Reed v. Goertz

JURISDICTION OVER § 1983 CLAIMS

Reed argues that the federal court has jurisdiction over his § 1983 claim because Supreme Court precedent has established that while only the Supreme Court may review state-court decisions, a lower federal court may review challenges to statutes or rules governing state-court decisions alleging violations of federal law. Brief for Petitioner, Rodney Reed at 22. Reed maintains that his § 1983 claim challenges Article 64 as it is authoritatively construed, not the decision of the CCA itself. Id. Reed further argues that the Eleventh Amendment does not bar the federal court from hearing his § 1983 claim against Goertz because federal courts may hear claims against state officials if they allege ongoing violations of federal law and seek prospective relief as a result. Id. at 23. Reed maintains that Article 64 violates his due process rights and that Goertz failed to exercise his ability as district attorney to prevent this ongoing violation of federal law. Id. Reed further maintains that the relief he seeks is prospective because he is seeking declaratory relief that will prohibit Goertz from using the CCA’s authoritative construction of Article 64 to unconstitutionally deny DNA testing. Id.

Goertz counters that the federal court does not have jurisdiction over Reed’s § 1983 claim because the Rooker-Feldman doctrine bars citizens from seeking federal court review of injuries caused by final state-court judgments, which is what Reed is attempting to do. Brief for Respondent, Bryan Goertz at 41-42. Goertz posits that Reed challenges the CCA’s decision as applied to him, and therefore his case is distinct from Skinner v. Switzer, which allowed a citizen to challenge Article 64 itself. Id. at 42. Goertz further argues that because Reed challenges both the conduct of the prosecutor assigned to his case and the CCA’s decision, Court precedent bars his claim. Id. at 39-40. Goertz contends that the Eleventh Amendment precludes Reed’s § 1983 claim against him because the Amendment prohibits suits directed towards public officials when the state is the real party in interest. Id. Goertz maintains that Texas is the real party in interest, and as an elected Texas district attorney, Goertz is entitled to immunity. Id. at 22-24. Furthermore, Goertz emphasizes that Reed cannot meet any exception to counteract Eleventh Amendment immunity. Id.

MEETING THE ARTICLE III STANDING THRESHOLD UNDER § 1983

Reed argues that he has standing to bring his § 1983 claim against Goertz because he meets all three required factors. Brief for Petitioner at 23. According to Reed, the three factors of standing are: (1) an injury in fact, (2) a causal connection between the injury and the conduct challenged before the court, and (3) a likely possibility that a favorable decision from the court will redress the injury. Id. Regarding the first factor, Reed posits that he suffered an injury in fact because Article 64 fails to protect Reed’s liberty to prove his innocence through DNA testing. Id. Regarding the second factor, Reed maintains that his injury is “fairly traceable” to Goertz because, as a district attorney, Goertz reserves the ability to access the DNA evidence, but he failed to allow the DNA testing Reed requested. Id. at 23-24. As for the third and final factor, Reed argues that a declaratory judgment can redress his injury because such judgment would prohibit Goertz from using the unconstitutional procedures outlined in Article 64 to deny Reed’s DNA testing request. Id. at 24.

Goertz counters that Reed lacks standing to sue him because he does not meet the required three factors, specifically the second and third factors. Brief for Respondent, at 37. Regarding the second factor, Goertz maintains that Reed’s alleged injury is not fairly traceable to Goertz, because Goertz did not himself deprive Reed of the ability to complete DNA testing; rather, the CCA ruled on its own that Reed failed to meet Article 64’s requirements. Id. at 38. As for the third factor, Goertz argues that declaratory judgment would not redress Reed’s alleged injury, because such judgment does not ask for any action from Goertz and would not require Goertz to alter his conduct. Id. Rather, Goertz maintains, a declaratory judgment would instead merely lead the Court to declare Article 64 unconstitutional. Id. at 38-39. Therefore, Goertz emphasizes that no relief can be granted from the person Reed traces his injury to. Id. at 39.

DETERMINING THE § 1983 STATUTE OF LIMITATIONS

Reed argues that the statute of limitations for his § 1983 claim began to run after state-court litigation ended, which was when the CCA rendered its final authoritative construction of Article 64. Brief for Petitioner at 24. Reed asserts that his challenge is to the authoritative construction of Article 64 as violative of his due process rights. Id. Thus, Reed posits that general common sense supports his argument, because it would be impossible for Reed to challenge the authoritative construction of Article 64 in federal court without knowing the CCA’s final authoritative construction of the law. Id. at 26. Reed maintains that common law underscores the common-sense argument he makes regarding the statute of limitations. Id. Reed also argues that Court precedent, as well as the very nature of his § 1983 claim, support his argument. Id. at 28. Reed posits that decisions such as District Attorney’s Office for Third Judicial District v. Osborne and Skinner, urge citizens to challenge state laws in state court before bringing federal claims challenging such laws. Id. at 29. Reed further posits that the nature of his claim, a challenge to the authoritative construction of Article 64, mandated that he wait until he had a final construction of the law before pursuing federal litigation. Id. Therefore, Reed maintains that the statute of limitations must begin after all state-court litigation ends. Id.

Reed also notes that his stance promotes due process purposes and values, because allowing the statute of limitations to begin running at the end of state-court litigation facilitates clarity regarding state procedures, which is crucial to evaluating potential deprivation of due process. Id. at 30. Reed further argues that analogous cases regarding the authoritative construction of state law depriving citizens of due process rights made their way to the Court in the past and therefore support the viability of Reed’s argument. Id. at 32.

Goertz counters that the statute of limitations began when the trial court denied DNA testing, or at the latest, when the CCA issued its decision affirming that the trial court’s denial was correct. Brief for Respondent at 14. Goertz maintains that the date the CCA’s authoritative construction of Article 64 became final is irrelevant. Id. at 18. Goertz asserts that the relevant occurrence is the moment Reed became aware of the denial of DNA testing that he views as unconstitutional. Id. Goertz emphasizes that this moment is when Reed knew he suffered an alleged injury, and therefore the statute of limitations began to run when the trial court denied DNA testing. Id. Goertz further argues that the statute of limitations should have begun, at the latest, when the CCA issued its decision because an appellate court’s opinion is immediately authoritative once it is issued. Id. at 22. Goertz posits that both Texas criminal procedure and Texas state court precedent support the assertion that an appellate court’s opinion is instantly authoritative and binding. Id. at 26-27.

Goertz also notes that Reed initially brought a challenge to Article 64 on its face, in addition to his challenge to the CCA’s authoritative construction, but he now only asks the Court to address his authoritative construction challenge. Id. at 33. Goertz nonetheless maintains the statute of limitations for Reed’s general challenge to Article 64 began to run the moment the state trial court denied DNA testing. Id.