Federal 7th Circuit Court
Civil Court
Subject Matter Jurisdiction
Plaintiff, who was found guilty of murder, filed a lawsuit in federal court after his state action filed pursuant to 725 ILCS 5/116-3 in which he sought post-conviction DNA testing of evidence was denied. Defendant argued that the state statute was facially unconstitutional. The district court dismissed the complaint for lack of subject matter jurisdiction on Rooker-Feldman grounds. The Seventh Circuit reversed and remanded, finding that plaintiff had standing to bring the lawsuit and that the Rooker-Feldman doctrine did not prevent the district court from exercising subject matter jurisdiction over the federal lawsuit. (SCUDDER and JACKSON-AKIWUMI, concurring)