681 F. App'x 279
4th Cir.2017Background
- In 1998 Derek Stanton LaMar was convicted of rape in Prince William County, Virginia; he later sought post-conviction relief including DNA testing.
- Virginia enacted a DNA-testing statute in 2001 (Va. Code § 19.2‑327.1) authorizing testing if five statutory criteria are met and stating that proceedings under the statute "shall not form the basis for relief in any habeas corpus proceeding or any other appeal" (subsection (G)).
- LaMar filed four state petitions for DNA testing (2001, 2003, 2008, 2011) which were denied; a state court preserved evidence by injunction but refused testing relief that could be used in habeas or appeal.
- In 2012 LaMar sued Commonwealth’s Attorney Paul Ebert under 42 U.S.C. § 1983 alleging the DNA statute and Ebert’s refusal to permit testing violated his Fourteenth Amendment due process rights; he sought declaratory, injunctive, and monetary relief.
- The district court dismissed under 28 U.S.C. § 1915A, holding the Rooker‑Feldman doctrine barred the suit and, alternatively, that the complaint failed to state a claim because LaMar misread subsection (G).
- The Fourth Circuit vacated and remanded: it held LaMar had Article III standing, Rooker‑Feldman did not bar an attack on the statute’s constitutionality (following Skinner), and his pro se complaint plausibly stated an Osborne procedural‑due‑process claim and should not have been dismissed at screening.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing to sue prosecutor over denial of access to DNA testing | LaMar: statutory denial of testing and lack of avenue to obtain habeas/appeal injures his liberty interests and is redressable by court-ordered testing | Ebert: LaMar alleges no cognizable injury traceable to Ebert; Ebert is not the proper actor/custodian | Held: LaMar has Article III standing — injury, causation, and redressability adequately pleaded |
| Application of Rooker‑Feldman doctrine | LaMar: challenge targets constitutionality of the DNA statute, not the state court rulings | Ebert: federal suit would effectively nullify state court denials and thus is barred | Held: Rooker‑Feldman does not bar the suit; challenge to statute is an independent claim (Skinner controls) |
| Sufficiency of complaint under § 1915A (failure to state a claim) | LaMar: his pro se complaint alleges deprivation of state‑created testing procedures and inability to obtain habeas relief, raising an Osborne procedural‑due‑process claim | District court/Ebert: subsection (G) means statute does not bar habeas and complaint fails to show constitutional infirmity | Held: Complaint sufficiently alleges a procedural due process claim under Osborne; dismissal at screening was improper |
| Proper defendant for relief and immunity issues | LaMar: seeks injunctive relief against Ebert to obtain testing; damages claim barred by prosecutorial immunity | Ebert: improper defendant for constitutional challenge; entitled to absolute immunity for damages | Held: Immunity bars damages claims (district court previously addressed), but injunctive challenge against Ebert is cognizable and Ebert is a proper defendant for prospective relief |
Key Cases Cited
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (standing requires injury‑in‑fact, causation, redressability)
- Skinner v. Switzer, 562 U.S. 521 (2011) (distinguishing challenges to state‑court rulings from constitutional challenges to a state DNA‑testing statute)
- District Attorney’s Office v. Osborne, 557 U.S. 52 (2009) (recognition of limited state‑created liberty interest in post‑conviction DNA testing and due‑process framework)
- Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923) (origin of Rooker doctrine barring lower federal review of state judgments)
- District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983) (extension of Rooker doctrine to federal courts)