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

Gary Wilson was previously convicted under Illinois law for possession of child pornography, a statute that criminalizes possession of sexually explicit images of minors as well as individuals with severe or profound intellectual disabilities. Nearly twenty years later, Wilson used gaming systems and social media to solicit sexually explicit images from minors, leading to his guilty plea on two counts of production of child pornography under federal law.At sentencing in the United States District Court for the Northern District of Illinois, Western Division, the government argued that Wilson’s prior Illinois conviction triggered a federal sentencing enhancement under 18 U.S.C. § 2251(e), which increases the mandatory minimum and maximum sentences for defendants with a prior conviction “relating to” possession of child pornography. Wilson’s attorney did not object to the application of this enhancement, and the district court imposed a sixty-year sentence.On appeal to the United States Court of Appeals for the Seventh Circuit, Wilson argued for the first time that the Illinois statute was broader than the federal definition because it also covered images of adults with certain disabilities, and therefore should not trigger the federal enhancement. The Seventh Circuit reviewed the issue for plain error due to Wilson’s failure to object below. The court held that, under the plain error standard, it was not “clear or obvious” that the Illinois statute did not “relate to” the possession of child pornography as required by § 2251(e), especially given the broad language Congress used and existing circuit precedent. Therefore, the Seventh Circuit affirmed the district court’s application of the sentencing enhancement and Wilson’s sentence. View "USA v Wilson" on Justia Law

Eddie Bolden was arrested in 1994 for double murder and attempted murder, convicted by a jury in 1996, and sentenced to life in prison. After more than 22 years incarcerated, his conviction was vacated by Illinois courts in 2016 due to ineffective assistance of counsel, and the State dismissed all charges, leading to his immediate release. Bolden subsequently filed a civil rights lawsuit under 42 U.S.C. § 1983 against the City of Chicago and several police officers, alleging constitutional and state law violations stemming from his wrongful conviction and imprisonment.The case was heard in the United States District Court for the Northern District of Illinois, Eastern Division. After delays, including judicial reassignment and the COVID-19 pandemic, the trial occurred in October 2021. The jury found in Bolden’s favor, awarding $25 million in compensatory damages for pain, suffering, and loss of normal life, plus punitive damages against two individual defendants. The district court later granted Bolden’s motion to amend the judgment to include $7.6 million in prejudgment interest, calculated from the date his conviction was vacated to the entry of final judgment.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether prejudgment interest could be awarded on noneconomic damages and whether the district court abused its discretion in granting the interest. The Seventh Circuit held that prejudgment interest is available as a matter of law for noneconomic damages in federal civil rights cases, reaffirming its precedent. However, the court found that interest should only be awarded on past damages, not future damages, and remanded for the district court to apportion the jury’s verdict accordingly. In all other respects, the district court’s judgment was affirmed. View "Bolden v. Pesavento" on Justia Law

Two psychiatrists challenged the practices of the American Board of Psychiatry and Neurology (ABPN), alleging that ABPN unlawfully tied its specialty certification to its maintenance of certification (MOC) product, thereby violating antitrust law and causing unjust enrichment. The plaintiffs argued that ABPN’s monopoly over specialty certifications forced doctors to purchase the MOC product, which includes both activity and assessment requirements, in order to maintain their professional standing and employment opportunities. They claimed that the MOC product functioned as a substitute for other continuing medical education (CME) products required for state licensure, and that this arrangement harmed competition in the CME market.The United States District Court for the Northern District of Illinois dismissed the plaintiffs’ second amended complaint with prejudice. The district court found that the plaintiffs failed to plausibly allege an illegal tying arrangement under Section 1 of the Sherman Act, specifically because they did not show that ABPN’s MOC product was a viable substitute for other CME products. The court also concluded that the plaintiffs had multiple opportunities to amend their complaint and had not demonstrated how further amendment would cure the deficiencies.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the dismissal de novo and affirmed the district court’s decision. The Seventh Circuit held that the plaintiffs did not plausibly allege that psychiatrists and neurologists view ABPN’s MOC product as reasonably interchangeable with other CME offerings. The court found that, even if MOC participation could partially or fully satisfy state CME requirements, the additional time, cost, and effort required by the MOC program made it implausible that doctors would choose MOC over other CME products. The court also upheld the district court’s decision to dismiss the complaint with prejudice, finding no abuse of discretion. View "Lazarou v. American Board of Psychiatry and Neurology" on Justia Law

Andrew Johnston was convicted by a jury of attempted bank robbery and sentenced to 168 months in prison. While awaiting transfer to federal prison, Johnston reported to authorities that a fellow inmate, a Sinaloa Cartel leader, had ordered a hit on another inmate. Johnston assisted law enforcement by recording a conversation with the cartel leader and later testified at the cartel leader’s sentencing hearing. Although the judge in that case did not credit Johnston’s testimony, the recorded conversation was considered in sentencing the cartel leader. In recognition of Johnston’s assistance, the government moved for a 25% reduction in his sentence under Rule 35(b) of the Federal Rules of Criminal Procedure, but the motion was filed more than two years after Johnston’s sentencing.The United States District Court for the Northern District of Illinois, Eastern Division, addressed the government’s untimely Rule 35(b) motion, accepting the government’s waiver of the one-year time limit. The judge found Johnston’s cooperation useful but determined that his repeated frivolous postconviction litigation undermined any inference of genuine acceptance of responsibility. As a result, the court granted only a 10% reduction, lowering Johnston’s sentence to 151 months, rather than the 25% requested.On appeal, the United States Court of Appeals for the Seventh Circuit first considered whether the district court had jurisdiction to entertain the untimely Rule 35(b) motion. The Seventh Circuit held that the one-year time limit in Rule 35(b)(1) is a nonjurisdictional claim-processing rule, which may be waived, overruling its prior decision in United States v. McDowell. The court further held that no legal rule barred the district judge from considering Johnston’s postconviction litigation conduct in evaluating his acceptance of responsibility. The court affirmed the district court’s decision to grant only a 10% sentence reduction. View "USA v Johnston" on Justia Law

Delta Airlines contracted with Lands’ End to supply new uniforms for its employees, which were manufactured overseas and distributed to approximately 64,000 workers. After the uniforms were issued, many employees reported that the garments transferred dye onto other surfaces and caused a range of health symptoms, including skin irritation and respiratory issues. Two groups of Delta employees filed lawsuits: one group sought damages for property damage and breach of express warranty as intended beneficiaries of the contract between Delta and Lands’ End, while the other group pursued personal injury claims, alleging the uniforms were defectively manufactured or designed and that Lands’ End failed to warn of these defects.The United States District Court for the Western District of Wisconsin consolidated the actions and, after discovery, granted summary judgment in favor of Lands’ End on all claims. For the personal injury claims, the court excluded the plaintiffs’ expert testimony on defect and causation, finding the opinions unreliable under Federal Rule of Evidence 702 and Daubert v. Merrell Dow Pharmaceuticals, Inc. The court also found that the plaintiffs failed to present sufficient evidence that the uniforms were defective or that any defect caused their injuries. On the breach of warranty claim, the court determined that Lands’ End had not breached the contract’s satisfaction guarantee because plaintiffs had not returned their uniforms as required by the contract’s terms.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The Seventh Circuit held that the exclusion of the plaintiffs’ expert testimony was not an abuse of discretion, as the experts failed to reliably establish defect or causation. The court also held that summary judgment on the breach of warranty claim was proper because the contract’s return requirement was reasonable and not an unlawful limitation on the express warranty. The district court’s judgment was affirmed in full. View "Gilbert v Lands' End, Inc." on Justia Law

A 69-year-old employee of the Cook County Sheriff’s Office, who previously had a long career with the Chicago Police Department, was terminated from his position as Assistant Chief of the Electronic Monitoring Unit. The termination followed an internal investigation into his work performance, which included allegations that he was absent from his post without authorization, failed to communicate with his team, and used work hours and resources for personal business. The investigation, initiated after a complaint by his supervisor, involved interviews with colleagues and a review of GPS and work records, ultimately concluding that he had neglected his duties on multiple occasions.After his termination, the employee filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, against his supervisor in her individual capacity and the Sheriff in his official capacity, alleging age discrimination under the Fourteenth Amendment (via 42 U.S.C. § 1983), the Age Discrimination in Employment Act (ADEA), and the Illinois Human Rights Act (IHRA). He also brought an indemnification claim against Cook County. During discovery, he presented affidavits from other older officers alleging ageist comments and discriminatory treatment by the same supervisor. The district court granted summary judgment for all defendants, finding insufficient evidence of age-based disparate treatment or causation.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The appellate court held that the plaintiff failed to identify similarly situated comparators who were treated more favorably, and that the evidence did not support a finding that any alleged discriminatory animus by the supervisor proximately caused the termination. The court also found that the internal investigation and the ultimate decisionmaker’s independent review provided legitimate, non-discriminatory reasons for the termination, precluding liability under the Fourteenth Amendment, ADEA, and IHRA. View "Gaines v Dart" on Justia Law

Bernard Mims spent a decade in prison after being convicted of murder, a conviction later vacated when the State’s Attorney’s Office lost confidence in the case for reasons unrelated to the claim at issue here. Mims then brought a civil rights lawsuit under 42 U.S.C. § 1983 against the City of Chicago and several police detectives. He alleged, among other things, that two detectives violated his due process rights by failing to disclose an audio recording of a conversation between two individuals, one of whom had previously claimed involvement in the murder. Mims argued that this recording was exculpatory because it implicated someone else in the crime.The United States District Court for the Northern District of Illinois granted summary judgment to the defendants on all claims. As relevant to this appeal, the district court found that Mims had not produced evidence showing that the detectives concealed or withheld the recording from the prosecutor. The court also concluded that the recording was not material under Brady v. Maryland, and, alternatively, that the detectives were entitled to qualified immunity.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision de novo. The appellate court held that Mims failed to present evidence that the detectives intentionally or recklessly concealed the recording from the prosecution. The court emphasized that the prosecutor had knowledge of and access to the recordings through the court file and that the duty to disclose exculpatory evidence primarily rests with the prosecution. Because Mims could not show suppression by the detectives, the Seventh Circuit affirmed the district court’s grant of summary judgment in favor of the defendants. View "Mims v City of Chicago" on Justia Law

A prisoner in the Illinois Department of Corrections was issued two disciplinary tickets for alleged gang affiliation after a gang-related questionnaire, purportedly filled out by him, was found in another inmate’s belongings. The first ticket was dismissed after a hearing, but a second, nearly identical ticket was issued shortly thereafter, leading to his immediate placement in segregation. The second ticket included additional allegations, such as handwriting analysis and claims of self-admitted gang membership. The prisoner remained in segregation for three months under conditions he described as inhumane, including exposure to mold, mildew, insects, rust, and leaking sewage. He filed grievances challenging the process and the conditions, and the ticket was eventually expunged for failure to follow internal procedures, but only after he had served the segregation term.The United States District Court for the Southern District of Illinois granted summary judgment to the defendants, holding that even if there were factual disputes about whether the prisoner was denied witnesses, he had not demonstrated that the conditions of segregation constituted an “atypical and significant hardship” sufficient to implicate a protected liberty interest under the Due Process Clause.On appeal, the United States Court of Appeals for the Seventh Circuit assumed, without deciding, that the prisoner’s conditions in segregation established a liberty interest. However, the court held that, under its recent precedent in Adams v. Reagle, prisoners who do not face the loss of good-time credits or other sentence-lengthening punishments are entitled only to informal, nonadversarial due process. The court found that the prisoner received the required process: notice of the charges, an opportunity to respond, and an impartial decisionmaker. Accordingly, the Seventh Circuit affirmed the district court’s judgment. View "Torres v Brookman" on Justia Law

Kenneth Courtright operated Today’s Growth Consultant (TGC), also known as The Income Store, which promised investors guaranteed, perpetual monthly payments based on website advertising revenue. Investors, called “site partners,” paid upfront fees under Consulting Performance Agreements (CPAs), which stated that these fees would be used exclusively for website-related expenses and that TGC was in satisfactory financial condition. In reality, TGC’s advertising revenue and business loans were insufficient to meet its payment obligations, and Courtright used new investors’ upfront fees to pay existing investors, misrepresenting the company’s financial health and the use of funds.The United States District Court for the Northern District of Illinois, Eastern Division, presided over Courtright’s criminal trial for seven counts of wire fraud. The government presented evidence of TGC’s financial shortfall and improper use of upfront fees, including testimony from employees and financial experts. The jury convicted Courtright on all counts. At sentencing, the parties debated the loss calculation, with the court ultimately adopting a $69.3 million loss figure and granting certain deductions, resulting in a final loss amount of $52.5 million. Courtright was sentenced to 90 months in prison and two years of supervised release.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed Courtright’s challenges to the sufficiency of the evidence and the loss calculation. The court held that the evidence was sufficient for a rational jury to find Courtright guilty of wire fraud, as he made material false statements about the use of upfront fees and TGC’s financial condition, and acted with intent to defraud. The court also found that Courtright waived his causation argument regarding loss calculation and that the district court did not clearly err in denying deductions for operating expenses. The Seventh Circuit affirmed the conviction and sentence. View "USA v Courtright" on Justia Law

A young music producer created an instrumental hip-hop beat and uploaded it online without first obtaining a copyright. After hearing a similar beat in a popular song by a well-known rapper, he registered a sound recording copyright for his track and later sued the rapper for copyright infringement, seeking damages and an injunction. The plaintiff alleged that the defendant had copied his digital recording, but did not obtain a musical composition copyright, which would have protected the underlying musical elements.In the United States District Court for the Northern District of Illinois, both parties failed to comply with local rules regarding summary judgment filings. The district court, exercising its discretion, chose not to penalize either side for these procedural lapses. On the merits, the court found that the plaintiff had not provided sufficient evidence to show that the defendant had duplicated the actual digital sound recording, as opposed to merely imitating the musical composition. The court granted summary judgment in favor of the defendant. The court also awarded costs to the defendant but denied his request for attorney’s fees, finding the plaintiff’s claims were not frivolous or objectively unreasonable.The United States Court of Appeals for the Seventh Circuit reviewed the case. It affirmed the district court’s decisions on all issues. The appellate court held that, for a sound recording copyright infringement claim, a plaintiff must present evidence of actual duplication of the digital recording, not just imitation of the musical composition. Because the plaintiff failed to provide such evidence, summary judgment for the defendant was proper. The appellate court also affirmed the district court’s discretionary decisions regarding enforcement of local rules and denial of attorney’s fees. View "Richardson v. Kharbouch" on Justia Law