Reed v. Goertz
995 F.3d 425
| 5th Cir. | 2021Background
- Rodney Reed was convicted of capital murder in 1998 after sperm found on the victim matched his DNA; he repeatedly pursued state and federal post-conviction relief.
- Reed sought post-conviction DNA testing under Texas Code of Criminal Procedure Chapter 64; the trial court denied the Chapter 64 motion in November 2014 and the Texas Court of Criminal Appeals affirmed.
- In August 2019 Reed filed a § 1983 action against Bastrop County DA Bryan Goertz (official capacity), challenging Chapter 64 as unconstitutional (facial and as-applied) and seeking prospective declaratory relief and access to evidence for DNA testing.
- The district court dismissed Reed’s amended complaint under Rule 12(b)(6); Reed appealed to the Fifth Circuit.
- The Fifth Circuit held it had jurisdiction (Rooker–Feldman inapplicable; Ex parte Young allowed prospective relief); but affirmed dismissal on the alternative ground that Reed’s § 1983 claims were time‑barred because they accrued when the trial court denied his Chapter 64 motion in November 2014, more than two years before his 2019 § 1983 filing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Applicability of Rooker–Feldman jurisdictional bar | Reed contends his § 1983 challenge targets the statute, not the state-court judgment, so federal court jurisdiction exists | Goertz argues Reed's suit effectively asks federal court to nullify the state-court denial of testing | Rooker–Feldman does not apply; Reed challenges Chapter 64 (Skinner principle) |
| Eleventh Amendment / Ex parte Young | Reed seeks prospective declaratory relief against the DA, so suit is permitted | Goertz contends Eleventh Amendment bars suit against state actor | Ex parte Young permits prospective declaratory relief against state official here |
| Prosecutorial absolute immunity | Reed seeks declaratory/prospective relief, not damages | Goertz argues prosecutorial immunity shields him | Absolute prosecutorial immunity does not bar declaratory/prospective § 1983 claims |
| Statute of limitations / accrual for § 1983 denial-of-access-to-evidence claim | Reed filed within reasonable time after exhausting state remedies | Goertz argues claim accrued when trial court denied Chapter 64 in Nov 2014, so Reed’s 2019 suit is time‑barred | Claim accrued when trial court denied Chapter 64 (Nov 2014); two-year limitations elapsed before 2019 filing, so claims are time‑barred |
Key Cases Cited
- Skinner v. Switzer, 562 U.S. 521 (a § 1983 challenge to a state's DNA-testing statute is not barred by Rooker–Feldman when it targets the statute rather than the state-court judgment)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (clarifies narrow scope of Rooker–Feldman)
- Lance v. Dennis, 546 U.S. 459 (Rooker–Feldman limits federal review of final state-court judgments)
- D.C. Court of Appeals v. Feldman, 460 U.S. 462 (foundation for Rooker–Feldman doctrina)
- Rooker v. Fidelity Trust Co., 263 U.S. 413 (original source of Rooker principle)
- Edwards v. Balisok, 520 U.S. 641 (§ 1983 contains no judicially imposed exhaustion requirement)
- Wallace v. Kato, 549 U.S. 384 (accrual principles: a cause of action is complete and present when injury occurs)
- Walker v. Epps, 550 F.3d 407 (§ 1983 borrows state limitations period; accrual principles)
- Russell v. Board of Trustees, 968 F.2d 489 (accrual when plaintiff knew or should have known of injury)