U.S. Court of Appeals for the Seventh Circuit

Reginald Chapman v. Eileen O'Neill Burke

August 13, 2026

Summary

The court held that Chapman has standing to challenge the constitutionality of Illinois's post-conviction DNA-testing statute because his alleged injury is fairly traceable to the prosecutor's control over and refusal to provide access to the evidence. It also held that Rooker-Feldman does not bar his federal constitutional challenge because the action targets the statute, not the state-court judgment, even though Chapman previously sought DNA testing in state court. The court reversed the jurisdictional dismissal and remanded for further proceedings.