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

Elizabeth Mejia-Hernandez, a native and citizen of Honduras, arrived in the United States with her children in June 2018. They were placed in immigration removal proceedings in October 2018. Mejia conceded removability and sought asylum, withholding of removal, or protection under the Convention Against Torture (CAT), claiming fear of persecution in Honduras from a man who allegedly killed six members of her family. The immigration judge (IJ) found her ineligible for asylum, denied her requests for withholding of removal and protection under the CAT, and ordered her removal to Honduras.Mejia appealed to the Board of Immigration Appeals (Board), which upheld the IJ's decision and dismissed the appeal. The Board agreed with the IJ that Mejia did not timely object to the Notice to Appear (NTA) defects and had waived her objection by conceding removability. The Board also found insufficient evidence that Mejia had suffered past persecution or had a well-founded fear of future persecution, attributing the violence to a personal dispute rather than her membership in a particular social group.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that Mejia had suffered past persecution due to credible, serious threats and actual violence against her family by Cesar Ramirez Mejia. The court also determined that Mejia had a well-founded fear of future persecution, as Cesar had carried out his threats by killing many of her relatives. The court concluded that Mejia's family relationships were the reason she was targeted, establishing the requisite nexus between her family membership and the persecution.The Seventh Circuit granted the petition for review and remanded the case to the Board for further consideration of whether the Honduran government was sufficiently involved in Cesar’s persecution of Mejia. View "Mejia-Hernandez v. Bondi" on Justia Law

Clinton Mahoney, the sole member and manager of Mahoney & Associates, LLC, signed an agreement obligating the company to contribute to the Railroad Maintenance and Industrial Health and Welfare Fund, an employee benefit fund. When the Fund could not collect delinquent contributions from Mahoney & Associates, it sued Mahoney personally, citing a personal liability clause in the agreement. The district court granted summary judgment to the Fund, concluding that Mahoney was personally liable based on the clause.The United States District Court for the Central District of Illinois initially entered judgment on July 31, but it did not comply with Federal Rule of Civil Procedure 58. Mahoney filed a notice of appeal on September 26, and the district court later entered a corrected judgment on October 11. Mahoney filed a second notice of appeal the same day. The district court had awarded the Fund attorneys’ fees based on the trust agreement.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court found that there was a genuine dispute of material fact regarding Mahoney’s intent to be personally bound by the trust agreement, as he signed the memorandum in a representative capacity, which conflicted with the personal liability clause. The court concluded that this issue could not be resolved at summary judgment. The court also addressed Mahoney’s laches defense but found it waived due to his failure to address relevant complications. Consequently, the Seventh Circuit reversed the district court’s grant of summary judgment and vacated the award of attorneys’ fees, remanding the case for further proceedings. View "Railroad Maintenance and Industrial Health & Welfare Fund v. Mahoney" on Justia Law

Richard Walker was arrested at his girlfriend Ramona Paulette's residence, where he was staying overnight. Officers conducted a protective sweep of the residence and found a loaded firearm under the mattress in Walker Jr.'s bedroom. Later, with consent from Paulette's mother, Laverne Shipp, officers conducted a second search and found drugs in Paulette's bedroom. Walker was indicted for being a felon in possession of a firearm and possession with intent to distribute fentanyl. He moved to suppress the evidence, arguing the searches violated the Fourth Amendment.The United States District Court for the Southern District of Illinois denied Walker's motion to suppress, finding the protective sweep and subsequent search justified. Walker entered a conditional guilty plea, reserving the right to appeal the denial of his suppression motion. He was sentenced to 51 months' imprisonment and three years of supervised release.The United States Court of Appeals for the Seventh Circuit reviewed the case. Walker argued that the firearm and drugs were discovered through an unconstitutional search. The court found that Walker had standing to challenge the search and that the protective sweep was unlawful in scope when officers lifted the mattress in Walker Jr.'s bedroom. The court also determined that the district court erred in applying the attenuation exception to the exclusionary rule and did not address the inevitable discovery exception.The Seventh Circuit reversed the district court's denial of Walker's suppression motion and remanded the case for further proceedings to determine if the inevitable discovery exception applied and to reassess whether Shipp's consent justified the second search. View "United States v. Walker" on Justia Law

Eugene Westmoreland, an Illinois inmate who uses a wheelchair, filed a class action lawsuit seeking prospective relief to make the showers at the Northern Reception and Classification Center (NRC) accessible. He claimed the showers were inaccessible to individuals using mobility aids. Westmoreland filed the suit without first using the prison's internal grievance process as required by the Prison Litigation Reform Act (PLRA). Six weeks after filing, he was transferred to a different facility with accessible showers, which led to questions about the mootness of his claim.The United States District Court for the Northern District of Illinois dismissed Westmoreland's suit for lack of subject matter jurisdiction, finding his claim moot due to his transfer. The court also determined that no exception to mootness applied, as Westmoreland had not exhausted the internal grievance process, making him an inadequate class representative.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 Westmoreland's transfer rendered his claim moot and that he did not qualify for any exceptions to mootness. The court also found that Westmoreland's failure to exhaust the grievance process as required by the PLRA made him an inadequate class representative, preventing the class action from proceeding. Consequently, the court affirmed the dismissal of the suit. View "Westmoreland v. Hughes" on Justia Law

Heriberto Carbajal-Flores, an illegal alien, was arrested in Chicago after firing a pistol at passing cars during a period of civil unrest. He was indicted for possessing a firearm as an illegal alien under 18 U.S.C. § 922(g)(5)(A). Carbajal-Flores moved to dismiss the indictment, arguing that the statute violated his Second Amendment rights. The district court denied his initial motion but reconsidered after the Supreme Court's decision in New York State Rifle & Pistol Ass’n v. Bruen, which established a new framework for evaluating Second Amendment challenges.The district court ultimately found § 922(g)(5)(A) facially constitutional but held it unconstitutional as applied to Carbajal-Flores, reasoning that historical traditions only supported disarming untrustworthy or dangerous individuals, and Carbajal-Flores did not fit that description. The government appealed this decision.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the Second Amendment's protections do not extend to illegal aliens, as historical evidence shows a consistent tradition of disarming individuals who have not sworn allegiance to the sovereign. The court found that § 922(g)(5)(A) aligns with this tradition, as it only disarms illegal aliens who have not taken an oath of allegiance. The court concluded that the statute is constitutional both on its face and as applied to Carbajal-Flores, reversing the district court's decision and remanding the case for further proceedings. View "United States v. Carbajal-Flores" on Justia Law

Jordan Watkins, while in federal custody, underwent hernia repair surgery and subsequently experienced severe pain and swelling in his groin. Medical staff at the correctional facility dismissed his symptoms as routine side effects and refused to schedule a follow-up appointment before his transfer to another facility. Watkins filed Bivens claims against the medical and correctional staff for deliberate indifference to his serious medical needs and a Federal Tort Claims Act (FTCA) claim against the United States for negligent medical treatment.The United States District Court for the Northern District of Illinois dismissed all of Watkins' claims under Rule 12(b)(6). The court held that the Supreme Court's framework for evaluating Bivens claims barred Watkins' claims and that his FTCA claim was filed too late.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that Watkins' Bivens claims could proceed under the precedent set by Carlson v. Green, which allows federal prisoners to sue for damages resulting from deliberate indifference to their serious medical needs. The court found that Watkins' claims fit within the context recognized by Carlson and were not meaningfully different. The court also held that the district court's dismissal of Watkins' FTCA claim was premature. Watkins may be able to establish the requirements for equitable tolling due to extraordinary circumstances, such as disruptions caused by COVID-19, which prevented him from filing his suit on time. The Seventh Circuit reversed the district court's dismissal and remanded the case for further proceedings. View "Watkins v. Mohan" on Justia Law

Nyzier Fourqurean, a member of the University of Wisconsin-Madison's football team, challenged the National Collegiate Athletic Association (NCAA) under § 1 of the Sherman Act. He argued that the NCAA's Five-Year Rule, which restricts student-athletes to four seasons of competition within a five-year period, unreasonably restrained trade by preventing him from playing a fifth season. The district court granted a preliminary injunction, allowing Fourqurean to play an additional season, reasoning that the Supreme Court's decision in NCAA v. Alston suggested that men's NCAA Division I Football Bowl Subdivision (FBS) football is a relevant market and that the Five-Year Rule likely had anticompetitive effects.The district court concluded that Fourqurean was likely to succeed on the merits of his claim, citing Alston and the trend in the law since that decision. The court found that the NCAA's Five-Year Rule excluded student-athletes from the market when their marketability for name, image, and likeness (NIL) income was at its peak. The court also acknowledged the rule's procompetitive benefit of linking athletic careers to degree progression but suggested that the NCAA could achieve this with less restrictive means.The United States Court of Appeals for the Seventh Circuit reviewed the case and reversed the district court's decision. The appellate court held that Fourqurean failed to define the relevant market independently and did not establish that the Five-Year Rule had anticompetitive effects. The court emphasized that exclusion from the market alone does not suffice to show anticompetitive effects and that Fourqurean did not demonstrate how the rule harmed competition or created, protected, or enhanced the NCAA's dominant position in the market. Consequently, the court found that Fourqurean did not show a likelihood of success on the merits of his Sherman Act claim. View "Fourqurean v. National Collegiate Athletic Association" on Justia Law

Law enforcement conducted a warrant-backed search of an apartment occupied by Tyrone Fulwiley and Deandre Maxwell, uncovering firearms, cocaine, and drug distribution paraphernalia. Maxwell pleaded guilty to charges of possession of cocaine with intent to distribute, possession of a firearm in furtherance of a drug trafficking offense, and possession of a firearm by a felon. Fulwiley went to trial and was convicted on all counts by a jury. Both defendants challenged the search, the denial of a Franks hearing, and the refusal to reveal the identity of the confidential informant. Fulwiley also contested the sufficiency of the evidence supporting his conviction.The United States District Court for the Central District of Illinois denied the defendants' motions to suppress evidence, for a Franks hearing, and to reveal the informant's identity. Fulwiley's motion for a judgment of acquittal was also denied. Maxwell pleaded guilty, while Fulwiley was convicted by a jury based on evidence including testimony from law enforcement and a forensic expert linking him to the drugs and firearms found in the apartment.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decisions. The appellate court held that the search warrant was supported by probable cause, given the detailed and corroborated information provided by the confidential informant. The court also found no error in the denial of a Franks hearing, as the defendants failed to make a substantial preliminary showing of a material falsity or omission in the warrant affidavit. Additionally, the court upheld the decision not to reveal the informant's identity, as the informant was deemed a mere tipster and not essential to the defense. Finally, the court found sufficient evidence to support Fulwiley's convictions, including his constructive possession of the drugs and firearms and the nexus between the firearms and drug trafficking activities. View "United States v. Maxwell" on Justia Law

A Wisconsin prisoner, Armin Wand III, developed appendicitis in February 2018. He was seen by Nurse Beckey Kramer on February 13, 2018, but she did not diagnose appendicitis at that time. The next day, February 14, she recognized the symptoms and sent him to the hospital for emergency surgery. Wand sued Kramer and other officials, claiming inadequate medical care under the Eighth Amendment and state law negligence for not recognizing his need for emergency care on February 13.The United States District Court for the Western District of Wisconsin denied summary judgment for Kramer and another defendant, allowing the case to proceed to trial. The court recruited an experienced lawyer for Wand, but only for settlement purposes. After settlement efforts failed, the lawyer withdrew, and Wand's subsequent motion for recruitment of another lawyer was denied. The court noted Wand's legal blindness and severe stutter but believed he could represent himself with the court's assistance.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that Wand's trial testimony contradicted his earlier claims, stating he did not report lower right quadrant pain to Kramer on February 13, which was crucial for diagnosing appendicitis. The court concluded that Wand's case was substantively weak and that he had not shown prejudice from the lack of recruited counsel. The court affirmed the district court's judgment in favor of Kramer, holding that Wand did not demonstrate a reasonable likelihood that the presence of counsel would have changed the trial's outcome. View "Wand v. Kramer" on Justia Law

Malcolm Wilson, an inmate at Indiana State Prison, was involved in an altercation where he grabbed another inmate's cane to defend himself, causing the other inmate to fall and require medical attention. Wilson was charged with battery and, after a disciplinary hearing conducted by Lieutenant Angelita Castaneda, was found guilty. Castaneda imposed a sentence that included 90 days in restrictive housing, a demotion in credit class, and up to $100,000 in restitution for medical costs.The United States District Court for the Northern District of Indiana dismissed Wilson's pro se complaint at the screening stage under 28 U.S.C. § 1915A, finding that there was sufficient evidence to support the restitution order. Wilson's motion for reconsideration was also denied. Wilson appealed the dismissal, arguing that the restitution amount was not supported by any evidence.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo, accepting the factual allegations in Wilson's complaint as true. The court found that the evidence presented at the disciplinary hearing, including Wilson's statements, video footage, and staff conduct reports, constituted "some evidence" to support the restitution order. The court held that the procedural requirements of due process were met, as Wilson received notice of the charges, an opportunity to defend himself, and a written statement of the evidence and reasons for the disciplinary action. The court affirmed the district court's judgment, concluding that Wilson received the process he was due. View "Wilson v. Castaneda" on Justia Law