order requiring DNA testing,” id. at 534, which
was the same relief he sought in Texas state court, id. at 528.
See also Huey v. Kunzweiler for Tulsa Cnty. State Att’y, 847 F.
App’x 530, 533 (10th Cir. 2021) (holding it did not “create a
Rooker-Feldman problem” in a plaintiff’s § 1983 suit
Nos. 25-1311 & 25-1392 15
challenging a state’s post-conviction DNA testing statute that
the plaintiff was “seeking the same relief through this federal
action that he was denied in state court”). Because the relief
the plaintiff requested in the federal action sought to remedy
a prior independent injury stemming from the allegedly un-
constitutional Texas statute—not the state court judgment
denying the plaintiff’s request under the terms of the stat-
ute—the action escaped Rooker-Feldman’s “shoal.” See Skinner,
562 U.S. at 531–32.
Likewise, in Reed, the plaintiff challenged Texas’s law on
accessing DNA evidence for post-conviction testing as uncon-
stitutional even though he had previously lost under the
Texas state court’s application of the statute to the facts of his
case. Reed, 598 U.S. at 233–34. The plaintiff did not argue he
was due relief under the Texas statute but, instead, “tar-
get[ed] as unconstitutional the Texas statute [the state court]
authoritatively construed.” Id. at 235 (quoting Skinner, 562
U.S. at 532). Thus, Rooker-Feldman did not hinder the lower
court’s subject matter jurisdiction over the plaintiff’s claims.
Id. Moreover, the majority concluded Rooker-Feldman was in-
applicable, id. at 234–35 (majority opinion), notwithstanding
the fact that the plaintiff had sought “the same relief” in his
§ 1983 action that he had previously sought in prior proceed-
ings, id. at 246 (Thomas, J., dissenting).
Putting the jurisprudential puzzle pieces together, Rooker-
Feldman does not bar a plaintiff from invoking § 1983 to chal-
lenge the constitutionality of a state’s post-conviction DNA
testing statute in federal court even if he previously lost his
bid to secure DNA testing under the statute’s terms in state
court. See Skinner 562 U.S. at 531–33; Reed, 598 U.S. at 234–35.
As the Supreme Court has explained, “a state-court decision
16 Nos. 25-1311 & 25-1392
is not reviewable by lower federal courts, but a statute or rule
governing the decision may be challenged in a federal action.”
Skinner 562 U.S. at 532. Because Chapman’s § 1983 action falls
within the latter category, Burke’s attempt to invoke the
Rooker-Feldman doctrine fails.
Chapman’s complaint is not a wolf in sheep’s clothing,
seeking to plead an independent constitutional claim but us-
ing it as a tool to seek review and reversal of the state court
judgment. Instead, the entire thrust of Chapman’s complaint
is that 725 Ill. Comp. Stat. 5/116-3 is unconstitutional. Chap-
man alleges Illinois’s post-conviction DNA testing statute “is
unconstitutionally vague, ambiguous, impossible to adminis-
ter, and deprived [him] of due process.” He also asserts § 116-
3’s “delegation of power to the trial judge, years after a jury
verdict, to divine ‘the’ basis for the jury’s verdict, is a depri-
vation of the defendant’s right to a jury trial under the Sixth
Amendment.” Various other paragraphs in his complaint
echo those allegations. At bottom, the allegations in Chap-
man’s complaint that challenge 725 Ill. Comp. Stat. 5/116-3 as
unconstitutional, coupled with the conspicuous omission of
allegations challenging the state court judgment, remove it
from Rooker-Feldman’s ambit. Like Skinner and Reed, Rooker-
Feldman does not divest the federal district court of subject
matter jurisdiction over Chapman’s complaint.
III. CONCLUSION
Chapman has standing to sue, and Rooker-Feldman poses
no obstacle to subject matter jurisdiction. 4 For the reasons
4
Burke argues that if we decide Chapman has standing and his claim is
not barred by Rooker-Feldman, we should find his case is precluded or oth-
erwise lacks merit. We decline both invitations. “Rooker-Feldman is not
Nos. 25-1311 & 25-1392 17
stated above, we REVERSE and REMAND for proceedings con-
sistent with this opinion.
simply preclusion by another name, and questions of preclusion unre-
solved below are best left for full airing and decision on remand.” Skinner,
562 U.S. at 533 n.11 (citation modified). And “[w]hether the case may ulti-
mately fail for other reasons” should be “for the district court to deter-
mine” on remand when we reverse a district court’s dismissal of a case on
Rooker-Feldman grounds. Andrade v. City of Hammond, 9 F.4th 947, 951 (7th
Cir. 2021).