Stacey Johnson v. Tim Griffin, No. 22-1922 (8th Cir. 2023)
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Plaintiff has been incarcerated on death row in Arkansas since 1997. After he was denied relief in state court under Arkansas’s postconviction DNA testing statute, Plaintiff filed this federal lawsuit against several Arkansas officials under 42 U.S.C. Section 1983. Defendants moved to dismiss the complaint on both standing and immunity grounds. The district court denied the motion, and Defendants appealed.
The Eighth Circuit affirmed. The court explained that while Plaintiff does not expressly allege that the Attorney General currently possesses any of the DNA evidence he wants to test, Act 1780 provides the Attorney General an opportunity to play a critical role in the statute’s implementation. And here, the Attorney General responded to Plaintiff’s Act 1780 petition by opposing it in state court. The Attorney General “thereby caused,” in part, Plaintiff’s ongoing injury of being denied access to DNA testing that might prove his innocence. As such, Plaintiff has sufficiently alleged an injury in fact that was caused by Defendants and that would be redressed by the relief he seeks in his Section 1983 action. He has standing to bring his procedural due process challenge to Act 1780. Further, the court found that Defendants here are not immune from suit under the Eleventh Amendment because Plaintiff seeks prospective declaratory and injunctive relief and has alleged a sufficient connection between the defendants and Act 1780’s enforcement.
Court Description: [Kelly, Author, with Erickson and Stras, Circuit Judges] Prisoner case - Prisoner civil rights. Plaintiff, an Arkansas death row inmate, sought DNA testing under Arkansas's Act 1780 (DNA testing statute); the state courts denied his request because he could not meet the statutory prerequisite for testing in that none of the evidence which might result from the testing could advance his claim of actual innocence or raise a reasonable probability that he did not commit the murder. In this Section 1983 action, plaintiff alleged that Act 1780, as interpreted by the Arkansas Supreme Court, violated his federal constitutional rights to due process and access to the courts. The district court determined that plaintiff had standing to challenge the Act on procedural due process grounds and that the defendant officials were not entitled to qualified immunity; defendants appeal these two rulings. Held: plaintiff has sufficiently alleged an injury in fact that was caused by the defendant and that would be redressed by the relief sought in his Section 1983 action; he thus has standing to bring his procedural due process challenge to Act 1780; the defendants are not immune from suit under the Eleventh Amendment because plaintiff seeks prospective declaratory and injunctive relief and has alleged a sufficient connection between the defendants and Act 1780's enforcement as the defendants either hold the evidence and refuse to provide it or have refused to agree to DNA testing and opposed plaintiff's Act 1780 petition in state court. Judge Stras, concurring.
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