McDermott Will & Schulte secures appellate victory in post-conviction DNA testing challenge

Global law firm McDermott Will & Schulte secured an important appellate victory for Reginald Chapman in the US Court of Appeals for the Seventh Circuit, which reversed the dismissal of his federal civil rights action and remanded the case for further proceedings. The ruling confirms that a federal court may hear an independent constitutional challenge to Illinois’ post-conviction DNA-testing statute even after the plaintiff was denied testing in state court.

Reginald, who maintains his innocence, sought DNA testing of previously untested evidence and more sophisticated testing of other evidence using methods unavailable at the time of his 1998 trial. Although the Cook County State’s Attorney’s Office initially agreed to testing, the Illinois trial court declined to accept the parties’ agreement and dismissed Reginald’s request. Reginald then filed a federal action under 42 U.S.C. § 1983, alleging that Illinois’ post-conviction DNA testing statute violates the Fourteenth Amendment’s Due Process Clause and the Sixth Amendment’s right to a jury trial. The district court dismissed the action for lack of subject-matter jurisdiction under Rooker-Feldman.

On appeal, the McDermott legal team successfully argued that Reginald had standing and that his lawsuit presented an independent constitutional challenge, rather than an improper appeal of the state court’s ruling. The Seventh Circuit agreed, holding that Rooker-Feldman did not prevent the district court from hearing his claims. The court reversed the dismissal and remanded the case, preserving Reginald’s opportunity to pursue access to DNA testing and litigate the merits of his constitutional challenge.

The decision removes the jurisdictional barrier that had prevented Reginald’s constitutional claims from being heard and allows the case to proceed in the district court. The Seventh Circuit ruling reinforces the narrow scope of the Rooker-Feldman doctrine and preserves a federal forum for constitutional challenges to state post-conviction procedures.

The McDermott legal team was led by William Schuman, with support from James Durkin, Emilie O’Toole, Kelsy Dorn, Gabrielle Siroonian, and Jane Kim.