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

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

In January 2015, Sarah Schoper, a tenure-track assistant professor at Western Illinois University, suffered a traumatic brain injury resulting in high-functioning mild aphasia and other physical disabilities. Despite her condition, she returned to teaching in May 2015, with accommodations from the University. Schoper applied for tenure in 2017 but was denied based on her teaching evaluations, which had declined post-injury. She then filed a lawsuit alleging disability discrimination and failure to accommodate under the Americans with Disabilities Act.The United States District Court for the Central District of Illinois granted summary judgment in favor of the University. The court found that Schoper could not prove that her disability was the but-for cause of her negative tenure recommendation. Additionally, the court ruled that Schoper failed to show how her requested accommodation—additional time to meet tenure criteria—would enable her to perform the essential functions of her job.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that Schoper was not a qualified individual under the ADA because her teaching evaluations did not meet the University's tenure requirements. The court also found that her request for more time to achieve tenure was not a reasonable accommodation, as it essentially sought a second chance rather than a modification to enable her to perform her job. Furthermore, the court concluded that no reasonable jury could find that Schoper's disability was the but-for cause of the University's decision to deny her tenure, given the multiple layers of review and the lack of evidence showing discriminatory intent by the reviewers. View "Schoper v. Board of Trustees of Western Illinois University" on Justia Law

In 2005, Full Circle Villagebrook GP, LLC formed a partnership with Protech 2004-D, LLC and AMTAX Holdings 436, LLC to develop and operate an affordable housing project in Illinois. Full Circle, as the General Partner, held a minor ownership stake but had an option to buy out the Limited Partners after 15 years, based on the property's fair market value. The partnership agreement specified that the appraiser for this valuation must be selected from the approved lists of LaSalle Bank or Deutsche Bank Berkshire Mortgage (DBBM). When Full Circle attempted to exercise this option in 2020, it selected an appraiser from the approved lists of the successor banks to LaSalle and DBBM, as the original banks no longer existed.The United States District Court for the Northern District of Illinois granted summary judgment in favor of the Limited Partners and Alden Torch Financial, LLC. The court held that Full Circle did not comply with the partnership agreement's terms, as it did not select an appraiser from the lists of the named banks, nor did it seek the Investor Limited Partner's approval for an alternative appraiser. Consequently, the court denied Full Circle's claims for breach of contract and tortious interference.The United States Court of Appeals for the Seventh Circuit affirmed the district court's judgment. The appellate court agreed that the contract's language was unambiguous and required strict compliance with the specified method for selecting an appraiser. Since Full Circle did not adhere to these terms, it failed to validly exercise its option, and no binding contract was formed. Therefore, the Limited Partners were not in breach, and Full Circle's claims were properly dismissed. View "Full Circle Villagebrook GP, LLC v. Protech 2004-D, LLC" on Justia Law

In February 2020, a police officer in Wauwatosa, Wisconsin, shot and killed a Black teenager, Alvin Cole. Following the incident, community members organized protests against police violence and racism. Anticipating unrest after the district attorney decided not to charge the officer, the mayor imposed a curfew. Plaintiffs, affected by the curfew and police conduct, filed constitutional and state law claims against the City of Wauwatosa and individual defendants.The United States District Court for the Eastern District of Wisconsin dismissed most claims, allowing only First Amendment and Driver’s Privacy Protection Act (DPPA) claims to proceed. The court later granted summary judgment for the defendants on the First Amendment claims, leaving only the DPPA claims for trial. The jury ultimately ruled in favor of the defendants on the DPPA claims.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s rulings, holding that the curfew was a permissible time, place, and manner restriction under the First Amendment. The court found that the curfew was content-neutral, served a significant government interest in public safety, was narrowly tailored, and left open ample alternative channels for communication. The court also upheld the dismissal of the plaintiffs' § 1983 claims against individual defendants, agreeing that the claims were inadequately pleaded and that the district court did not abuse its discretion in denying further amendments. Lastly, the court found no abuse of discretion in the district court’s response to a jury question regarding the definition of “personal information” under the DPPA. The judgment of the district court was affirmed. View "Knowlton v. City of Wauwatosa" on Justia Law