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Supreme Court reverses Fifth Circuit, allows challenge to Texas DNA-testing limits in Gutierrez v. Saenz

Term Talk Podcast from the Federal Judicial Center · October 2, 2025
AI-Generated Content: All content on this page was generated by AI to highlight key points from the meeting. For complete details and context, we recommend watching the full video. so we can fix them.

Summary

In a 6–3 decision, the Supreme Court held that a death‑row inmate may challenge Texas’s Article 64 restrictions on postconviction DNA testing, rejecting the Fifth Circuit’s probabilistic redressability analysis and instructing lower courts to consider the plaintiff’s original prayer for relief.

Jim Chance, senior judicial education attorney at the Federal Judicial Center, moderated a panel discussion of Gutierrez v. Saenz, in which the Supreme Court reversed the Fifth Circuit and allowed a challenge to Texas’s postconviction DNA-testing rules.

The court reversed 6–3 (the transcript attributes the opinion to Justice Sotomayor, joined by the chief justice and Justices Kagan, Kavanaugh, Barrett, and Jackson) and faulted the appeals court for treating redressability as a probabilistic ‘‘guess’’ about whether a prosecutor would ultimately hand over evidence. Unidentified Panelist (S3), a panelist on the podcast, summarized the majority’s view that the court of appeals should have examined Gutierrez’s original prayer for relief…

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