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Supreme Court decisions
No. 23-7809Jun 26, 2025Crime and Law EnforcementReversed

The question

Whether a death-row prisoner has Article III standing to bring a Section 1983 due process claim challenging a state's postconviction DNA testing procedures.

Gutierrez v. Saenz

What the Court decided

The Court held that Ruben Gutierrez has standing to bring his Section 1983 claim challenging Texas's postconviction DNA testing procedures under the Due Process Clause. The prosecutor's denial of DNA testing injured Gutierrez by depriving him of his liberty interest in using state procedures to seek an acquittal or reduced sentence, and a declaratory judgment that Texas's procedures violate due process would redress that injury by removing the barrier to the requested testing. The decision follows Reed v. Goertz, which recognized standing on materially the same facts.

How the justices split

6-3
In favor 6Against 3
Sotomayor
Roberts
Kagan
Kavanaugh
Jackson
Barrett
Thomas
Alito
Gorsuch

The Court's opinion

Sotomayor, joined by Roberts, Kagan, Kavanaugh, Jackson, Barrett

Gutierrez has standing to bring his Section 1983 due process claim. He adequately alleged an injury in the denial of access to the requested evidence, the prosecutor caused that injury by denying access, and a declaratory judgment that Texas's postconviction DNA testing procedures violate due process would redress the injury by removing the prosecutor's justification for denying testing. The case is controlled by Reed v. Goertz, which recognized standing on materially the same facts, and by the liberty interest in demonstrating innocence with new evidence under state law recognized in Osborne and Skinner. Barrett joined all but Part II-B-2.

Concurring in part and in the judgment

Barrett, writing alone

Barrett concurred in part and concurred in the judgment, agreeing with the outcome but not joining Part II-B-2 of the Court's opinion.

Dissenting

Thomas, writing alone

Thomas filed a dissenting opinion arguing that Gutierrez lacks standing to bring his Section 1983 claim.

Dissenting

Alito, joined by Thomas, Gorsuch

Alito filed a dissenting opinion, joined by Thomas and Gorsuch, arguing that Gutierrez lacks standing because a favorable declaratory judgment would not redress his asserted injury.

How we know · 5 sourced claims
  • The Court held that Gutierrez has standing to bring his Section 1983 claim challenging Texas's postconviction DNA testing procedures under the Due Process Clause.

    Source: syllabus, Held

  • Sotomayor delivered the opinion of the Court, joined by Roberts, Kagan, Kavanaugh, and Jackson, and joined by Barrett as to all but Part II-B-2.

    Source: syllabus, lineup

  • Barrett filed an opinion concurring in part and concurring in the judgment.

    Source: syllabus, lineup

  • Alito filed a dissenting opinion, in which Thomas and Gorsuch joined, and Thomas also filed a separate dissenting opinion.

    Source: syllabus, lineup

  • The Court relied on Reed v. Goertz, 598 U. S. 230, which recognized a Texas prisoner's standing to pursue declaratory relief on materially the same facts.

    Source: syllabus, Held

Read the opinion on supremecourt.gov