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 postconviction 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- Page 2conviction 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.

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 Page 3Chapman’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 Page 4provided 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.

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 Page 5agreed 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.

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 Page 6jurisdiction under the Rooker -Feldman doctrine.² In her view, Chapman's injury stemmed from the state court judgment denying his motion for testing, and he was seeking to reverse that judgment in an action before a lower federal court even though only the Supreme Court has jurisdiction to do so. Moreover, she claimed Chapman lacked standing to sue.

The district court dismissed Chapman's complaint on Rooker -Feldman grounds. See generally Gilbank v. Wood Cnty. Dep't of Hum. Servs. , 111 F.4th 754 (7th Cir. 2024) (en banc). In its view, Chapman was asking the court to nullify the Illinois state court’s judgment on his post-conviction motion, which it found Rooker -Feldman prohibited. While Chapman had not requested the federal district court to reverse the state court judgment, the district court concluded he was seeking the same relief in federal court that the state court had denied— an order directing DNA testing of the evidence. And granting that relief would reverse the state court judgment, which Rooker-Feldman barred. At bottom, the federal district court decided “there [was] no way that Chapman can obtain the relief he [sought] here without nullifying the state court judgment.' Consequently, pursuant to Rooker -Feldman , it dismissed Chapman’s complaint for lack of subject matter jurisdiction.

The parties cross-appealed.

On appeal, Chapman argues the district court erred in dismissing his case on Rooker -Feldman grounds. Burke responds Page 7that the district court correctly did so, but, in the alternative, Burke also argues that Chapman lacks standing to sue.

We review dismissal of claims for lack of subject matter jurisdiction on standing grounds de novo. Satanic Temple, Inc. v. Rokita , 163 F.4th 1061, 1066 (7th Cir. 2026). The same is true for Rooker -Feldman . Gilbank , 111 F.4th at 765.

Burke argues Chapman does not have standing to challenge the constitutionality of the Illinois post-conviction DNA testing statute because she did not cause his injury. In Burke’s view, her initial representation to the Illinois state court during the post-conviction proceedings that she agreed to DNA testing shows she did not cause Chapman’s injury. Thus, she insists Chapman lacks standing because he sued the wrong party.

“Individuals convicted of crimes in state court ‘have a liberty interest in demonstrating [their] innocence with new evidence under state law.’” Gutierrez v. Saenz , 606 U.S. 305, 314 (2025) (alteration in original) (quoting Dist. Atty’s Off. for Third Jud. Dist. v. Osborne , 557 U.S. 52, 68 (2009)). “For that reason, a state-created right to post[-]conviction procedures can, ‘in some circumstances, beget yet other rights to procedures essential to the realization of the parent right.'' Id. (quoting Osborne , 557 U.S. at 68). To that end, where state law permits post-conviction testing of DNA evidence, an individual can file suit in federal court under § 1983 'against a prosecutor who refuse[s] ‘to release … biological evidence for testing’” if he alleges the state law 'unconstitutionally prevented him from obtaining such testing.” Id. (second alteration in Page 8original) (first quoting Skinner v. Switzer , 562 U.S. 521, 530 (2011); and then quoting Skinner , 562 U.S. at 532).

To seek the withheld evidence, the individual, like all other plaintiffs, must have standing. 'Federal courts are courts of limited subject matter jurisdiction, meaning we have authority to hear cases only where authorized by statute and permitted by the Constitution.” Satanic Temple , 163 F.4th at 1066. Article III of the Constitution requires a plaintiff to have a personal stake in the litigation—“in other words, standing to sue.' Id. If a party lacks standing, we lack power to hear the case. Id. at 1066–67.

To establish standing, the plaintiff has the burden of establishing that he has (1) suffered an injury in fact that is concrete, particularized, and actual or imminent; (2) that is fairly traceable to the challenged conduct of the defendant; and (3) that is likely to be addressed by a favorable judicial decision. Id. at 1067 (citing TransUnion LLC v. Ramirez , 594 U.S. 413, 423 (2021)). And he must support his standing “in the same way as any other matter on which the plaintiff bears the burden of proof, i.e. , with the manner and degree of evidence required at the successive stages of the litigation.' Id. (quoting Apex Digit., Inc. v. Sears, Roebuck & Co. , 572 F.3d 440, 444 (7th Cir. 2009)). While we recognize two types of standing challenges, only one is relevant here. Id. at 1068. And that is '[a] facial challenge,” which “asserts that a plaintiff fails to satisfy the requirements of standing on the pleadings, even if the complaint’s well-pleaded allegations are taken as true.” Id.

Burke does not argue Chapman’s complaint fails to meet the injury-in-fact and redressability prongs of the standing inquiry—for good reason. The denial of Chapman’s request to conduct DNA testing of evidence is sufficient to constitute an Page 9injury in fact. Reed v. Goertz , 598 U.S. 230, 234 (2023). And the relief Chapman seeks “would redress that injury by ordering a change in the legal status of the parties and eliminating” an “unlawful justification for denying DNA testing.” Gutierrez , 606 U.S. at 315–16 (citation modified).

Instead, Burke contests Chapman’s ability to meet the requirements of the second prong, typically referred to as causation. See TransUnion , 594 U.S. at 423. A “causal connection between the injury and the conduct complained of” must exist for a plaintiff to have standing. Lujan v. Defs. of Wildlife , 504 U.S. 555, 560 (1992). That means “the injury has to be ‘fairly … trace[able] to the challenged action of the defendant, and not … th[e] result [of] the independent action of some third party not before the court.’” Id. (alterations in original) (quoting Simon v. E. Kentucky Welfare Rts. Org. , 426 U.S. 26, 41–42 (1976)). The causal chain cannot be too attenuated or rest on conjecture. Dep’t of Educ. v. Brown , 600 U.S. 551, 567 (2023). But “[s]tanding is not always lost when the causal connection is weak, and a defendant’s action need not be ‘the very last step in the chain of causation.’” Doe v. Holcomb , 883 F.3d 971, 978 (7th Cir. 2018) (internal citation omitted) (quoting Bennett v. Spear , 520 U.S. 154, 168–69 (1997)).

A plaintiff challenging the constitutionality of a state's post-conviction DNA testing statute under § 1983 satisfies the causation prong of standing where the “named defendant” is “[t]he state prosecutor” who denies the plaintiff’s request for DNA testing, 'thereby caus[ing] [the plaintiff's] injury.' Reed , 598 U.S. at 234; see also Gutierrez , 606 U.S. at 315. A plaintiff seeking post-conviction DNA testing under § 1983, then, has established causation where he sues the “prosecutor” whosePage 10 “denial of his request for DNA testing deprive[s] him of his liberty interests.” Gutierrez , 606 U.S. at 315 (citation modified).

Given these principles, Burke’s position that Chapman’s injury is not fairly traceable to her fails. It is of no moment that she supposedly agrees DNA testing of the evidence should occur. The focus, instead, is whether she has “denied” Chapman “access to the evidence,” Reed , 598 U.S. at 234, or 'his request for DNA testing,” Gutierrez , 606 U.S. at 315. Despite Burke's purported willingness to have the evidence tested, Chapman alleges that Burke “has control over access to the evidence” he “seeks to test” and has denied access to test it based on an allegedly unconstitutional statute. Put another way, Burke can agree that the evidence should be tested but still deny Chapman's request to do so for one reason or another. “That a prosecutor might eventually find another reason, grounded in [state law] or elsewhere, to deny a prisoner’s request for DNA testing,' however, 'does not vitiate his standing to argue that the cited reasons violated his rights under the Due Process Clause.” Id. at 319.³ Burke's argument, Page 11taken to its logical end, would leave Chapman with only the state court to sue, which is cloaked in absolute immunity for such judicial acts. Forrester v. White , 484 U.S. 219, 225-28 (1988). 'Article III mandates no such result.' Accord Gutierrez , 606 U.S. at 321.

Taken together, as alleged, Chapman's injury is fairly traceable to Burke’s post-state-court-judgment refusal to turnover the evidence for DNA testing. That is enough to establish causation for standing purposes here. Reed , 598 U.S. at 234; Gutierrez , 606 U.S. at 314–16.

Next, the parties dispute whether the district court had subject matter jurisdiction over Chapman's claims on what has become known as the Rooker -Feldman doctrine.

Under 28 U.S.C. § 1257(a), Congress vested the Supreme Court with the power to review state court judgments. Gilbank , 111 F.4th at 765. 'The Rooker -Feldman doctrine recognizes that Congress has not authorize[d] ‘district courts to exercise appellate jurisdiction over state-court judgments.’” Id. (alteration in original) (quoting Verizon Maryland, Inc. v. Pub. Serv. Comm'n of Maryland , 535 U.S. 635, 644 n.3 (2002)). Accordingly, if the plaintiff’s alleged injury resulted from a state Page 12court judgment, federal district courts lack subject matter jurisdiction “to reverse.” Gilbank , 111 F.4th at 792. That authority lies only with the Supreme Court. Id. at 791–92. Named for the duo of cases holding as such, the Rooker -Feldman doctrine effectuates this statutory limitation on federal court jurisdiction. See Exxon Mobil Corp. v. Saudi Basic Indus. Corp. , 544 U.S. 280, 291 (2005).

By illustration, in Rooker v. Fidelity Trust Co. , the plaintiff commenced suit in federal district court seeking to have an adverse state court judgment “declared null and void.” 263 U.S. 413, 414 (1923). And in District of Columbia Court of Appeals v. Feldman , the plaintiffs litigated before and lost in the D.C. Court of Appeals, the district’s equivalent to a state supreme court. 460 U.S. 462, 468–70 (1983). They then sued that court in federal district court, seeking review of final judicial determinations the D.C. Court of Appeals made. Id. ; see also Exxon , 544 U.S. at 285–86 (describing Feldman ).

In both cases, the Supreme Court noted the parties’ federal complaints, under the pretext of federal question jurisdiction, “essentially invited federal courts of first instance to review and reverse unfavorable state-court judgments.” Exxon , 544 U.S. at 283; see also id. at 291-92. Such suits are properly dismissed for want of subject matter jurisdiction because appellate jurisdiction to reverse or modify state court judgments is lodged exclusively in the Supreme Court. Id. at 283–84. Consequently, lower federal courts lack subject matter jurisdiction over “cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments.” Id. at 284.

Page 13This doctrine applies only in “limited circumstances.” Id. at 291; Gilbank , 111 F.4th at 765 (citation modified). Narrow application recognizes our “virtually unflagging obligation to exercise the jurisdiction that Congress has granted” and ensures that issues are properly resolved under comity, abstention, preclusion, or other grounds where at all possible. Gilbank , 111 F.4th at 765-66 (citation modified).

To strike the right balance, we have held that lower federal courts lack subject matter jurisdiction where (1) a federal plaintiff lost in state court; (2) the state court judgment has become final before the federal proceedings began; (3) the state court judgment caused the alleged injury underlying the federal claim; (4) the claim must invite the federal district court to review and reject the state court judgment; and (5) a federal plaintiff had a reasonable opportunity to raise her federal issue in the state courts. Id. at 766. All prongs must be satisfied to divest the federal district court of subject matter jurisdiction. Id. at 792.

With respect to the third prong, jurisdiction is lacking only “where … the state-court judgment itself caused the alleged injury underlying the claim.” Id. at 766 (emphasis added). So, jurisdiction exists when there is “an independent prior injury that the state court failed to remedy.' Id. at 767 (quoting Sykes v. Cook Cnty. Cir. Ct. Prob. Div. , 837 F.3d 736, 742 (7th Cir. 2016)); see also Ghelf v. Town of Wheatland , 132 F.4th 456, 470 n.26 (7th Cir. 2025) (recognizing Rooker -Feldman does not bar “claims” that “are independent of the state-court judgment”). In other words, the doctrine does not apply '[i]f a federal plaintiff 'present[s] [an] independent claim,'' even if 'the 'same or related question' was earlier aired between the Page 14parties in state court.” Skinner , 562 U.S. at 532 (second and third alteration in original) (quoting Exxon , 544 U.S. at 29293).

As for the fourth prong, the inquiry turns on determining whether the remedy sought invites the district court to review and reject the state court judgment. Exxon , 544 U.S. at 284. We focus “on what the plaintiff asks the federal court to do.” Gilbank , 111 F.4th at 792 (emphasis in original). Rooker -Feldman may kick in when “the plaintiff asks a federal court to ‘overturn’ or ‘undo’ the state court judgment.” Id. (quoting Exxon , 544 U.S. at 287 n.2, 292-93). On the other hand, Rooker -Feldman does not divest lower courts of subject matter jurisdiction simply because a plaintiff’s requested remedy in federal court is the same as what she sought in state court. Skinner , 562 U.S. at 528, 534. It is only where, “given the relief sought, a plaintiff … seek[s] to reverse a state court judgment” that Rooker -Feldman might apply. Gilbank , 111 F.4th at 793.

The Supreme Court has twice affirmed these principles in § 1983 cases like Chapman’s here. In Skinner , the plaintiff lost his bid under the terms of a Texas statute to have DNA testing done on evidence he claimed would exonerate him. 562 U.S. at 528–29. Invoking § 1983, he then challenged the constitutionality of the Texas statute in federal court. Id. at 529. Rooker -Feldman posed no barrier because the plaintiff, in his federal action, brought a claim independent of the state court judgment. Id. at 532–53. That was true even though the plaintiff requested “an order requiring DNA testing,” id. at 534, which was the same relief he sought in Texas state court, id. at 528. See also Huey v. Kunzweiler for Tulsa Cnty. State Att’y , 847 F. App’x 530, 533 (10th Cir. 2021) (holding it did not “create a Rooker -Feldman problem” in a plaintiff’s § 1983 suit Page 15challenging a state’s post-conviction DNA testing statute that the plaintiff was “seeking the same relief through this federal action that he was denied in state court”). Because the relief the plaintiff requested in the federal action sought to remedy a prior independent injury stemming from the allegedly unconstitutional Texas statute-not the state court judgment denying the plaintiff's request under the terms of the statute-the action escaped Rooker -Feldman ’s “shoal.” See Skinner , 562 U.S. at 531–32.

Likewise, in Reed , the plaintiff challenged Texas’s law on accessing DNA evidence for post-conviction testing as unconstitutional even though he had previously lost under the Texas state court’s application of the statute to the facts of his case. Reed , 598 U.S. at 233–34. The plaintiff did not argue he was due relief under the Texas statute but, instead, 'target[ed] as unconstitutional the Texas statute [the state court] authoritatively construed.' Id. at 235 (quoting Skinner , 562 U.S. at 532). Thus, Rooker -Feldman did not hinder the lower court’s subject matter jurisdiction over the plaintiff’s claims. Id. Moreover, the majority concluded Rooker -Feldman was inapplicable, id. at 234–35 (majority opinion), notwithstanding the fact that the plaintiff had sought “the same relief” in his § 1983 action that he had previously sought in prior proceedings, id. at 246 (Thomas, J., dissenting).

Putting the jurisprudential puzzle pieces together, Rooker -Feldman does not bar a plaintiff from invoking § 1983 to challenge the constitutionality of a state’s post-conviction DNA testing statute in federal court even if he previously lost his bid to secure DNA testing under the statute’s terms in state court. See Skinner 562 U.S. at 531–33; Reed , 598 U.S. at 234–35. As the Supreme Court has explained, “a state-court decision Page 16is not reviewable by lower federal courts, but a statute or rule governing the decision may be challenged in a federal action.” Skinner 562 U.S. at 532. Because Chapman’s § 1983 action falls within the latter category, Burke's attempt to invoke the Rooker-Feldman doctrine fails.

Chapman's complaint is not a wolf in sheep's clothing, seeking to plead an independent constitutional claim but using it as a tool to seek review and reversal of the state court judgment. Instead, the entire thrust of Chapman’s complaint is that 725 Ill. Comp. Stat. 5/116-3 is unconstitutional. Chapman alleges Illinois’s post-conviction DNA testing statute “is unconstitutionally vague, ambiguous, impossible to administer, and deprived [him] of due process.” He also asserts § 1163’s “delegation of power to the trial judge, years after a jury verdict, to divine ‘the’ basis for the jury’s verdict, is a deprivation of the defendant’s right to a jury trial under the Sixth Amendment.' Various other paragraphs in his complaint echo those allegations. At bottom, the allegations in Chapman’s complaint that challenge 725 Ill. Comp. Stat. 5/116-3 as unconstitutional, coupled with the conspicuous omission of allegations challenging the state court judgment, remove it from Rooker -Feldman 's ambit. Like Skinner and Reed , RookerFeldman does not divest the federal district court of subject matter jurisdiction over Chapman’s complaint.

Chapman has standing to sue, and Rooker -Feldman poses no obstacle to subject matter jurisdiction.⁴ For the reasons Page 17stated above, we REVERSE and REMAND for proceedings consistent with this opinion.