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

In 2015, Giulio Palma and his friend Graham Kos developed a plan to pool investor funds to purchase and develop luxury properties in Italy, with the aim of reselling them or operating short-term rentals. Palma claimed to have exclusive connections enabling access to discounted properties. Over several years, they raised about $6 million from multiple investors, all of whom believed their funds would be used exclusively for acquiring and developing Italian properties. Contrary to his repeated assurances and the terms of their arrangements, Palma withdrew approximately $2 million for personal use, concealing these actions from investors. These unauthorized transactions were discovered in 2019.The United States District Court for the Northern District of Illinois, Eastern Division, indicted Palma on seven counts of wire fraud under 18 U.S.C. § 1343. Following a jury trial in 2023, Palma was convicted on six counts. He moved for a judgment of acquittal and a new trial, but the district court denied both motions, finding that the evidence overwhelmingly supported the jury’s verdict. The district court then sentenced Palma to 36 months in prison.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the denial of the motion for judgment of acquittal de novo, applying the standard for sufficiency of the evidence. The court held that the evidence was more than sufficient for a rational jury to find that Palma engaged in a scheme to defraud and acted with intent to defraud. The Seventh Circuit affirmed the judgment of the district court, upholding both the conviction and the sentence. View "USA v. Palma" on Justia Law

A freshman student at the University of Wisconsin, Madison alleged that she had been sexually assaulted by another student. Upon receiving her complaint, the university provided her academic accommodations, imposed a no-contact order to separate her from the accused student, and expelled him following a disciplinary process that found him responsible for sexual assault and harassment under the university’s policies. The accused was also acquitted of related criminal charges in state court, after which he petitioned for readmission to the university, citing new evidence that had emerged during his trial. The university’s chancellor reviewed the new information, determined that the preponderance of evidence standard was no longer met for the sexual assault finding, and readmitted him. The university maintained the no-contact order but did not implement additional safety measures for the complainant.The United States District Court for the Western District of Wisconsin granted summary judgment for the university, concluding that the university’s actions did not amount to deliberate indifference under Title IX. A panel of the United States Court of Appeals for the Seventh Circuit initially reversed this decision, but the full court granted rehearing en banc and vacated the panel’s opinion.Reviewing the case en banc, the United States Court of Appeals for the Seventh Circuit held that a school is liable under Title IX for student-on-student harassment only if it responds with deliberate indifference—that is, with conduct clearly unreasonable in light of known circumstances. The court found that the university’s actions, including the prompt issuance and enforcement of a no-contact order, the investigation, and the imposition of discipline, constituted a reasonable response. The court also determined that neither the decision to readmit the accused student nor the refusal to implement additional safety measures amounted to deliberate indifference. Accordingly, the court affirmed the district court’s grant of summary judgment for the university. View "Arana v. Board of Regents of the University of Wisconsin" on Justia Law

A participant in two ERISA-qualified retirement plans at a university sought to change the beneficiary designation shortly before his death, naming trust accounts for his grandchildren as primary beneficiaries and removing his wife as a primary beneficiary. The plan documents required spousal consent for such changes. The participant’s wife, who was still living at the time, had previously executed a Wisconsin statutory power of attorney appointing her son-in-law as her agent. The agent signed the spousal consent form on her behalf, but the power of attorney did not expressly grant authority to waive her spousal survivor annuity rights. The plan recordkeeper rejected the beneficiary change form as deficient, and the participant died soon thereafter. The wife died about a year later. The plaintiffs, including family members and trustees, sought to enforce the beneficiary change, arguing that the power of attorney provided sufficient authority.After the recordkeeper’s rejection, the plaintiffs made a claim for benefits with the university as plan administrator. The university denied the claim, determining that Wisconsin law required a specific grant of authority in the power of attorney to waive spousal survivor benefits, which was absent in this case. The plaintiffs appealed the denial, but the university upheld its decision. Plaintiffs then filed suit in the United States District Court for the Northern District of Illinois, asserting claims under ERISA for benefits, breach of fiduciary duty, and negligence. The district court granted summary judgment for the defendants, concluding the waiver was invalid and finding no merit in the other claims.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The Seventh Circuit held that under Wisconsin law, specifically Wis. Stat. § 244.41(1)(f), a power of attorney must expressly grant authority to an agent to waive spousal rights to a joint and survivor annuity. Because the power of attorney did not contain such an express grant, the attempted waiver was invalid, and the plaintiffs’ ERISA claim failed. The court also affirmed dismissal of the fiduciary duty and negligence claims and denied the plaintiffs’ motion to certify a question to the Wisconsin Supreme Court. View "Havlik v. University of Chicago" on Justia Law

Andrew Boltz, age 25, met A.S., a 16-year-old, through the website Omegle in early 2020. Their communication continued across various platforms, including Snapchat, and involved frequent daily contact. Boltz repeatedly requested sexually explicit images and videos from A.S., fully aware of her minor status. A.S. testified that she was uncomfortable with these requests but ultimately sent nude photos. Law enforcement was alerted after A.S.’s mother discovered the relationship, leading to Boltz’s arrest.The United States District Court for the Northern District of Illinois, Eastern Division, presided over Boltz’s jury trial on charges including sexual exploitation of a minor. The court made several key evidentiary rulings: it excluded evidence that A.S. had sent explicit photos to other men under Federal Rule of Evidence 412 (the rape shield rule), allowed the government to introduce Rule 404(b) evidence that Boltz had groomed another minor, and permitted A.S.’s mother to testify about A.S.’s vulnerability. After his conviction, Boltz moved for a new trial, arguing the government failed to preserve exculpatory Snapchat messages. The district court denied the motion, finding no bad faith by the government.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed these rulings. The court held that the district court properly excluded evidence of A.S.’s sexual conduct with others under Rule 412, as it was either sexual behavior or predisposition and not central to Boltz’s defense. The court also found that the Rule 404(b) evidence was properly admitted for the non-propensity purpose of establishing Boltz’s identity, due to the distinctive similarities between the incidents. The court further ruled that A.S.’s mother’s testimony was relevant and that the government did not act in bad faith regarding evidence preservation. The Seventh Circuit affirmed the district court’s decision. View "USA v. Boltz" on Justia Law

A man was convicted of first-degree child sexual assault in Wisconsin after a two-day jury trial. The victim, a minor, had a prior relationship with the defendant, who was not his biological father but remained involved in his life. In late 2014, after the defendant cared for the child during the father’s hospitalization, the child’s behavior changed and troubling statements were made, leading to a report to Child Protective Services (CPS). A police investigation followed, and after a forensic interview in August 2015, the child disclosed inappropriate contact by the defendant, who was then charged with sexual assault.The State made various pre-trial disclosures, including a police report summarizing the CPS report, but did not provide the actual CPS report. At trial, the prosecution relied on testimony from the forensic interviewer, the child, the child’s grandmother, and the investigating officer. The defense had access to the police report but did not use it to impeach the officer’s testimony. The defendant testified and denied the allegations. The jury found him guilty, and he was sentenced to twenty-five years. He moved for postconviction relief, arguing suppression of material evidence and ineffective assistance of counsel. The postconviction court denied relief, but the Wisconsin Court of Appeals reversed. The Wisconsin Supreme Court unanimously reinstated the conviction.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s grant of habeas relief de novo, applying the deferential standard required by the Antiterrorism and Effective Death Penalty Act. The Seventh Circuit held that the Wisconsin Supreme Court reasonably applied federal law in finding that the suppressed CPS report was cumulative of evidence already available to the defense and not material, and that trial counsel’s performance did not prejudice the outcome. The Seventh Circuit reversed the district court’s judgment and denied habeas relief. View "Hineman v. Chase" on Justia Law

Several related companies, along with an individual, operated the Inn of Chicago. After purchasing the property, they assumed an existing collective bargaining agreement (CBA) with a labor union. When the City of Chicago approached them to use the Inn to house displaced migrants, the operation resumed, but the employers did not use union members for typical hotel functions. Instead, these tasks were handled by an outside staffing agency and later by another company managed by the same people. The labor union learned of this arrangement, filed grievances alleging violations of the CBA, and submitted the dispute to arbitration. The union also filed an unfair labor practice charge with the National Labor Relations Board, which was consolidated with the arbitration.The United States District Court for the Northern District of Illinois, Eastern Division, reviewed the arbitration award. The arbitrator had found that the Inn was operating as a “hotel” within the meaning of the CBA while housing migrants, that the related companies and individual were a “single employer” under the CBA, and that they violated both the CBA and the National Labor Relations Act by failing to use union employees and failing to provide notice or bargain with the union. The district court confirmed the arbitration award, rejecting the employers’ arguments regarding arbitrability, notice, and authority.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s confirmation of the arbitration award. The court held that the employers were bound by the arbitration because they participated without reserving objections, and the arbitrator’s findings drew from the CBA and issues submitted by the parties. The court found no due process or public policy violation and affirmed the district court’s confirmation of the award. View "Elmar Hotel Management, LLC v Unite Here Local 1" on Justia Law

Robert Carter, convicted of wire fraud, sought compassionate release from his sentence under 18 U.S.C. § 3582(c)(1)(A), citing family caregiving obligations. The United States District Court for the Western District of Wisconsin denied his motion on February 6, 2026. Carter was required to file a notice of appeal within 14 days, but his notice was postmarked February 27 and received March 2, missing the deadline even under the prison-mailbox rule.Following the denial, Carter did not file a motion for extension of time, which would ordinarily be fatal in civil cases under Federal Rule of Appellate Procedure 4(a)(5). However, Rule 4(b)(4), governing criminal cases, allows the district court to extend the time to appeal “with or without motion” for up to 30 days after the deadline. Carter argued that the district judge implicitly granted an extension by docketing his late notice of appeal, but the court found this reasoning unpersuasive, emphasizing that docketing is a ministerial act and does not imply a judicial finding of excusable neglect or good cause.The United States Court of Appeals for the Seventh Circuit reviewed the matter. Adopting the consensus of other circuits, the court held that if a notice of appeal in a criminal case is filed within the 30-day extension window, the appeal should not be dismissed until the district judge has made a finding regarding excusable neglect or good cause, even without a formal motion for extension. Accordingly, the Seventh Circuit suspended further proceedings and remanded the issue to the district court for a determination on whether Carter’s delay was justified. View "USA v Carter" on Justia Law

Segerdahl Corporation, a direct-mail printing company wholly owned by an employee stock ownership plan (ESOP), was sold to a private equity firm in 2016. Bruce Rush, a senior manager and ESOP shareholder, alleged that the sale was improperly organized and approved for less than the company’s fair market value. He claimed that the Defendants—the ESOP trustee GreatBanc and several Segerdahl Board members—breached their fiduciary duties under ERISA by favoring financial buyers, inadequately marketing the company, and failing to secure a higher sale price. The sale process involved negotiations led by JP Morgan, with only financial buyers considered, culminating in an agreement with ICV Partners for $265 million.The United States District Court for the Northern District of Illinois, Eastern Division, certified a class of ESOP shareholders and denied summary judgment for most claims. After a three-week bench trial, the district court issued a comprehensive opinion finding in favor of Defendants on all counts. The court determined that the Defendants did not intentionally depress the sale price, had obtained the best possible price given Segerdahl’s declining performance, and had fulfilled their fiduciary obligations. The district court also found no prohibited transactions under ERISA and concluded that Rush failed to prove damages, rejecting expert testimony that relied on hypothetical buyers and unsupported valuations.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s legal conclusions de novo and factual findings for clear error. The appellate court affirmed the district court’s judgment, holding that there was no clear error in the findings that Defendants did not breach their fiduciary duties, did not engage in prohibited transactions, and that the sale price reflected fair market value. The district court’s decision was affirmed in full. View "Rush v GreatBanc Trust Co." on Justia Law

A mother, Jacqueline, who is an Illinois police officer, and her son John, who lived in Indiana, were the subjects of criminal allegations after a local resident reported that someone at their home pointed a gun at children walking home from school. Three St. John, Indiana police officers responded and gathered witness statements, some of which vaguely described the suspect and referred to a gun that appeared to be a BB or pellet gun. The officers questioned Jacqueline and John, who admitted to handling an airsoft gun but denied aiming it at anyone. Without making arrests, the officers later pursued criminal charges: John was accused of intimidation with a deadly weapon, and Jacqueline was cited for allegedly permitting the discharge of a pellet gun within town limits. Ultimately, the prosecutor declined to pursue John’s charge, and Jacqueline’s citation was dismissed.Jacqueline filed suit in the United States District Court for the Northern District of Indiana, asserting federal claims under 42 U.S.C. § 1983 for malicious prosecution, false arrest, failure to intervene, and abuse of process, along with a state indemnification claim. The district court dismissed the case and denied leave to amend the complaint to add class-of-one equal protection claims, finding them futile because the officers purportedly had probable cause.The United States Court of Appeals for the Seventh Circuit reviewed the case. It affirmed the dismissal of the malicious prosecution, false arrest, failure-to-intervene, abuse-of-process, and municipal claims. However, it held that the district court erred in denying leave to amend to add class-of-one equal protection claims, as the proposed amended complaint did not conclusively establish probable cause and plausibly alleged differential treatment based on animus. The court reversed in part and remanded, allowing the equal protection claims to proceed, and ordered the state indemnification claim dismissed without prejudice. View "Agee v Hickenbottom" on Justia Law

The plaintiff, an African American clinical pharmacist, worked at a Department of Veterans Affairs facility in Illinois. He was the only African American pharmacist at his workplace and was employed on a yearlong probationary period. After receiving a “fully successful” performance review, his new supervisor criticized his productivity, which later improved. The plaintiff filed an internal Equal Employment Opportunity (EEO) complaint alleging race-based disparate treatment and retaliation by his supervisor, referencing racially charged remarks and disparate scrutiny. Weeks after the complaint, the department received anonymous reports of several medication errors allegedly committed by the plaintiff. He admitted to most of these errors in a subsequent investigatory meeting. Days after mediation regarding his EEO complaint, which he voluntarily withdrew, the plaintiff was terminated just before his probationary period ended.The United States District Court for the Northern District of Illinois granted summary judgment for the Department, dismissing both the race discrimination and retaliation claims. The district court found that the plaintiff failed to establish a prima facie case of race discrimination, as there was no evidence he was treated less favorably than similarly situated employees outside his protected class. The court also concluded that the Department’s stated reasons for termination—medication errors—were legitimate and not shown to be pretextual. The retaliation claim was rejected for lack of evidence showing a causal connection between the EEO complaint and his termination.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court’s judgment. The appellate court held that the plaintiff failed to provide evidence that the Department’s stated nondiscriminatory reason for his termination was pretextual or that his protected activity was the but-for cause of his termination. The judgment for the Department was affirmed. View "Abayomi v Collins" on Justia Law