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Chapman v. Doe

Updated Sep 19, 2026

In brief

The Supreme Court wiped out the ruling and sent the case back to be thrown out as moot; it did not decide whether Chapman had immunity or whether the notice violated the minor’s rights.

Where it stands
Decided

Decided · March 20, 2023 · Opinion by Justice Jackson

What it’s about
This case considers whether a court clerk is entitled to quasi-judicial immunity after notifying a minor's parents about her application for a judicial bypass for an abortion.
Who it affects
The ruling no longer stands, and the Eighth Circuit must throw out the case (dismiss it) as moot. The Supreme Court did not decide whether Chapman had immunity or whether the notice violated the minor’s clearly established rights in this case.

Summary: written with AI from the case record.

Illustration for Chapman v. Doe
Conceptual illustration · AI-generated

What it's about

It also examines whether such notification violated the minor's clearly established rights in 2018.

This case shows that a moot dispute can end with the ruling wiped out, without the Supreme Court deciding the underlying legal questions.

Question presented

1. Whether a court clerk is entitled to quasi-judicial immunity after notifying a minor's parents about her application for a judicial bypass for an abortion. 2. Whether such notification violated the minor's clearly established rights in 2018.

What the Court decided

Holding

The judgment is vacated, and the case is remanded to the United States Court of Appeals for the Eighth Circuit with instructions to dismiss the case as moot.

Result
Vacated

The vote

Majority author
Ketanji Brown Jackson

From the opinions

“Here, the majority has acquiesced to the parties’ joint request for a Munsingwear vacatur.”

— Justice Jackson(dissent)

What's next

The Eighth Circuit must follow the Supreme Court’s instructions and throw out the case (dismiss it) as moot. That ends this case without a Supreme Court decision on Chapman’s immunity or the 2018 rights question.

Documents

4

Docket activity

7
  • New analysis added

    Sep 19, 2026 · Court records

  • AI analysis generated: Case Briefing

    Sep 19, 2026 · Generated

  • AI analysis generated: Decision Record

    Sep 19, 2026 · Generated

  • Opinion added: Chapman

    Mar 20, 2023 · Court records

  • Opinion added: Opinion

    Mar 20, 2023 · Court records

Show 2 more
  • Brief added: Petition

    Sep 30, 2022 · Court records

  • Court Order added: Lower Court Orders/Opinions

    Aug 15, 2022 · Court records

More questions

4
What did the Supreme Court do in Chapman v. Doe?
It wiped out the ruling (vacated) and sent the case back to the Eighth Circuit (remanded) to throw out the case as moot.
Did the Court decide whether Clerk Chapman had quasi-judicial immunity (legal protection from a lawsuit)?
No. It did not decide whether Chapman had that legal protection in this case.
Did the Court decide whether the notification violated the minor’s rights that were clearly established in 2018?
No. It did not decide whether the 2018 notification violated the minor’s clearly established rights.
What happens next in Chapman v. Doe?
The Eighth Circuit must follow the instructions and throw out the case (dismiss it) as moot, meaning the dispute is no longer live.

Sources

Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.

Checked Sep 19, 2026Methodology

Court records and filings

Reporting and analysis