Skinner v. Switzer
2011 U.S. LEXIS 1905, 179 L. Ed. 2d 233, 131 S. Ct. 1289 (2011)
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Rule of Law:
A state prisoner's claim seeking post-conviction DNA testing of evidence is cognizable in a civil rights action under 42 U.S.C. § 1983 and is not required to be brought in a petition for a writ of habeas corpus.
Facts:
- In 1995, Henry Skinner was convicted of murdering his live-in girlfriend, Twila Busby, and her two sons.
- Skinner was present in the house at the time of the murders but claimed he was incapacitated by alcohol and codeine, rendering him physically unable to commit the crimes.
- Skinner identified Busby’s uncle, Robert Donnell, as a potential perpetrator.
- Police collected significant biological evidence from the crime scene, including an axe handle, knives, vaginal swabs from Busby, fingernail clippings, and hair samples.
- At trial, the State tested some evidence, such as blood on Skinner's clothing, which implicated him.
- However, several key items, including the knives, axe handle, and vaginal swabs, were not subjected to DNA testing.
- Skinner's trial counsel strategically chose not to request testing on the remaining evidence, fearing the results would further incriminate his client.
Procedural Posture:
- Henry Skinner was convicted of capital murder and sentenced to death in a Texas state trial court.
- The Texas Court of Criminal Appeals (CCA), the state's highest court for criminal matters, affirmed Skinner's conviction and sentence on direct appeal.
- Skinner twice moved for post-conviction DNA testing in state court under Texas's Article 64 statute; both motions were denied by the trial court, and those denials were affirmed by the CCA.
- Skinner then filed a lawsuit in the U.S. District Court for the Northern District of Texas against District Attorney Lynn Switzer under 42 U.S.C. § 1983, seeking access to the DNA evidence.
- The District Court dismissed Skinner's § 1983 complaint, holding that the claim could only be brought as a petition for a writ of habeas corpus.
- Skinner, as the appellant, appealed the dismissal to the U.S. Court of Appeals for the Fifth Circuit.
- The Fifth Circuit affirmed the District Court's dismissal, holding that circuit precedent barred such claims under § 1983.
- The U.S. Supreme Court granted Skinner's petition for a writ of certiorari to resolve a split among the circuit courts.
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Issue:
May a convicted state prisoner seeking post-conviction 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 only in a petition for a writ of habeas corpus?
Opinions:
Majority - Justice Ginsburg
Yes, a state prisoner may assert a claim for post-conviction DNA testing in a § 1983 civil rights action. A claim is properly brought under § 1983 when a favorable judgment would not necessarily imply the invalidity of the prisoner's conviction or sentence. Because success in a suit for DNA testing only grants the prisoner access to evidence—which could prove inculpatory, exculpatory, or inconclusive—it does not necessarily mean his conviction is unlawful. The court's precedents, particularly Wilkinson v. Dotson, establish that habeas corpus is the exclusive remedy only when a prisoner seeks immediate or speedier release from confinement. A request for DNA testing does not meet that standard. Furthermore, the Rooker-Feldman doctrine does not bar Skinner's suit because he is challenging the constitutionality of the state statute as construed, not appealing the state court's specific judgments against him.
Dissenting - Justice Thomas
No, a state prisoner may not assert a claim for post-conviction DNA testing in a § 1983 action, as such a claim sounds in habeas corpus. Challenges to state procedures for reviewing the validity of a conviction, including post-conviction collateral review statutes like Texas's Article 64, should be treated the same as challenges to trial procedures, which are not cognizable under § 1983. Allowing these claims under § 1983 would undermine the strict limitations Congress has placed on federal habeas review, such as exhaustion of state remedies and deferential review of state court decisions. This creates a loophole for prisoners to relitigate their claims and get a 'second bite at the apple' without adhering to established habeas procedures. The majority's reliance on Wilkinson v. Dotson is misplaced because parole procedures, unlike DNA testing, do not relate to the validity of the underlying conviction.
Analysis:
This decision clarifies the proper procedural channel for state prisoners seeking access to post-conviction DNA evidence. By affirming that § 1983 is an appropriate vehicle, the Court reinforced the 'necessarily implies' test from Heck v. Humphrey as the primary determinant for whether a claim belongs in a civil rights suit or a habeas petition. This provides a clearer, brighter line for lower courts. However, the Court also tempered this procedural victory by referencing its decision in District Attorney's Office v. Osborne, which significantly limits the substantive due process grounds for such claims, suggesting that while prisoners can now more easily file these lawsuits, their ultimate chances of success in compelling DNA testing remain slim.
