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

In February 2018, Joseph Fuchs, a special agent with the U.S. Postal Service’s Office of the Inspector General, traveled to the Philippines to engage in sexual activity with a 14-year-old girl, referred to as MV-1. Homeland Security Investigations (HSI) was alerted by the Illinois Attorney General’s office in March 2019, following a tip from Facebook about Fuchs’s explicit messages to MV-1. HSI confirmed Fuchs’s trip and examined his Facebook messages, which revealed his belief that MV-1 was 14 or 15 years old and detailed their sexual encounters. A photograph and MV-1’s birth certificate confirmed her age.The United States District Court for the Southern District of Illinois tried the case without a jury. Fuchs contested the admissibility of MV-1’s birth certificate, arguing insufficient proof of its authenticity. The court admitted the birth certificate, along with other evidence, including Fuchs’s Facebook messages, a recorded interview, and financial records of payments to MV-1. The court found Fuchs guilty of using a facility of foreign commerce to coerce a minor, traveling with intent to engage in illicit sexual conduct, and engaging in illicit conduct in a foreign country. He was sentenced to 126 months in prison.The United States Court of Appeals for the Seventh Circuit reviewed the case. Fuchs challenged the admissibility of the birth certificate and the recorded interview, and argued insufficient evidence for his conviction. The court upheld the district court’s decision, finding the birth certificate properly admitted and the evidence sufficient to establish MV-1’s age and Fuchs’s guilt. The court affirmed Fuchs’s conviction. View "U.S. v. Fuchs" on Justia Law

Michael Davis was arrested after a 911 call from a 15-year-old girl in Gary, Indiana, reported that he had threatened to kill her mother and had an assault rifle in his car. Police located Davis following the family's minivan and arrested him. A search of his vehicle revealed a loaded, semi-automatic shotgun with an obliterated serial number. Davis was charged with illegal firearm possession under 18 U.S.C. § 922(g). He moved to suppress the shotgun, arguing the search violated the Fourth Amendment, but the district court denied his motion.The United States District Court for the Northern District of Indiana held a two-day evidentiary hearing and found that the warrantless search of Davis's vehicle was justified under both the search incident to arrest and automobile exceptions to the warrant requirement. Davis entered a conditional guilty plea, reserving his right to appeal the suppression ruling. He was sentenced to ninety-two months in prison and two years of supervised release.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's denial of Davis's motion to suppress, holding that the search of Davis's vehicle was lawful under both the search incident to arrest and automobile exceptions. The court found that the officers had probable cause to arrest Davis based on the credible 911 report and corroborating evidence. Additionally, the court determined that it was reasonable to believe Davis's vehicle contained evidence of the crime, thus justifying the search. The judgment of the district court was affirmed. View "United States v. Davis" on Justia Law

Santanu Das, a sales associate at Tata Consultancy Services, participated in a compensation incentive plan that promised a bonus exceeding $400,000 for achieving certain sales targets. Das met the target but was paid less than $100,000. He sued Tata under Illinois law, which requires employers to pay all agreed-upon compensation. Tata argued that disclaimers in the incentive plan negated any agreement to pay the bonus. The district court dismissed Das’s complaint, leading to this appeal.The United States District Court for the Northern District of Illinois initially dismissed Das’s claims without prejudice. Das amended his complaint, adding breach of contract and fraudulent misrepresentation claims. The district court dismissed the repleaded claims with prejudice but allowed Das to replead the new claims. Das chose to appeal only the Wage Act and fraudulent misrepresentation claims. The district court found that the disclaimers in the incentive plan prevented the formation of an agreement to pay wages and that Das’s fraudulent misrepresentation claim lacked the necessary particularity.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court found that Illinois law does not treat disclaimers as necessarily preventing the formation of mutual assent to terms. The court noted that past practices between Das and Tata could establish mutual assent. The court concluded that Das had plausibly alleged that Tata agreed to pay him the full bonus, reversing the district court’s dismissal of the Wage Act claim. However, the court affirmed the dismissal of the fraudulent misrepresentation claim, as Das failed to allege a scheme to defraud.The Seventh Circuit reversed the district court’s decision on the Wage Act claim and remanded the case for further proceedings. The dismissal of the fraudulent misrepresentation claim was affirmed. View "Das v. Tata Consultancy Services Limited" on Justia Law

Heide Montoya, a former Superintendent of On-Board Services at Amtrak, was discharged in 2020 and later rehired to a different position. Montoya filed a lawsuit alleging sex discrimination and other state-law claims. The litigation became complicated due to a dispute over arbitration. Amtrak argued that Montoya had agreed to arbitration by continuing to work after receiving an email notice. Montoya denied receiving the arbitration agreement, and the district judge could not resolve the issue due to a lack of definitive evidence.The United States District Court for the Northern District of Illinois, Eastern Division, held a status hearing where the judge indicated that the evidence was insufficient to determine if an arbitration agreement existed. The judge suggested that the parties confer and possibly provide a joint statement on how to proceed. Instead of following these steps, Amtrak filed a notice of appeal, relying on §16(a)(1) of the Federal Arbitration Act (FAA), which allows interlocutory appeals from orders bypassing arbitration.The United States Court of Appeals for the Seventh Circuit reviewed the case and found that §16 of the FAA only applies when the Act as a whole is applicable. Section 1 of the FAA excludes contracts of employment for railroad employees, among others, from its scope. Since Montoya was an Amtrak employee, the case falls outside the FAA. The court referenced similar cases and legal precedents, including Southwest Airlines Co. v. Saxon and Bissonnette v. LePage Bakeries Park St., LLC, to support its conclusion. Consequently, the Seventh Circuit dismissed Amtrak's appeal for lack of jurisdiction, noting that the district court still needs to resolve whether Montoya agreed to arbitrate disputes under state law. View "Montoya v. National Railroad Passenger Corp." on Justia Law

Three former satellite service technicians filed a class action lawsuit against their employer, DirectSat USA, LLC, alleging violations of the Illinois Minimum Wage Law (IMWL) and the Fair Labor Standards Act (FLSA). They claimed that DirectSat failed to compensate them for work-related tasks performed beyond forty hours per week. The district court initially certified a class of full-time Illinois DirectSat technicians but later vacated this certification and certified a Rule 23(c)(4) issue class to resolve fifteen questions related to DirectSat’s liability.The case was reassigned to another district judge in 2019. Before the trial, the district court decertified the Rule 23(c)(4) class. The plaintiffs settled their individual claims but reserved the right to appeal the decertification decision. The district court found that the class action was not a superior method for adjudicating the plaintiffs' controversy due to the variance in the amount of time technicians spent on work-related tasks and the individualized nature of their piece-rate compensation system.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that a party seeking certification of an issue class under Rule 23(c)(4) must show that common questions predominate in the resolution of the specific issues to be certified, not the entire cause of action. However, the court affirmed the district court’s decision to decertify the class, concluding that a class action was not a superior method for resolving the controversy due to the individualized nature of the claims and the necessity for numerous separate trials to determine liability and damages. View "Jacks v. DirectSat USA, LLC" on Justia Law

James Harris, with a significant criminal history, was on federal supervised release following a 2013 federal drug conviction. After his release in 2016, he was arrested and convicted in a state drug case, leading to the revocation of his federal supervised release. He was sentenced to one year in prison, followed by three years of supervised release. In 2020, Harris was arrested again on state gun charges, which led to further alleged violations of his federal supervised release conditions.The United States District Court for the Northern District of Illinois held a two-day evidentiary hearing in July 2023. The court found that Harris had violated the conditions of his supervised release by using controlled substances and failing to comply with the rules of a community corrections program. Additionally, the court found by a preponderance of the evidence that Harris had unlawfully possessed a firearm, despite his acquittal in the state gun case. The court sentenced Harris to 36 months in prison for the firearm violation and 24 months for the community corrections program violation, to be served concurrently, with no additional supervised release.The United States Court of Appeals for the Seventh Circuit reviewed the case. Harris argued that the district court lacked jurisdiction to rule on the supervised release violations and that procedural errors were made during the revocation hearing. The Seventh Circuit held that the district court had jurisdiction, as Harris's federal supervised release term was tolled during his five-month imprisonment for violating state supervised release. The court also found no procedural errors, concluding that Harris had admitted to the Salvation Army violations and that the district court did not rely on inaccurate information. The Seventh Circuit affirmed the district court's ruling. View "United States v. Harris" on Justia Law

The City of Chicago’s Department of Water Management hired Tinka Vassileva as a Filtration Engineer (FE) in 2001. Vassileva, who started as an FE II, was promoted to FE III in July 2019. She applied unsuccessfully for promotions to FE V in April 2018 and FE IV in July 2019. Vassileva claimed that the City’s decisions not to interview her for these positions were based on age, gender, national origin, and retaliation for previous discrimination charges she filed with the Illinois Department of Human Rights (IDHR) and the Equal Employment Opportunity Commission (EEOC).The United States District Court for the Northern District of Illinois granted summary judgment in favor of the City on all claims. The court found that Vassileva did not provide sufficient evidence that her age, gender, national origin, or EEOC charges motivated the City’s decision not to interview her for the 2018 FE V position. Additionally, the court concluded that Vassileva had not administratively exhausted her claims related to the 2019 FE IV openings, as she failed to file an EEOC charge based on the City’s 2019 actions before filing the lawsuit.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The appellate court held that Vassileva did not present evidence suggesting that the City’s explanation for not interviewing her in 2018 was pretext for discrimination or retaliation. The court also noted that Vassileva failed to show that the decision-maker was aware of her EEOC charges. Regarding the 2019 claims, the court found that Vassileva waived her argument about administrative exhaustion by not addressing it until oral argument. Thus, the appellate court affirmed the summary judgment in favor of the City. View "Vassileva v. City of Chicago" on Justia Law

Lafiamma Orona was indicted for mail theft, identity theft, and related crimes after a scheme involving the theft of mail, including credit cards and checks, from mailboxes in Elkhart County, Indiana. He pleaded guilty to all charges about six weeks before trial. Under the Sentencing Guidelines, a defendant who pleads guilty and admits their conduct can receive a two-point reduction in their offense level, with an additional one-point reduction possible if the government files a motion affirming that the defendant's acceptance of responsibility saved prosecutorial and court resources.The district judge awarded Orona the two-level reduction, but the prosecutor declined to move for the extra one-level reduction, citing Orona's baseless challenge to the loss amount, which required the government to prepare for a contested sentencing hearing. Orona objected, asking the judge to order the prosecutor to file the motion. The judge overruled the objection, holding that the government had permissibly withheld the motion based on Orona's frivolous challenge. This decision was consistent with circuit precedent, specifically United States v. Nurek and United States v. Sainz-Preciado.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 Sentencing Commission's Amendment 775 did not abrogate the precedent set by Nurek and Sainz-Preciado. Therefore, the government was within its rights to withhold the motion for the additional one-level reduction under § 3E1.1(b) based on Orona's objections to the loss amount, which necessitated additional prosecutorial resources. The court concluded that the district judge correctly overruled Orona's objection and affirmed the judgment. View "United States v. Orona" on Justia Law

On the night of July 18, 2019, in Charlestown, Indiana, bystanders called 911 to report a fight between RJ Slaymaker and his wife, Amylyn Slaymaker. Two police officers responded, separated the couple, and learned from Amylyn that RJ was drunk, had hit her, had guns, and was threatening to kill her and himself. RJ denied the allegations. The officers called an ambulance for RJ to seek mental health help at a hospital but did not place him under a 24-hour mental health hold. RJ left the hospital shortly after arriving, returned home, and killed Amylyn before committing suicide.The administrator of Amylyn’s estate sued Officer Roederer and the estate of Officer Johnson, claiming they created a danger by misleading Amylyn into believing RJ would be held for 24 hours, thus making her believe it was safe to return home. The United States District Court for the Southern District of Indiana granted summary judgment to the defendants, concluding they were entitled to qualified immunity.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s judgment regarding Officer Roederer, finding no evidence of his personal involvement in making assurances to Amylyn. However, the court reversed the judgment regarding Officer Johnson, finding that a jury could reasonably infer that he misled Amylyn about RJ’s detention, creating a danger she would not have otherwise faced. The court held that Officer Johnson’s actions could be seen as a violation of clearly established law under the state-created danger doctrine, as established in Monfils v. Taylor. The case against Officer Johnson’s estate was remanded for further proceedings. View "Rakes v. Roederer" on Justia Law

A student at Rosalind Franklin University was accused of sexual assault by another student after a night of heavy drinking and marijuana use. The accused student, Nicholas Gash, had no memory of the events due to his intoxication. The university conducted an investigation, during which Gash received notices of allegations and participated in interviews. Despite attempting to withdraw from the university, Gash was informed that his withdrawal was not approved, and the Title IX hearing proceeded. The hearing panel found Gash responsible for the alleged assault and sanctioned him with expulsion.The United States District Court for the Northern District of Illinois dismissed Gash’s claims of sex-based discrimination under Title IX and breach of contract under Illinois law. The court found that the procedural errors cited by Gash did not suggest sex-based discrimination. Gash’s state law contract claims were also dismissed, as the court determined that he did not meet the high burden of showing that the university acted arbitrarily or in bad faith.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court affirmed the district court’s dismissal, holding that the procedural errors and alleged biases did not plausibly suggest sex-based discrimination. The court noted that the errors could indicate a pro-victim or pro-complainant bias but not an anti-male bias. Additionally, the court found that Gash did not provide sufficient evidence to support his breach of contract claim, as he failed to show that the university acted without a rational basis or in bad faith. The court concluded that the university’s actions, while flawed, did not constitute sex-based discrimination or breach of contract. View "Gash v. Rosalind Franklin University" on Justia Law