U.S. Supreme Court 03-07-11
by: Abassos • March 6, 2011 • no comments
Read the full article for details about the following new cases:
- Post-Conviction Access to DNA Evidence
Rejoice all ye nerds!!! A potentially useful new post-conviction nugget was handed down by the SCOTUS today. In its opinion in Skinner v. Switzer, the Court held that federal courts possesses subject matter jurisdiction over civil rights claims brought under 42 U.S.C. § 1983 for the purpose of seeking access to DNA evidence. In explaining this conclusion, the Court reasoned that
"[a]s the Court explained in Feldman, 460 U. S., at 487, and reiterated in Exxon, 544 U. S., at 286, 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. Skinner's federal case falls within the latter category. There was, therefore, no lack of subject-matter jurisdiction over Skinner's federal suit."
Id. at 10 (footnotes omitted).
The Court further explained that a prisoner properly invokes § 1983-rather than habeas corpus-when seeking only access to DNA evidence that may have a bearing on guilt or innocence because that remedy is wholly distinct from claims such as Brady violations. The opponent to DNA access argued that
"[a]lthough Skinner's immediate plea is simply for an order requiring DNA testing, his ultimate aim is to use the test results as a platform for attacking his conviction."
In rejecting this as a basis for denying relief, the Court brushes aside the perceived overlap with Brady claims and simply notes that the opponent's argument is telling: An order for DNA does not seek an "immediate or speedier" release from custody, while any potential Brady claim does. Thus, § 1983 is the proper avenue to pursue.
Be wary, though, as the Court does include this important caveat to its decision, which has the effect of severely narrowing the class of claims over which federal jurisdiction properly extends:
"We note, however, that the Court's decision in Osborne severely limits the federal action a state prisoner may bring for DNA testing. Osborne rejected the extension of substantive due process to this area and left slim room for the prisoner to show that the governing state law denies him procedural due process."
