dna testing

Gutierrez v. Saenz

Issues

For Article III standing purposes, does Ruben Gutierrez have a redressable injury if it is not clear that a declaratory judgment in his favor would allow him to access the DNA evidence he seeks?

This case asks the Court to determine if Ruben Gutierrez has Article III standing to seek a declaratory judgment in federal court stating that Texas’ denial of access to DNA evidence violates his constitutional rights. Gutierrez contends that he has standing to seek this declaratory judgment because it would significantly increase the likelihood that the prosecutor would subsequently grant him access to the DNA evidence he seeks. Saenz contends that Gutierrez lacks standing because a declaratory judgment would not affect the state’s refusal to grant Gutierrez access to the DNA evidence. This case touches upon the role of the states and the federal government in protecting fundamental rights.

Questions as Framed for the Court by the Parties

Whether Article III standing requires a particularized determination of whether a specific state official will redress the plaintiff’s injury by following a favorable declaratory judgment.

Ruben Gutierrez was convicted of capital murder in 1999 for the murder of Escolastica Harrison and was sentenced to death in Texas state court. Gutierrez v. Saenz at 1. Harrison lived in a mobile-home park in Brownsville, Texas with her nephew, who was a friend of Gutierrez.

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Reed v. Goertz

Issues

Does the statute of limitations for a federal law allowing prisoners the right to challenge a state’s post-conviction DNA testing regime begin to run as soon as the state trial court denies DNA testing or at the end of the state-court litigation, including all appeals?

This case asks the Supreme Court to resolve a circuit split and decide when the statute of limitations for 42 U.S.C. § 1983 claims for post-conviction DNA testing begin to run. Rodney Reed argues that the statute of limitations for his § 1983 claim for DNA testing should begin after the Texas Court of Criminal Appeals denied rehearing because this is the point at which he exhausted his state court options. Bryan Goertz counters that the statute of limitations should begin after the trial court denied Reed’s DNA testing request because this is when Reed first became aware that his right to DNA testing was allegedly being violated. The outcome of this case has significant implications for federalism, inmate rights, and the accuracy of the justice system.

Questions as Framed for the Court by the Parties

Whether the statute of limitations for a 42 U.S.C. § 1983 claim seeking DNA testing of crime-scene evidence begins to run at the end of state-court litigation denying DNA testing, including any appeals (as the U.S. Court of Appeals for the 11th Circuit has held), or whether it begins to run at the moment the state trial court denies DNA testing, despite any subsequent appeal (as the U.S. Court of Appeals for the 5th Circuit, joining the U.S. Court of Appeals for the 7th Circuit, held below).

In 1996, 19-year-old Stacey Stites’ body was found on the side of a country road in Bastrop County, Texas. Reed v. Goertz, at 2. The medical examiner determined that Stites was strangled to death with her belt. Id.

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Skinner v. Switzer

Issues

Must a convicted capital murderer bring a federal habeas corpus claim in order to assert his due process right to access to DNA evidence, or may he bring his claim as a civil rights violation under 42 U.S.C. § 1983?

 

Florida convicted petitioner Henry Skinner of capital murder and sentenced him to death. Although Skinner admits that he was present at the scene of the murders, he maintains his innocence. Skinner now seeks access to biological evidence for DNA testing, which he claims will prove that he is innocent of the murders. After unsuccessfully filing two habeas corpus claims, Skinner filed a 42 U.S.C. § 1983 claim to attempt to gain access to the evidence. The Fifth Circuit denied Skinner’s motion to stay his execution, but Skinner appealed that decision and the Supreme Court agreed to hear Skinner’s case. The Court must now decide whether a demand for access to biological evidence may be brought under 42 U.S.C. § 1983, or whether the claim falls within the realm of habeas corpus law and was thus improperly filed. The Supreme Court’s decision will not only decide Skinner’s fate, but also clarify the scope and procedure of habeas corpus claims.

Questions as Framed for the Court by the Parties

May a convicted prisoner seeking access to biological evidence for DNA testing assert that claim in a civil rights action under 42 U.S.C. § 1983, or is such a claim cognizable only in a petition for writ of habeas corpus?

In 1995, Henry Skinner was convicted of murdering his girlfriend and her two sons in their Pampa, Texas home, and sentenced to death. See Brief for Petitioner, Henry W.

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Additional Resources

· Wex: Habeas Corpus

· Wex: Civil Rights

· Human Genome Project: DNA Forensics

· Fort Worth Star-Telegram, Dave Montgomery: U.S. Supreme Court to Hear Texas Death Row Inmate’s Case (May 24, 2010)

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