Justia U.S. 7th Circuit Court of Appeals Opinion Summaries

Indiana enacted a law prohibiting physicians from altering a child's sex characteristics through medication or surgery as treatment for gender dysphoria. Plaintiffs, including transgender children, their parents, and a physician, argued that the law violated their rights under the Equal Protection Clause, substantive due process, and the First Amendment. The district court found these arguments likely to succeed and issued a preliminary injunction against the law. Indiana appealed the decision.The United States District Court for the Southern District of Indiana granted a preliminary injunction, finding that the plaintiffs were likely to succeed on their claims that the law violated the Equal Protection Clause and the First Amendment. The court concluded that the law discriminated based on sex and transgender status and that the aiding and abetting provision regulated speech based on its content. The court also found that the balance of harms favored the plaintiffs and that they would suffer irreparable harm without the injunction.The United States Court of Appeals for the Seventh Circuit reviewed the case and reversed the district court's decision. The Seventh Circuit held that the law did not classify based on sex or transgender status in a way that warranted heightened scrutiny. The court applied rational basis review and found that the law was rationally related to the state's legitimate interest in protecting children from uncertain and potentially harmful medical treatments. The court also held that the law's aiding and abetting provision did not violate the First Amendment, as it regulated speech integral to unlawful conduct. The court vacated the preliminary injunction and remanded the case for further proceedings. View "K.C. v. Individual Members of the Medical Licensing Board" on Justia Law

Sherman Fields, a federal prisoner, filed a petition for a writ of habeas corpus under 28 U.S.C. § 2241, which was dismissed by the district court. Fields was previously convicted of multiple crimes, including murder and carjacking, after escaping from federal custody. He was sentenced to death on one count and to imprisonment on others. Fields sought relief through various motions under 28 U.S.C. § 2255, which were denied, and his convictions and sentence were affirmed on direct appeal by the Fifth Circuit.Fields later filed a habeas petition under § 2241 in the Southern District of Indiana, where he was imprisoned. The district court stayed the proceedings pending Supreme Court decisions in related cases. Following these decisions, Fields filed another § 2255 motion, which led to the vacating of his death sentence and resentencing to life imprisonment. The district court then dismissed his § 2241 petition, holding that Fields failed to demonstrate that § 2255 was inadequate or ineffective to test the legality of his detention, as required by § 2255(e).On appeal, Fields argued that § 2255 was inadequate to address his claim of judicial bias. The United States Court of Appeals for the Seventh Circuit reviewed the case and referenced the Supreme Court's decision in Jones v. Hendrix, which clarified the relationship between § 2241 and § 2255. The court held that § 2255 is not inadequate or ineffective simply because a prisoner cannot meet the standards for a successive motion under § 2255(h). The court found that Fields had already presented his claims of judicial bias in his § 2255 motions, which were denied on the merits.The Seventh Circuit affirmed the district court's decision, concluding that Fields could not pursue his claims under § 2241 because he failed to meet the requirements of the saving clause in § 2255(e). The court emphasized that the inability to meet the standards for a successive § 2255 motion does not render § 2241 available for such claims. View "Fields v. Gilley" on Justia Law

Miko Thomas, an employee of JBS Green Bay, filed a lawsuit under Title VII of the Civil Rights Act of 1964, alleging racial discrimination. He claimed that his employer delayed his training for three years, denied his vacation requests while approving similar requests for others, and transferred him to a different shift despite knowing it caused childcare issues. Thomas argued these actions were discriminatory based on his color.The United States District Court for the Eastern District of Wisconsin dismissed Thomas's complaint under Rule 12(b)(6) for failure to state a claim. The court found that the alleged events were not serious enough to be actionable under Title VII and that Thomas's complaint did not include all necessary elements to prove his case. After Thomas amended his complaint, the district court dismissed the suit outright, maintaining that the complaint lacked sufficient detail and did not meet the required legal standards.The United States Court of Appeals for the Seventh Circuit reviewed the case and found the district court's dismissal to be mistaken. The appellate court held that the district court incorrectly required the complaint to allege significant or material injury, which is not necessary under Title VII as clarified by the Supreme Court in Muldrow v. St. Louis. The appellate court also noted that the district court improperly demanded that the complaint include every element of proof needed for summary judgment, contrary to the notice pleading standard established by the Federal Rules of Civil Procedure and reaffirmed in Swierkiewicz v. Sorema N.A.The Seventh Circuit reversed the district court's dismissal and remanded the case for further proceedings, allowing it to move to the summary-judgment stage and potentially to trial. View "Thomas v. JBS Green Bay, Inc." on Justia Law

Six former commanders of the Cook County Jail filed a lawsuit under 42 U.S.C. §1983, claiming their layoffs in late 2017 violated their First Amendment rights. The layoffs occurred during a budget crisis, which led to the elimination of their positions. The plaintiffs argued that the layoffs were retaliatory, linked to their support for unionization efforts by the Teamsters Union, which the Sheriff opposed.The United States District Court for the Northern District of Illinois granted summary judgment in favor of the Sheriff. The court found that the evidence did not support an inference that the commanders' pro-union speech caused the layoffs. The court concluded that the layoffs were a result of a significant budget shortfall, not retaliation for union activities.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that the budget crisis was the primary reason for the layoffs. It noted that the Illinois Labor Relations Board had determined the commanders were supervisors and not entitled to collective bargaining. The court found no evidence that the Sheriff's Office targeted the commanders for their union activities, as the layoffs affected all commanders regardless of their stance on unionization. The court also observed that the overall unionized workforce increased after the layoffs, further undermining the plaintiffs' claims of anti-union retaliation. The court concluded that reasonable jurors could not find the Sheriff's explanation for the layoffs to be pretextual. View "Consolino v. Dart" on Justia Law

In this case, Charles House was involved in drug trafficking activities, traveling to California to obtain large quantities of marijuana and methamphetamine, which he then shipped to addresses in Indiana. In October 2018, FedEx personnel alerted law enforcement to suspicious packages addressed to various locations in Anderson, Indiana. A drug-sniffing dog indicated that five of the twelve packages contained drugs, leading to a state warrant and the discovery of methamphetamine and marijuana. Subsequently, law enforcement installed a pole camera to surveil House’s residence for thirteen months, capturing his activities and patterns related to drug distribution.The United States District Court for the Southern District of Indiana denied House’s motion to suppress the pole camera evidence, relying on the precedent set in United States v. Tuggle, which held that the warrantless use of pole cameras does not constitute a search under the Fourth Amendment. House was found guilty on all counts, including drug distribution and possession of a firearm by a convicted felon, and was sentenced to 360 months’ imprisonment.The United States Court of Appeals for the Seventh Circuit reviewed the case and reaffirmed the Tuggle decision. The court held that the warrantless use of pole cameras to observe a home does not amount to a search under the Fourth Amendment, as it is consistent with Supreme Court precedent and the rulings of other federal courts. The court emphasized that House did not have a reasonable expectation of privacy in the activities observable from public thoroughfares. The court affirmed the district court’s denial of House’s motion to suppress the pole camera evidence. View "United States v. House" on Justia Law

A group of current and former employees of Professional Transportation, Inc. filed a collective action under the Fair Labor Standards Act (FLSA) in 2014, alleging overtime and minimum-wage violations. The district court conditionally certified the collective action, and approximately 3,500 workers opted in. However, the court later decertified the collective action, deeming it overbroad, and the suit was abandoned without an appeal. Subsequently, a second collective action was filed in a different district court on behalf of over 1,400 workers, including a new claim regarding the company's commute-time adjustment formula. This case was transferred to the Southern District of Indiana, which conditionally certified a collective action on the commute-time claim but later decertified it due to the formula's inconsistent application across locations.The Southern District of Indiana severed the claims, leaving Joseph Miller as the sole plaintiff, and determined that the statute of limitations barred Miller's claim. The plaintiffs' lawyers filed a notice of appeal. However, the main issue on appeal was the lack of an appellant, as the named plaintiffs did not file written consents to join the suit as required by 29 U.S.C. §216(b). The court found that the consents from the earlier suit could not be recycled for the new case, and the forms authorizing counsel to represent the plaintiffs were not sufficient consents to join the lawsuit.The United States Court of Appeals for the Seventh Circuit dismissed the appeal due to lack of jurisdiction, as the plaintiffs' lawyers prosecuted the appeal on behalf of individuals who were not parties to the case. The court emphasized that without proper written consents, the named plaintiffs were not parties and could not appeal. The court also noted that the district court's ruling on the statute of limitations for Miller's claim was not adequately contested on appeal. View "Ghafoor v. Professional Transportation, Inc." on Justia Law

John Henigan was involved in a drug distribution operation, buying large quantities of heroin and cocaine in Chicago and selling them in Peoria, Illinois. Following an investigation that included controlled buys, Henigan was indicted on three counts of heroin distribution. He pleaded guilty to all counts. The presentence report linked Henigan to three overdose deaths, but he denied responsibility. The probation officer recommended against reducing his offense level for acceptance of responsibility due to his denial of relevant conduct.The United States District Court for the Central District of Illinois held an evidentiary hearing. The judge found insufficient evidence to link Henigan to two of the overdose deaths but held him responsible for the death of Seth Rhodes. Despite this, the judge credited Henigan for accepting responsibility and reduced his offense level by two levels under U.S.S.G. § 3E1.1(a). The prosecutor did not move for an additional one-level reduction under § 3E1.1(b) because Henigan had falsely denied relevant conduct. The judge imposed an above-guidelines sentence based on Henigan’s involvement in Rhodes’s death.The United States Court of Appeals for the Seventh Circuit reviewed the case. Henigan challenged the prosecutor’s refusal to move for the extra acceptance-of-responsibility credit, citing a 2013 amendment to the commentary to § 3E1.1. The court rejected this argument, referencing its recent decision in United States v. Orona, which upheld the government’s broad discretion under § 3E1.1(b). Henigan also contested the judge’s factual findings regarding Rhodes’s death, but the appellate court found no clear error. Lastly, Henigan argued that his sentence was procedurally and substantively flawed due to the judge not compensating for the government’s refusal to file a § 3E1.1(b) motion. The court found this argument waived and meritless. The Seventh Circuit affirmed the district court’s decision. View "United States v. Henigan" on Justia Law

Professional Labor Group, LLC (PLG) is an Indiana-based staffing firm that employs skilled tradesmen and assigns them to remote job sites for temporary work. PLG provides per diems and mileage reimbursements but does not compensate employees for travel time to and from these assignments during normal working hours. James Walters, a former PLG employee, filed a lawsuit claiming that this travel time should be compensable under the Fair Labor Standards Act (FLSA).The United States District Court for the Southern District of Indiana denied PLG's motion for summary judgment and granted Walters' motion for summary judgment on the issue of liability. The district court concluded that federal law requires PLG to treat employee travel to overnight work assignments as compensable worktime when it occurs during normal work hours. The parties then stipulated to damages, and PLG reserved the right to appeal the summary judgment order.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court held that PLG violated the FLSA by not compensating employees for travel time to overnight assignments during normal working hours. The court clarified that 29 C.F.R. § 785.39 requires compensation for overnight travel that cuts across an employee's workday, including travel during normal working hours on nonworking days. The court rejected PLG's arguments that the travel was normal commuting and that the Portal-to-Portal Act applied, emphasizing that the regulation's substitution language is a rationale, not a prerequisite for compensation. View "Walters v. Professional Labor Group, LLC" on Justia Law

Larry Dennis pleaded guilty to possession with intent to distribute cocaine base and marijuana. The government presented photos of Dennis pointing a firearm at a man, describing the incident as an "armed robbery." Based on these photos and Dennis's post-arrest statements, the district court enhanced his sentence. Dennis contested the enhancement and argued that two of his supervised release conditions were inconsistent with the district court's pronouncements.The United States District Court for the Northern District of Illinois initially handled the case. Dennis was arrested after a search warrant at his home revealed drugs, drug paraphernalia, cash, and a loaded handgun. Despite being released, he continued similar activities, leading to a federal search warrant and further charges. Dennis pleaded guilty, and the plea agreement set a base offense level of 24. The district court applied a two-level enhancement for making a credible threat of violence based on the photos and Dennis's statements. The court imposed a 78-month sentence and included several discretionary conditions for supervised release.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's decision to enhance Dennis's sentence, finding that the government met its burden of proof with the photos and Dennis's statements. The court also found no procedural error in the district court's reliance on the government's characterization of the incident as an "armed robbery." However, the appellate court agreed with Dennis that the written judgment's discretionary conditions on supervised release conflicted with the district court's oral pronouncements. The court ordered the modification of the condition related to substance abuse treatment to reflect that Dennis only needed a mental health assessment at the probation officer's direction. The court affirmed the district court's judgment in all other respects. View "United States v. Dennis" on Justia Law

Jerry Peoples and three associates planned to rob a marijuana dealer, unaware that the police were monitoring their conversations via a wiretap. The police intervened and arrested the group before the robbery could take place. Peoples was subsequently charged with conspiring and attempting to interfere with commerce by robbing a drug dealer, in violation of the Hobbs Act.The United States District Court for the Northern District of Illinois, Eastern Division, presided over Peoples' trial. The jury found him guilty on both counts. Peoples then filed post-trial motions under Federal Rule of Criminal Procedure 29 for a judgment of acquittal and Rule 33 for a new trial, arguing that the government’s evidence was insufficient. The district court denied both motions, stating that the evidence against Peoples was overwhelming. Peoples was sentenced to concurrent terms of 110 months’ imprisonment.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court upheld the district court’s decision, finding that the evidence presented at trial, including wiretap recordings and testimony, was sufficient to support the jury’s verdict. The court noted that the wiretap revealed detailed plans for the robbery, and the actions taken by Peoples and his associates demonstrated a substantial step toward committing the crime. The court also found that the evidence satisfied the Hobbs Act’s interstate commerce element, as the robbery targeted drugs and drug proceeds. Consequently, the Seventh Circuit affirmed the district court’s denial of Peoples' motions and upheld the jury’s guilty verdicts. View "USA v. Peoples" on Justia Law