Henry W. Skinner v. Lynn Switzer

Summary

The Supreme Court held that a state prisoner's postconviction claim for DNA testing of crime-scene evidence is properly brought under 42 U.S.C. § 1983 rather than exclusively in a habeas petition, because success would yield only access to the evidence—which may prove exculpatory, inculpatory, or inconclusive—and would not 'necessarily imply' the invalidity of the conviction. It further held that the Rooker-Feldman doctrine does not strip the district court of subject-matter jurisdiction, since Skinner challenges the Texas postconviction DNA statute as construed by the state courts rather than the state-court judgments themselves. The Court reversed the Fifth Circuit's dismissal and remanded, expressing no view on the ultimate merits of the due process claim, which Osborne severely limits. Justice Thomas, joined by Justices Kennedy and Alito, dissented, contending that due process challenges to state collateral review procedures are not cognizable under § 1983 and that the Fifth Circuit's judgment should have been affirmed.