Reginald Chapman v. Eileen O'Neill Burke

Court of Appeals for the Seventh Circuit·Decided August 13, 2026·No. 25-1392·Published·Pryor

Opinion

In the

United States Court of Appeals For the Seventh Circuit

Nos. 25-1311 & 25-1392 REGINALD L. CHAPMAN, Plaintiff-Appellant/Cross-Appellee, v.

EILEEN O’NEILL BURKE, Defendant-Appellee/Cross-Appellant.

Appeals from the United States District Court for the Northern District of Illinois, Eastern Division. No. 22-cv-5510 — Jeffrey I. Cummings, Judge.

ARGUED FEBRUARY 18, 2026 — DECIDED AUGUST 13, 2026

Before SCUDDER, JACKSON-AKIWUMI, and PRYOR, Circuit Judges.

PRYOR, Circuit Judge. An Illinois state court jury convicted Reginald Chapman of murdering Angela Butler and her son, C.B. Years later, in Illinois state court, Chapman sought post- conviction DNA testing of evidence law enforcement recovered during its investigation. To do so, he filed suit under 725 Ill. Comp. Stat. 5/116-3, which provides the statutory framework under Illinois law by which a person can seek post-

2 Nos. 25-1311 & 25-1392

conviction DNA testing of evidence. The Illinois state court denied his motion, the state appellate court affirmed, and the Illinois Supreme Court denied review.

Chapman then sued Eileen O’Neill Burke, the Cook County State Attorney, in federal court, invoking 42 U.S.C. § 1983 to challenge the facial constitutionality of 725 Ill. Comp. Stat. 5/116-3 under the Fourteenth Amendment’s Due Process Clause and the Sixth Amendment’s right to a jury trial. The district court dismissed Chapman’s complaint for lack of subject matter jurisdiction on Rooker-Feldman grounds, pursuant to Rule 12(b)(1) of the Federal Rules of Civil Procedure . Rooker-Feldman, a narrow doctrine, reinforces the bedrock principle that Congress authorized only the Supreme Court with appellate jurisdiction to review state court judgments , divesting lower federal courts of subject matter jurisdiction over such cases. T.M. v. Univ. of Maryland Med. Sys. Corp., 146 S. Ct. 1739, 1746–48 (2026).

Chapman appeals, arguing the district court erred in dismissing his complaint for lack of subject matter jurisdiction under Rooker-Feldman. Burke cross-appeals. In addition to contending Rooker-Feldman bars Chapman’s complaint, Burke claims Chapman lacks standing to sue. Because Chapman has standing and Rooker-Feldman does not prevent the district court from exercising subject matter jurisdiction, we reverse.

I. BACKGROUND

A. Chapman’s Murder Convictions Our account of the following facts draws from Chapman’s second amended complaint in this federal lawsuit and the Illinois Supreme Court’s recitation of facts in its affirmance of

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Chapman’s convictions on direct review. See People v. Chapman , 743 N.E.2d 48 (Ill. 2000).

On September 4, 1994, law enforcement found Angela Butler dead, floating facedown in the Calumet River. When found, her body was bloated, discolored, decomposing, wrapped in an electrical cord, and attached to 75 pounds of free weights. Eight days later, on September 12, 1994, they found C.B.’s body, also wrapped in electrical cords and attached to 40 pounds of free weights, in the same river. Law enforcement’s search for the perpetrator led them to Chapman , a man Butler previously dated and who had fathered C.B. After further investigation, the state charged Chapman in Illinois state court with a variety of crimes, including, as relevant here, two counts of first-degree murder for the deaths of Angela and C.B.

In 1998, Chapman went to trial. The government argued Chapman killed Butler and C.B. at his apartment because he was jealous that Butler and C.B. were moving to Iowa so that they could live with Butler’s new fiancé. After murdering them, Chapman placed their bodies into the trunk of his car and disposed of them in the river. As part of its case, the government introduced evidence recovered from Chapman’s apartment that had blood spatters, which tested positive for Butler’s DNA. Other physical evidence from Chapman’s apartment, his car, and the crime scene were introduced but not tested for DNA—including a baseball bat, a blood stain on the weather stripping of the car’s trunk, the weights and cords that were tied to the victims’ bodies, and a black pillowcase recovered near C.B.’s body. Additionally, the government presented eyewitness testimony placing Chapman with Butler and C.B. immediately prior to their deaths and 4 Nos. 25-1311 & 25-1392

provided a confession from Chapman to a state prosecutor that the police would find C.B.’s body in the same place they found Butler’s body.

On March 18, 1998, the jury convicted Chapman of murdering Butler and C.B., and he was sentenced to death, which was later commuted to life in prison in 2003. Chapman maintains his innocence.

B. State Post-Conviction Proceedings In October 2014, Chapman filed a motion in the Illinois state court where he was convicted, seeking post-conviction DNA testing of certain evidence law enforcement gathered during their investigation, pursuant to § 116-3 of the Illinois Code of Criminal Procedure. 725 ILL. COMP. STAT. 5/116-3. 1 Chapman argued for DNA testing of certain evidence that had not been tested and more sophisticated DNA testing— that was unavailable at the time of his trial—of previously tested evidence. Chapman contended this DNA evidence would establish his innocence. On September 19, 2018, the county prosecutor’s office informed the Illinois state court that it agreed to DNA testing and submitted to the court an

1 Section 116-3 permits an Illinois state court to issue an order for DNA testing of evidence secured in relation to a prior criminal trial if: (1) the evidence was not previously tested or the evidence can now be tested using methods “not scientifically available at the time of trial that provides a reasonable likelihood of more probative results”; (2) the defendant has made a prima facie case that identity was the issue in the trial resulting in his conviction; and (3) the defendant has made a prima facie case that the evidence to be tested has been subject to a chain of custody sufficient to establish that it has not been substituted, tampered with, replaced, or altered in any material aspect. 725 ILL. COMP. STAT. 5/116-3(a)(1)–(2), (b)(1)– (2).

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agreed order to that effect. The state, in the alternative, advised the court that it could dismiss the petition sua sponte.

At the post-conviction proceeding on Chapman’s motion for DNA testing, the Illinois state court refused to accept the parties’ agreement and sua sponte dismissed Chapman’s § 116-3 motion, finding the evidence presented at trial was “beyond overwhelming” and any further forensic testing would not have changed the outcome of the trial. Chapman appealed, and the state appellate court affirmed. On September 28, 2022, the Illinois Supreme Court denied Chapman’s petition for leave to appeal.

C. Federal Court Proceedings After the Illinois Supreme Court denied the motion, Chapman filed suit in federal district court against Burke, the Cook County State’s Attorney who, as alleged, has “control over access to the evidence” Chapman “seeks to test.” Chapman asserted that Illinois’s post-conviction DNA testing statute is unconstitutional on its face. Chapman contended the statute is ambiguous, arbitrary, and impossible to administer under the Fourteenth Amendment and violates the Sixth Amendment ’s right to a jury trial. He sought a declaratory judgment that 725 Ill. Comp. Stat. 5/116-3 is unconstitutional, an injunction against enforcement of the statute, a declaration that he is entitled to DNA testing, and an order directing DNA testing of certain evidence.

Burke moved to dismiss Chapman’s complaint under Federal Rule of Civil Procedure 12(b)(1) for lack of subject matter 6 Nos. 25-1311 & 25-1392

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