Gutierrez v. Saenz, 145 S. Ct. 2258 (June 26, 2025) Sotomayor, J.
Justice Sotomayor delivered the opinion of the Court.
For nearly 15 years, petitioner Ruben Gutierrez has sought DNA testing of evidence that, he says, will help him prove he was never at the scene of the murder he was convicted of committing. When the local prosecutor refused to test the evidence in his custody, Gutierrez filed suit under Rev. Stat. §1979, 42 U. S. C. §1983, arguing that Texas’s procedures for obtaining DNA testing violated his rights under the Due Process Clause. The District Court agreed and granted a declaratory judgment to that effect.
The Fifth Circuit, however, held that Gutierrez lacked standing to bring his §1983 suit, reasoning that, even if a federal court declared Texas’s procedures unconstitutional, the local prosecutor would be unlikely to turn over the physical evidence for DNA testing. That holding contravenes Reed v. Goertz, 598 U.S. 230 (2023), where this Court decided on analogous facts that another Texas prisoner had standing to sue the local prosecutor who denied him access to DNA testing. Id., at 234. Put simply, Reed held that a federal court order declaring “that Texas’s post-conviction DNA testing procedures violate due process” would redress the prisoner’s claimed injury by “eliminat[ing]” the state prosecutor’s reliance on Article 64 as a reason for denying DNA testing. Ibid.; see Tex. Code Crim. Proc. Ann., Art. 64.01 (Vernon 2018). The same is true here and the Court therefore reverses.
Individuals convicted of crimes in state court “have a liberty interest in demonstrating [their] innocence with new evidence under state law.” District Attorney’s Office for Third Judicial Dist. v. Osborne, 557 U.S. 52, 68 (2009). For that reason, a state-created right to postconviction procedures can, “ ‘in some circumstances, beget yet other rights to procedures essential to the realization of the parent right.’ ” Ibid.[1] To that end, this Court held in Skinner v. Switzer, 562 U.S. 521 (2011), that a Texas prisoner could file a due process claim under §1983 against a prosecutor who refused “ ‘to release . . . biological evidence for testing.’ ” Id., at 530. In that case, Skinner had alleged that the prosecutor’s refusal to turn over evidence deprived him of “ ‘his liberty interests in utilizing state procedures to obtain reversal of his conviction and/or to obtain a pardon or reduction of his sentence.’ ” Ibid. This Court reasoned that, while Skinner could not challenge in federal court the TCCA decisions denying his Article 64 motions, he could allege in a §1983 action that Article 64 unconstitutionally prevented him from obtaining such testing. Id., at 532.
Skinner did not explicitly address a state prisoner’s standing to bring a due process claim against the custodian of his evidence. That question was first raised in Reed, where this Court confronted another claim that Texas’s postconviction DNA testing law failed to guarantee procedural due process. 598 U. S., at 233. Rodney Reed alleged, among other things, that Article 64’s “stringent chain-of-custody requirement was unconstitutional and in effect foreclosed DNA testing for individuals convicted before ‘rules governing the State’s handling and storage of evidence were put in place.’ ” Ibid. Before this Court, the local prosecutor argued that Reed lacked Article III standing. Specifically, the prosecutor asserted that a favorable court decision would not redress Reed’s injury. That was because, in the prosecutor’s view, a federal court’s “declaration that the statutory provision [he] attack[s] is unconstitutional” would not “likely” cause the district attorney to turn over the physical evidence in his possession. Brief for Respondents 38–39; Reed, 598 U.S. 230; California v. Texas, 593 U.S. 659, 673 (2021).
Gutierrez has standing to challenge Texas’s DNA testing procedures under the Due Process Clause. The judgment of the U. S. Court of Appeals for the Fifth Circuit is therefore reversed, and the case is remanded for further proceedings consistent with this opinion.
