Reed v. Goertz, 598 U.S. 230

Rodney Reed was convicted and sentenced to death for the 1996 murder of Stacey Stites; DNA at the scene matched Reed but his convictions and habeas petitions were unsuccessful.
In 2014 Reed filed a Texas Chapter 64 post‑conviction motion seeking DNA testing of many items (including the belt used to strangle Stites); the local prosecutor agreed to test some items but opposed most requests.
The state trial court denied Reed’s Chapter 64 motion (citing chain‑of‑custody problems and lack of a showing that exculpatory results would have prevented conviction); the Texas Court of Criminal Appeals (CCA) affirmed and denied rehearing.
Reed sued the Bastrop County district attorney under 42 U.S.C. § 1983, alleging Texas’s post‑conviction DNA‑testing statute (as interpreted) violated procedural due process by, e.g., imposing an unconstitutional chain‑of‑custody barrier.
The District Court dismissed and the Fifth Circuit held Reed’s § 1983 claim was time‑barred because the 2‑year limitations period began when the trial court denied the motion; the Supreme Court granted certiorari.
The Supreme Court reversed the Fifth Circuit, holding the § 1983 limitations period accrues when the state litigation ends (here, after the CCA denied rehearing) and rejecting Texas’s standing, sovereign‑immunity, and Rooker‑Feldman defenses to the suit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
When does the 2‑year statute of limitations for a § 1983 procedural‑due‑process challenge to a State’s post‑conviction DNA testing procedures begin to run?	Reed: accrual occurs when state‑court litigation is complete (after CCA denial of rehearing)	Texas: accrual occurred when the trial court denied the Chapter 64 motion	Court: accrual occurs when state litigation ends — here, on denial of rehearing by the CCA
Standing / redressability	Reed: denial of access to evidence by the prosecutor is a concrete, redressable injury	Texas: Reed lacks standing to sue the prosecutor	Court: Reed has standing; federal relief declaring the procedure unconstitutional would substantially increase likelihood of obtaining testing
State sovereign immunity / Ex parte Young	Reed: official‑capacity declaratory/injunctive relief against prosecutor is permissible	Texas: sovereign immunity bars suit	Court: Ex parte Young allows suits for declaratory or injunctive relief against state officers in official capacity
Rooker–Feldman jurisdictional bar	Reed: suit challenges the statute as authoritatively construed, not the state judgments themselves	Texas: federal courts are being used to review state‑court judgments	Court: Rooker–Feldman does not bar the § 1983 challenge; Skinner permits challenging a statute or rule governing state decisions

Utah v. Evans, 536 U.S. 452 (establishing redressability principles where relief depends partly on third‑party compliance)
Ex parte Young, 209 U.S. 123 (establishing exception to state sovereign immunity for prospective relief against state officers)
Rooker v. Fidelity Trust Co., 263 U.S. 413 (limiting federal courts to original jurisdiction and reserving appellate review of state judgments to the Supreme Court)
District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (defining limits on federal district court review of state‑court judgments)
Skinner v. Switzer, 562 U.S. 521 (permitting § 1983 challenge to state post‑conviction DNA procedures and clarifying Rooker–Feldman boundaries)
District Attorney’s Office for Third Judicial Dist. v. Osborne, 557 U.S. 52 (limiting federal remedies for DNA‑testing claims and discussing procedural avenues)
Zinermon v. Burch, 494 U.S. 113 (explaining when procedural‑due‑process claims are "complete")
Bay Area Laundry & Dry Cleaning Pension Trust Fund v. Ferbar Corp. of Cal., 522 U.S. 192 (statute‑of‑limitations accrual: claim accrues when plaintiff has a complete and present cause of action)
Wallace v. Kato, 549 U.S. 384 (accrual rules for § 1983 claims)