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

Mary Ann Arnold worked for United Airlines from 1994 to 2020. She alleged age discrimination, retaliation, hostile work environment, and constructive discharge after experiencing changes in her job responsibilities and being placed on a Performance Improvement Plan (PIP). Arnold claimed these actions were due to her age and previous complaints about discrimination and harassment.The United States District Court for the Northern District of Illinois granted summary judgment in favor of United Airlines on Arnold's claims of discrimination, retaliation, and hostile work environment. The court dismissed her constructive discharge claim without prejudice, citing failure to exhaust administrative remedies.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's decision, holding that Arnold did not provide sufficient evidence to show that she suffered adverse employment actions due to age discrimination. The court also found that her retaliation claim failed because the actions taken by United were not materially adverse and were not shown to be causally connected to her complaints. Additionally, the court held that Arnold did not demonstrate a hostile work environment based on age, as the incidents she described were not severe or pervasive enough to meet the legal standard. The court also upheld the dismissal of her constructive discharge claim due to failure to exhaust administrative remedies. View "Arnold v. United Airlines, Inc." on Justia Law

Anthony Sullers, Sr., an African American elevator mechanic, filed a lawsuit against his union, the International Union of Elevator Constructors, Local 2 (IUEC), alleging that the union breached its duty of fair representation in handling his claim of racial discrimination by his employer, ThyssenKrupp Elevator Corporation (TKE). Sullers and another employee were laid off, and while Sullers was without work, TKE hired a white mechanic. Sullers informed the union of his layoff and his belief that it was racially motivated. The union filed a grievance on his behalf but did not include allegations of racial discrimination. Sullers followed the union's advice to file a complaint with the Illinois Department of Human Rights (IDHR).The United States District Court for the Northern District of Illinois granted summary judgment in favor of IUEC. The court found that the union had fulfilled its duty of fair representation by obtaining the maximum remedy available for Sullers, including his reinstatement and backpay. The court also noted that Sullers had not requested the union to file a racial discrimination grievance and that the union's actions were not arbitrary, discriminatory, or in bad faith.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's judgment. The appellate court held that the union's decision to pursue the grievance as it did, rather than filing a racial discrimination grievance, was within its discretion and not arbitrary, discriminatory, or in bad faith. The court also found that Sullers did not suffer harm attributable to the union's actions, as he was reinstated and received backpay. The court concluded that the union had properly represented Sullers and that he had not shown how he would have achieved a better outcome through arbitration. View "Sullers v. International Union Elevator Constructors, Local 2" on Justia Law

Federal agents investigated a drug trafficking conspiracy in Fort Wayne, Indiana, using a confidential source to conduct controlled buys from Zachary Barnes. Barnes coordinated the sales, supplied methamphetamine, and directed his co-conspirator, Marquese Neal, to make deliveries. Neal testified that Barnes paid him in marijuana for his services. Barnes was arrested, and law enforcement found drugs and ammunition in his home.Barnes pleaded guilty to conspiracy to distribute methamphetamine and to possess it with intent to distribute. The United States District Court for the Northern District of Indiana applied a two-level enhancement under section 3B1.1(c) of the Sentencing Guidelines for Barnes' role as a manager or supervisor. This enhancement made Barnes ineligible for safety-valve relief under 18 U.S.C. § 3553(f), resulting in a mandatory minimum sentence of ten years. Barnes objected to the role enhancement and the denial of safety-valve relief, but the district court overruled his objections, finding Neal's testimony credible and supported by other evidence.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's application of the role enhancement, agreeing that Barnes' actions—recruiting Neal, coordinating logistics, supplying drugs, and directing deliveries—fit the criteria for a manager or supervisor under section 3B1.1(c). The court also upheld the denial of safety-valve relief, as Barnes' supervisory role made him ineligible. The Seventh Circuit found no clear error in the district court's credibility determinations or factual findings and affirmed Barnes' ten-year sentence. View "United States v. Barnes" on Justia Law

Michael Cobbs pleaded guilty in 2017 to attempted Hobbs Act robbery, using or brandishing a firearm during a crime of violence, and being a felon in possession of a firearm. The attempted Hobbs Act robbery served as the predicate crime of violence for the firearm charge. Cobbs later sought to vacate his 25-year sentence under 28 U.S.C. § 2255, arguing that his § 924(c) conviction was invalid based on the Supreme Court's decision in United States v. Taylor, which held that attempted Hobbs Act robbery is not a crime of violence for purposes of § 924(c).The United States District Court for the Central District of Illinois denied Cobbs’s petition, finding that he had procedurally defaulted his claim by not raising it on direct appeal and that he failed to show cause or actual innocence to excuse the default. The district court also noted that Cobbs admitted to facts supporting a conviction for a completed Hobbs Act robbery, which would still qualify as a crime of violence under § 924(c).The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that Cobbs could not demonstrate actual innocence because he admitted to facts that constituted a completed Hobbs Act robbery, which remains a valid predicate for a § 924(c) conviction. The court concluded that the change in law announced in Taylor did not affect Cobbs’s conviction since his factual admissions supported a completed robbery charge. Therefore, Cobbs’s procedural default was not excused, and his petition to vacate his sentence was properly denied. View "Cobbs v USA" on Justia Law

Santoasha Harris endured five years of sexual harassment at her job with the City of Milwaukee. When she reported the harassment in 2017, the City separated her from the harasser, conducted an investigation, compelled the harasser’s resignation, and restored Harris to her position within a month. Harris sued the City, alleging it knew about the harassment for years, failed to act, and retaliated against her for reporting it. Due to Harris’s bankruptcy filing, her estate was substituted as the plaintiff.The United States District Court for the Eastern District of Wisconsin granted summary judgment to the City. The court concluded that Harris’s Estate had not shown the City unreasonably failed to prevent the harassment or that she suffered a tangible employment action as a consequence of reporting it. The court found no evidence supporting the Title VII and Section 1983 claims against the City.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s judgment. The appellate court agreed that the evidence did not support the claims of quid pro quo harassment, hostile work environment, or retaliation under Title VII. The court found that Harris did not suffer a tangible employment action and that the City acted promptly and reasonably once the harassment was reported. Additionally, the court found no basis for employer liability under Section 1983, as there was no evidence of intentional discrimination by the City. The court concluded that no reasonable jury could find for the Estate on its claims against the City. View "Bankruptcy Estate of Harris v City of Milwaukee" on Justia Law

Alicia Rae Pufahl applied for disability insurance benefits from the Social Security Administration in August 2012, citing limitations due to Wegener’s granulomatosis, depression, pulmonary disease, back injury, bipolar disorder, and excessive fatigue. She needed to establish disability between August 8, 2011, and December 31, 2016. Her application was initially denied in November 2012, followed by several unfavorable decisions from Administrative Law Judges (ALJs), appeals, and remands. The most recent ALJ decision concluded that she was not disabled during the relevant period, and the district court affirmed this decision.The United States District Court for the Eastern District of Wisconsin affirmed the ALJ’s decision, finding that substantial evidence supported the agency’s determination. The Appeals Council denied further review, making the ALJ’s decision the final decision of the Commissioner of Social Security.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s judgment. The court held that the ALJ properly weighed the medical opinion evidence, including the opinions of Ms. Pufahl’s neurologist, primary care provider, and psychiatrist, and found substantial evidence supporting the ALJ’s decision to not give controlling weight to these opinions. The ALJ’s evaluation of Ms. Pufahl’s subjective complaints was not patently wrong, as it was supported by specific reasons and evidence. Additionally, the hypothetical question posed to the vocational expert (VE) sufficiently accounted for Ms. Pufahl’s mental limitations, including her ability to maintain attention and concentration for two-hour segments. The court concluded that the ALJ’s decision was supported by substantial evidence and affirmed the district court’s judgment. View "Pufahl v Bisignano" on Justia Law

Evelio Santana pleaded guilty to unlawful possession of a firearm as a convicted felon. His sentence was enhanced under the Armed Career Criminal Act (ACCA) after the district judge found by a preponderance of the evidence that Santana had three prior convictions for violent felonies committed on different occasions. Santana appealed, arguing that the determination should have been made by a jury beyond a reasonable doubt, as required by a recent Supreme Court decision in Erlinger v. United States.The United States District Court for the Southern District of Indiana initially handled Santana's case. The district judge determined that Santana's prior convictions were committed on different occasions and sentenced him to the mandatory minimum of fifteen years in prison under the ACCA. Santana's lawyer had agreed with the judge's authority to make this determination based on then-current Seventh Circuit precedent. The government objected, arguing that a jury should make the determination, but the judge overruled the objection.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that an error occurred because the judge, not a jury, made the different-occasions determination by a preponderance of the evidence, contrary to the Supreme Court's ruling in Erlinger. The error was plain and affected Santana's substantial rights by increasing his sentence. The court concluded that the error undermined the fairness and integrity of the proceedings, as a reasonable jury might have found reasonable doubt about whether the prior felonies were committed on different occasions. Consequently, the Seventh Circuit vacated Santana's sentence and remanded the case for resentencing consistent with the Supreme Court's decision in Erlinger. View "United States v Santana" on Justia Law

During the COVID-19 pandemic, Tangtang Zhao, a pharmacist at Walgreens, took blank COVID-19 vaccination cards from his workplace and sold them on eBay for personal profit. Zhao was charged with and convicted on twelve counts of theft of government property under 18 U.S.C. § 641. He appealed, arguing that the government did not provide sufficient evidence to prove that the vaccination cards were government property when he took them. He also challenged the trial judge’s response to the jury’s question about the definition of government property and parts of the jury instructions.The United States District Court for the Northern District of Illinois denied Zhao’s motion for judgment of acquittal, and the jury found him guilty on all counts. Zhao was sentenced to one year of probation and fined $5,600. He renewed his motion for judgment of acquittal, which was again denied by the district court.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the lower court’s decision. The appellate court held that the government presented sufficient evidence that it maintained supervision and control over the vaccination cards, which retained their federal character. The court found that the government’s restrictions on the use and distribution of the cards, its right to inspect and access the cards, and its ability to terminate Walgreens’ participation in the vaccination program were sufficient to prove that the cards were government property.The appellate court also held that the district court did not err in its response to the jury’s question or in its jury instructions. The court concluded that the instructions were correct statements of the law and that the district court acted within its discretion. The appellate court affirmed Zhao’s conviction and sentence. View "USA v Zhao" on Justia Law

Jesus Zambrano was convicted of first-degree murder in Illinois state court in 2013. The Illinois Appellate Court later found that the trial court erred by not giving a jury instruction on accomplice liability, leading to a retrial where Zambrano was acquitted. Zambrano then filed a federal lawsuit against Detective Patrick Schumacher and sought indemnification from the City of Joliet, alleging that Schumacher fabricated evidence, violating his Fourteenth Amendment due process rights.The case involved the murder of Robert Gooch, who was shot at his girlfriend's apartment in May 2009. Key evidence included testimonies and surveillance videos placing Zambrano at the scene. Detective Schumacher's police report stated that Zambrano identified his friends and the location of his girlfriend's apartment, which Zambrano claimed was false.The United States District Court for the Northern District of Illinois granted summary judgment in favor of the defendants, finding that Zambrano failed to provide sufficient evidence that Schumacher deliberately falsified evidence in bad faith or that the alleged fabrication was material to his conviction.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 Zambrano did not present enough evidence to show that Schumacher knowingly falsified the police report or acted in bad faith. Additionally, the court found that the alleged fabricated evidence was not material to the outcome of the trial, as it did not affect the jury's judgment. Therefore, the summary judgment in favor of the defendants was upheld. View "Zambrano v City of Joliet" on Justia Law

Gurkirat Singh, a citizen of India and a member of the Sikh ethnoreligious group, fled to the United States after being beaten and threatened by members of the Congress Party due to his political activities with the Mann Party. Singh applied for asylum, withholding of removal, and relief under the Convention Against Torture (CAT). The Immigration Judge (IJ) denied his requests, finding that Singh could reasonably relocate within India to avoid persecution. The Board of Immigration Appeals (BIA) affirmed the IJ's decision.The IJ found Singh's testimony credible but concluded that he had not suffered persecution, would not face a substantial risk of torture if deported, and could safely relocate within India. The IJ noted that Singh, a healthy 25-year-old male, had successfully relocated to the United States and maintained a livelihood. The BIA affirmed the IJ's decision, finding no clear error in the IJ's relocation or past persecution findings.The United States Court of Appeals for the Seventh Circuit reviewed Singh's petition. Singh argued that the BIA improperly deferred to the IJ, erred in finding he could reasonably relocate within India, and erred in finding he had not suffered past persecution. The court found that the BIA did not defer to the IJ but conducted an independent review of the record. The court also held that substantial evidence supported the IJ and BIA's conclusion that Singh could reasonably relocate within India, given his health, resilience, and adaptability. Consequently, the court denied Singh's petition for review, affirming that he is ineligible for asylum, withholding of removal, or protection under the CAT. View "Singh v Bondi" on Justia Law