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

In June 2021, police officers in Aurora, Illinois responded to a 911 call from a woman who reported, based on information from her nephew, that Antron Cannon was violently assaulting a woman inside his home. Officers arrived to find Cannon and a companion inside the house. There were discrepancies between Cannon’s account and that of other witnesses regarding what occurred, but responding officers heard loud noises, received confirmation that no one had left the home, and were told a side door was unlocked. They entered the home without a warrant, detained Cannon, and interviewed his companion, who alleged that Cannon had assaulted her. Physical evidence of injuries was documented, and Cannon was arrested for domestic battery, though the charges were later dropped.The United States District Court for the Northern District of Illinois, Eastern Division, reviewed Cannon’s subsequent civil lawsuit against the officers and the city. Cannon claimed the officers unlawfully entered his home and arrested him without probable cause. The district court granted summary judgment for the defendants, concluding that exigent circumstances justified the warrantless entry and probable cause supported the arrest. The court also dismissed Cannon’s indemnification claim against the city and awarded defendants their costs, rejecting Cannon’s argument that his indigency should exempt him from the cost award.The United States Court of Appeals for the Seventh Circuit reviewed the appeal. The appellate court affirmed the district court’s decisions. It held that the officers’ warrantless entry was reasonable under the emergency aid exception to the Fourth Amendment, given the information available to them at the time. It further held that probable cause existed for Cannon’s arrest based on statements and observed injuries. Finally, it found no abuse of discretion in awarding costs, as Cannon did not demonstrate inability to pay now or in the future. View "Cannon v. Filip" on Justia Law

A former lieutenant in a county sheriff’s office was accused of using excessive force during two arrests. After an internal investigation was initiated, he was suspended and scheduled for a public hearing before a merit board, which is required under Indiana law for disciplinary actions. The lieutenant alleged that the sheriff manipulated both the investigation and the merit board to ensure an unfavorable outcome for him. Faced with the possibility of an unfair hearing and negative publicity, the lieutenant negotiated a severance agreement with the sheriff: he would resign and waive his hearing in exchange for withdrawal of the charges and a promise of a neutral reference.Despite the agreement, on the day the resignation became effective, two county prosecutors and the sheriff broadly disclosed the excessive-force allegations to local legal professionals and the lieutenant’s current and prospective employers, including through Brady/Giglio disclosures. The disclosures described the alleged misconduct and claimed issues with the lieutenant’s credibility, leading to his suspension from his part-time job and the loss of other employment opportunities. The lieutenant claimed these actions were part of a premeditated scheme to render him unemployable in law enforcement.In the United States District Court for the Northern District of Indiana, the complaint was dismissed. The district court found that absolute and qualified immunity protected the prosecutors and that the sheriff could not be liable because the lieutenant had voluntarily resigned, waiving his due process rights. On appeal, the United States Court of Appeals for the Seventh Circuit held that the prosecutors were entitled to absolute immunity only for Brady/Giglio disclosures made in pending criminal cases. For disclosures to the bar association and employers, neither absolute nor qualified immunity applied at this stage because the alleged coercion through misrepresentation could constitute a procedural due process violation. The appellate court reversed in part, affirmed in part, and remanded for further proceedings. View "Martin v. Goldsmith" on Justia Law

37celsius Capital Partners, a Milwaukee-based firm specializing in healthcare-related businesses, sought to acquire Care Innovations, a subsidiary of Intel Corporation. The parties entered into a nondisclosure agreement containing a “Hold Harmless” clause that limited damages, and subsequently executed a term sheet outlining the proposed transaction. The term sheet required 37celsius to contribute $12 million by a specified closing date and granted it an exclusivity period during which Intel could not negotiate with other parties regarding Care Innovations. The term sheet expressly limited legal obligations, stating that no binding contract would exist until a definitive agreement was executed, except for certain provisions such as confidentiality and exclusivity.After 37celsius failed to provide proof of the required funds by the closing date, Intel sold Care Innovations to another buyer. 37celsius filed suit in Wisconsin state court, alleging breach of contract based on Intel’s communications with third parties during the exclusivity period. The defendants removed the case to the United States District Court for the Eastern District of Wisconsin, which ruled that 37celsius was not entitled to expectation damages under the NDA and subsequently granted summary judgment for Intel, finding no reliance damages and no evidence of causation.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s summary judgment de novo. It held that the term sheet was not a binding “Type II” preliminary agreement under Delaware law, as its language did not obligate the parties to negotiate in good faith. Further, even if a binding obligation existed, 37celsius could not show that Intel’s alleged breach was the but-for cause of the failed transaction, as 37celsius did not have the required funds. The court also concluded that the NDA barred expectation damages and 37celsius did not appeal the denial of reliance damages. The Seventh Circuit affirmed the district court’s judgment for Intel. View "37celsius Capital Partners, L.P. v Intel Corporation" on Justia Law

Israel Ruiz was convicted by an Illinois jury of first-degree murder and aggravated discharge of a firearm for an offense he committed at age 18 in 1998. In 2000, he received a 40-year prison sentence without the possibility of parole for murder and a concurrent 15-year sentence for the firearm offense. In 2019, Illinois enacted a law (Public Act 100-1182) allowing parole eligibility for young adults convicted of first-degree murder committed under age 21, but only for those sentenced on or after June 1, 2019. Ruiz, sentenced before that date, is ineligible for parole under the Act.Ruiz filed a lawsuit under 42 U.S.C. § 1983 in the United States District Court for the Northern District of Illinois, Eastern Division, against Illinois’s governor and other state officials. He alleged that the Act’s prospective application violated his rights under the Equal Protection Clause and the Eighth Amendment. The district court granted the defendants’ motion to dismiss, holding that established Seventh Circuit precedent foreclosed Ruiz’s Fourteenth Amendment claim and that the Act’s prospective-only application did not render his sentence cruel or unusual under the Eighth Amendment. Ruiz appealed.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s dismissal de novo. It held that the Act’s limitation to offenders sentenced on or after its effective date did not violate the Equal Protection Clause, as rational-basis review permits such prospective legislative distinctions, consistent with prior circuit decisions such as United States v. Speed and United States v. Sanders. The court also held that Ruiz’s sentence was not unconstitutional under the Eighth Amendment, as Supreme Court precedent limiting life without parole for offenders under 18 did not apply to Ruiz. The Seventh Circuit affirmed the district court’s judgment. View "Ruiz v. Pritzker" on Justia Law

Federal agents arrested a defendant after he engaged in explicit online communications with an undercover agent posing as the father of an eight-year-old girl. Over several months, the defendant requested sexually explicit images of the fictitious child, instructed the agent on how to sedate her to facilitate the abuse, and provided detailed suggestions about the nature of the photographs. The defendant attempted to access links purported to contain the requested images, which were in fact fake and used to record his attempts.A grand jury indicted the defendant on three counts: attempted enticement of a minor to engage in criminal sexual activity, attempted sexual exploitation of a child for the purpose of producing a visual depiction, and attempted receipt of child pornography. At trial in the United States District Court for the Central District of Illinois, the government presented evidence through two FBI agents. After the government rested, the court granted the defendant’s motion for acquittal on the enticement charge but denied it on the other two; the defendant was convicted by a jury on attempted sexual exploitation and attempted receipt of child pornography and was sentenced to 180 months, the statutory minimum for the exploitation charge.The United States Court of Appeals for the Seventh Circuit reviewed the conviction for attempted sexual exploitation. The court held that the defendant’s sufficiency-of-the-evidence challenge was preserved and, viewing the evidence in the light most favorable to the government, found sufficient evidence to support the conviction beyond a reasonable doubt. The court further held that the jury was properly instructed that conviction under 18 U.S.C. § 2251(a) does not require direct communication with a minor, and that the statute covers conduct involving an intermediary. The court affirmed the judgment of the district court. View "USA v Carpenter" on Justia Law

Stericycle, Inc. reorganized its sales department in 2021, creating a new position called Key Account Director (KAD) in both its national and hospital divisions. Cheryl Lane and Adrienne Hause, both female employees, were promoted to the National KAD role. Prior to being promoted, Lane and Hause were National Account Managers with base salaries of $92,784 and $95,026. After expressing concerns about salary disparities between themselves and male Hospital KADs, they received raises increasing their salaries to $98,000. The male Hospital KADs, some promoted and some transferred, generally received higher salaries, with promoted males receiving immediate raises and transferred males retaining their previous, often higher, salaries.The United States District Court for the Northern District of Illinois, Eastern Division, granted summary judgment to Stericycle, finding that Lane and Hause had established a prima facie case under the Equal Pay Act but that Stericycle’s pay practices were justified by a sex-neutral factor: prior salary history. The court found Stericycle had satisfied its affirmative defense for all comparators, concluding that salary disparities were not based on sex. The court also granted summary judgment on the Title VII claim, holding that Lane and Hause had failed to show intentional discrimination.On appeal, the United States Court of Appeals for the Seventh Circuit found genuine disputes of material fact regarding whether Lane and Hause received raises at the time of promotion, as their male counterparts did. The court held that summary judgment was improper in relation to the two promoted male Hospital KADs, as Stericycle failed to prove its affirmative defense as a matter of law, and there was a material factual dispute as to pretext under Title VII. The Seventh Circuit reversed the district court’s judgment and remanded the case for further proceedings. View "Lane v Stericycle, Inc." on Justia Law

Julius Robinson was convicted of murders committed during drug offenses and sentenced to death in the Northern District of Texas. His convictions and sentences were affirmed on direct appeal by the United States Court of Appeals for the Fifth Circuit. Robinson then filed a petition under 28 U.S.C. §2255, which was denied by the United States District Court for the Northern District of Texas, and the Fifth Circuit denied him a certificate of appealability. Subsequent efforts to reopen his case were treated as requests to file second or successive §2255 petitions, which were also denied.After these unsuccessful attempts, Robinson sought habeas relief under 28 U.S.C. §2241 in the United States District Court for the Southern District of Indiana, where he was incarcerated. He raised five issues, including claims about the jurisdiction of the trial court, alleged prosecutorial misconduct, ineffective assistance of trial counsel, and violations of his rights under the American Declaration of the Rights and Duties of Man. The district court dismissed Robinson’s §2241 petition, holding that §2255(e) barred review because Robinson had not shown that the remedy under §2255 was inadequate or ineffective, referencing the Supreme Court’s decision in Jones v. Hendrix.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that, under Jones and its own recent decision in Agofsky v. Baysore, §2255(e) does not permit a federal prisoner to seek relief under §2241 merely because he cannot satisfy the requirements for filing a second or successive §2255 motion, unless the sentencing court is unavailable. The Seventh Circuit further clarified that prior circuit decisions allowing such claims under §2241 are no longer authoritative. The court also rejected Robinson’s Suspension Clause argument and affirmed the district court’s dismissal of the petition. View "Robinson v. Lammer" on Justia Law

Karl Rabenhorst, a former Navy officer employed by FEMA, alleged that he was subjected to age and sex discrimination, a hostile work environment, and retaliation after being removed from a Puerto Rico disaster relief operation and later suspended without pay. The incidents leading to these adverse actions included reprimands for inappropriate interactions with state officials and insubordination, such as sending unauthorized emails and making disrespectful remarks. During the Puerto Rico deployment, Rabenhorst used derogatory language toward younger female coworkers, which prompted his removal from the operation.After his removal, Rabenhorst filed internal complaints, including a grievance with the DHS Office of Equal Rights, alleging discrimination and retaliation. FEMA investigated and ultimately denied his claims, issuing a final agency decision in 2021. Rabenhorst then brought suit in the United States District Court for the Northern District of Illinois, Eastern Division, asserting violations of Title VII and the Age Discrimination in Employment Act (ADEA).The United States District Court for the Northern District of Illinois granted summary judgment for the Secretary of Homeland Security, finding that Rabenhorst failed to establish a prima facie case of discrimination, as he did not meet his employer’s legitimate expectations and could not show that similarly situated employees outside his protected classes were treated more favorably. The court also concluded that Rabenhorst provided no evidence of an objectively hostile work environment or that any adverse conduct was based on his age or sex. Regarding retaliation, the court found no causal link between his protected activity and the suspension decision. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision de novo and affirmed, holding that Rabenhorst did not provide sufficient evidence to support claims of discrimination, hostile work environment, or retaliation. View "Rabenhorst v. Noem" on Justia Law

Ramona Milam, an Illinois homeowner, obtained a mortgage loan in 2005 and later fell behind on her payments. Selene Finance, acting as the loan servicer since 2021, sent Milam a letter warning of possible acceleration and foreclosure if she did not cure her default within 35 days. Milam argued that, due to federal regulations and Selene’s internal practices, Selene would not actually seek foreclosure or acceleration until at least 120 days of delinquency, making the letter’s threat misleading and intended to spur premature payment. After making a payment, Milam sued Selene, alleging violations of the Fair Debt Collection Practices Act and Illinois law, and claimed negligent misrepresentation.Selene moved to dismiss the complaint in the United States District Court for the Northern District of Illinois, Eastern Division, arguing that, as the lender’s assignee under the mortgage, it was entitled to notice and an opportunity to cure before being sued. The district court agreed, finding Selene to be an assignee and holding that Milam failed to comply with the mortgage’s notice and cure provision, thus barring her claims. The court also dismissed Milam’s state law claims for lack of pleaded pecuniary loss.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether Milam had standing and whether Selene was properly considered an assignee under Illinois law. The court found Milam had standing based on supplemental allegations of monetary harm from accelerated payment. However, the Seventh Circuit held that the pleadings did not establish Selene as an assignee under Illinois law, distinguishing between assignment and delegation of duties. The Seventh Circuit reversed the district court’s dismissal and remanded the case for further proceedings to resolve the assignee issue and reconsider the state law claims. View "Milam v Selene Finance" on Justia Law

Alfredo Juarez-Perez, a citizen of Mexico, was arrested in Sun Prairie, Wisconsin, after illegally reentering the United States for the third time. His criminal history spans decades, including multiple state convictions for sexual assault, failure to register as a sex offender, operating while intoxicated, and federal convictions for distributing cocaine and illegal reentry. He has repeatedly used aliases to elude law enforcement and violated conditions of release by failing to appear for legal proceedings. Upon his most recent arrest, U.S. Immigration and Customs Enforcement (ICE) lodged a detainer against him, and he was indicted for illegal reentry in October 2025.A magistrate judge in the United States District Court for the Western District of Wisconsin initially ordered Juarez-Perez released pending trial, reasoning that the ICE detainer eliminated the risk of flight because he would remain in government custody. The magistrate judge indicated that, absent the detainer, Juarez-Perez would pose a serious risk of flight under the Bail Reform Act. The government appealed this decision, and the district court revoked the release order, finding that Juarez-Perez’s criminal history, likely incentive to consent to deportation, repeated illegal reentries, and use of fraudulent documents presented a serious risk of flight. The district court concluded that no conditions could reasonably assure his appearance in court.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision and affirmed the denial of Juarez-Perez’s motion for release pending trial. The Seventh Circuit held that the presence of an ICE detainer does not preclude pretrial detention under the Bail Reform Act, and that Juarez-Perez’s history demonstrated a serious risk of flight and non-appearance. The court found that no conditions of release would reasonably assure his appearance, and accordingly denied his motion for release. View "USA v Juarez-Perez" on Justia Law