Skinner v. Switzer

Background

Henry Skinner is a Texas prisoner convicted of murder who asked for DNA testing of crime-scene evidence held by the prosecutor, Lynn Switzer. Some items were tested at trial but many biological items remained untested. Texas later enacted Article 64 to allow limited postconviction DNA testing; Skinner twice sought testing under that law and was denied. He then filed a federal civil-rights lawsuit claiming the state procedures, as interpreted by Texas courts, denied him procedural due process. Lower federal courts dismissed his suit as the sort of claim that must be brought only in habeas, and an appeals court affirmed.

Reasoning

The Court addressed whether a postconviction request for DNA testing must be pursued only in federal habeas or may be brought as a civil-rights suit. Relying on prior decisions that habeas is exclusive for claims that would necessarily speed release, the Court held that ordering DNA tests would not necessarily imply a conviction’s invalidity because results could be exculpatory, incriminating, or inconclusive. For that reason, a §1983 civil-rights action seeking testing is cognizable. The Court noted Osborne limits substantive due process claims in this area and left open the merits of Skinner’s procedural-due-process challenge.

Real world impact

The ruling lets convicted people ask federal civil courts for orders forcing testing of evidence held by prosecutors. It does not itself overturn convictions and the case was returned to lower courts for further review. Congress’s limits on prisoner suits remain in force and may constrain filings.

Dissents or concurrances

Justice Thomas, joined by Justices Kennedy and Alito, dissented, arguing such challenges to collateral review procedures belong in habeas and warning that allowing §1983 claims would undermine federalism and habeas rules.