Skinner v. Switzer
Annotate this Case
562 U.S. ___ (2011)
OCTOBER TERM, 2010
SKINNER V. SWITZER
SUPREME COURT OF THE UNITED STATES
SKINNER v. SWITZER, DISTRICT ATTORNEY FOR 31st JUDICIAL DISTRICT OF TEXAS
certiorari to the united states court of appeals for the fifth circuit
No. 09–9000. Argued October 13, 2010—Decided March 7, 2011
District Attorney’s Office for Third Judicial Dist. v. Osborne, 557 U. S. ___, ___, left unresolved the question whether a convicted state prisoner seeking DNA testing of crime-scene evidence may assert that claim in a civil rights action under 42 U. S. C. §1983 or may assert the claim in federal court only in a petition for a writ of habeas corpus under 28 U. S. C. §2254.
A Texas jury convicted petitioner Skinner and sentenced him to death for murdering his girlfriend and her sons. He claimed that a potent alcohol and drug mix rendered him physically unable to commit the brutal murders, and he identified his girlfriend’s uncle as the likely perpetrator. In preparation for trial, the State tested some of the physical evidence, but left untested several items, including knives found on the premises, an axe handle, vaginal swabs, fingernail clippings, and certain hair samples. More than six years later, Texas enacted Article 64, which allows prisoners to gain postconviction DNA testing in limited circumstances. Invoking Article 64, Skinner twice moved in state court for DNA testing of the untested biological evidence. Both motions were denied. The Texas Court of Criminal Appeals (CCA) affirmed the first denial of relief on the ground that Skinner had not shown, as required by Article 64.03(a)(2), that he “would not have been convicted if exculpatory results had been obtained through DNA testing.” The CCA affirmed the second denial of relief on the ground that Skinner had not shown, as required by Article 64.01(b)(1)(B), that the evidence was not previously tested “through no fault” on his part.
Skinner next filed the instant federal action for injunctive relief under §1983, naming as defendant respondent Switzer, the District Attorney who has custody of the evidence that Skinner would like to have tested. Skinner alleged that Texas violated his Fourteenth Amendment right to due process by refusing to provide for the DNA testing he requested. The Magistrate Judge recommended dismissal of the complaint for failure to state a claim, reasoning that postconviction requests for DNA evidence are cognizable only in habeas corpus, not under §1983. Adopting that recommendation, the District Court dismissed Skinner’s suit. The Fifth Circuit affirmed.
Held: There is federal-court subject-matter jurisdiction over Skinner’s complaint, and the claim he presses is cognizable under §1983. Pp. 7–15.
(a) Federal Rule of Civil Procedure 8(a)(2) generally requires only a plausible “short and plain” statement of the plaintiff’s claim, not an exposition of his legal argument. Skinner stated his due process claim in a paragraph alleging that the State’s refusal “to release the biological evidence for testing … 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 … .” His counsel has clarified that Skinner does not challenge the prosecutor’s conduct or the CCA’s decisions; instead, he challenges Texas’ postconviction DNA statute “as construed” by the Texas courts. Pp. 7–8.
(b) The Rooker-Feldman doctrine does not bar Skinner’s suit. This Court has applied the doctrine only in the two cases from which it takes its name, Rooker v. Fidelity Trust Co., 263 U. S. 413, District of Columbia Court of Appeals v. Feldman, 460 U. S. 462. See Exxon Mobil Corp. v. Saudi Basic Industries Corp., 544 U. S. 280. Given “the narrow ground” the doctrine occupies, id., at 284, the Court has confined Rooker-Feldman “to cases … brought by state-court losers … inviting district court review and rejection of [a state court’s] judgments.” Ibid. Skinner’s complaint encounters no Rooker-Feldman shoal. “If a federal plaintiff ‘present[s] [an] independent claim,’ ” it is not an impediment to the exercise of federal jurisdiction that the “same or a related question” was earlier aired between the parties in state court. Id., at 292–293. 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. See, e.g., Feldman, 460 U. S., at 487. Because Skinner’s federal case—which challenges not the adverse state-court decisions but the Texas statute they authoritatively construed—falls within the latter category, there was no lack of subject-matter jurisdiction over his federal suit. Pp. 8–10.
(c) Measured against this Court’s prior holdings, Skinner has properly invoked §1983. This Court has several times considered when a state prisoner, complaining of unconstitutional state action, may pursue a civil rights claim under §1983, and when habeas corpus is the prisoner’s sole remedy. The pathmarking decision, Heck v. Humphrey, 512 U. S. 477, concerned a state prisoner who brought a §1983 action for damages, alleging that he had been unlawfully investigated, arrested, tried, and convicted. This Court held that §1983 was not an available remedy because any award in the plaintiff’s favor would “necessarily imply” the invalidity of his conviction. See id., at 487. In contrast, in Wilkinson v. Dotson, 544 U. S. 74, the Court held that prisoners who challenged the constitutionality of administrative decisions denying them parole eligibility, could proceed under §1983, for they sought no “injunction ordering … immediate or speedier release into the community,” id., at 82, and “a favorable judgment [would] not ‘necessarily imply’ the invalidity of [their] conviction[s] or sentence[s],” ibid. Here, success in Skinner’s suit for DNA testing would not “necessarily imply” the invalidity of his conviction. Test results might prove exculpatory, but that outcome is hardly inevitable, for those results could also prove inconclusive or incriminating. Switzer argues that, although Skinner’s immediate aim is DNA testing, his ultimate aim is to use the test results as a platform for attacking his conviction. But she has found no case in which the Court has recognized habeas as the sole remedy where the relief sought would not terminate custody, accelerate the date of release, or reduce the custody level. Contrary to the fears of Switzer and her amici, in the Circuits that currently allow §1983 claims for DNA testing, there has been no flood of litigation seeking postconviction discovery of evidence associated with the questions of guilt or punishment. 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. More generally, in the Prison Litigation Reform Act of 1995, Congress has placed constraints on prisoner suits in order to prevent sportive federal-court filings. Nor is there cause for concern that the instant ruling will spill over to claims relying on Brady v. Maryland, 373 U. S. 83. Brady, which announced a constitutional requirement addressed to the prosecution’s conduct pretrial, proscribes withholding evidence “favorable to an accused” and “material to [his] guilt or to punishment.” Cone v. Bell, 556 U. S. ___, ___. Unlike DNA testing, which may yield exculpatory, incriminating, or inconclusive results, a successful Brady claim necessarily yields evidence undermining a conviction: Brady claims therefore rank within the traditional core of habeas corpus and outside the province of §1983. Pp. 10–14.
(d) Switzer’s several arguments why Skinner’s complaint should fail for lack of merit, unaddressed by the courts below, are ripe for consideration on remand. P. 14.
363 Fed. Appx. 302, reversed and remanded.
Ginsburg, J., delivered the opinion of the Court, in which Roberts, C. J., and Scalia, Breyer, Sotomayor, and Kagan, JJ., joined. Thomas, J., filed a dissenting opinion, in which Kennedy and Alito, JJ., joined.