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

Michael Connor was convicted in 2013 after a bench trial in Livingston County, Illinois, of five counts of predatory criminal sexual assault of a child. The offenses involved his daughter and stepdaughter, occurring when they were between five and seven years old. The statutory penalty was six to sixty years per count, to be served consecutively, but if convicted of assaulting multiple victims, the law required a mandatory life sentence. After his conviction, Connor received the mandatory life term.After his direct appeal was unsuccessful, Connor pursued postconviction relief in Illinois state court, arguing that his trial counsel was constitutionally ineffective during plea negotiations by failing to inform him that he faced a mandatory life sentence. He claimed this omission led him to reject an 18-year plea offer. At an evidentiary hearing, Connor testified that he would have accepted the plea had he known about the life sentence. The trial judge, however, found this testimony not credible, noting that Connor had repeatedly asserted his innocence and had unequivocally stated at sentencing that he would not have pleaded guilty even if aware of the outcome. The trial court denied postconviction relief, and the Illinois Appellate Court affirmed, finding no reasonable probability that Connor would have accepted the plea but for counsel’s alleged errors.Connor then sought federal habeas relief in the United States District Court for the Central District of Illinois, which was denied. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the denial. The Seventh Circuit held that federal habeas relief was not warranted because Connor failed to rebut, by clear and convincing evidence, the state court's credibility finding that he would not have accepted the plea. The judgment of the district court was affirmed. View "Connor v. Greene" on Justia Law

Elizabeth Chitwood worked as a human resources specialist for Ascension and was granted intermittent Family and Medical Leave Act (FMLA) leave for migraines in 2021, which she was required to report on the same day to a third-party administrator, Sedgwick, and to notify her supervisor as soon as practicable. She also received approval for continuous FMLA leave to care for her son from August 31 to November 3, 2021. After her continuous leave ended, Chitwood did not return to work despite explicit instructions and warnings from Ascension. She instead applied for a personal leave, which was denied, and ultimately left a voicemail on November 15, 2021, implying she believed she had been terminated. Ascension terminated her that day for failure to return to work. The following day, Chitwood attempted to retroactively report intermittent FMLA leave for absences on November 11, 12, and 15, but Ascension rejected these requests since she was already terminated.Chitwood filed suit against Ascension in the United States District Court for the Southern District of Indiana, alleging interference with her FMLA rights and retaliation for using FMLA leave. The district court granted summary judgment for Ascension, finding no reasonable jury could rule in Chitwood’s favor. The court concluded she was not entitled to FMLA benefits at the time of her post-termination requests and had failed to provide timely notice for her absences.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 Chitwood could not prevail on either her FMLA interference or retaliation claims because she was not denied FMLA benefits to which she was entitled and there was no evidence that her termination was retaliatory. The court found that her noncompliance with notice requirements and her failure to return to work justified her termination. View "Chitwood v. Ascension Health Alliance" on Justia Law

A fire severely damaged a church building in southeastern Indiana. The church promptly notified its insurer, which had issued a policy covering actual cash value (subject to depreciation) and additional replacement-cost benefits if the property was repaired or replaced “as soon as reasonably possible.” The parties disputed the cost of rebuilding, but the insurer paid the church nearly $1.7 million—the undisputed actual cash value and additional agreed amounts—while the church continued to contest the estimates and did not begin repairs or replacement. About two years after the fire, the church sued the insurer for breach of contract and bad faith denial of replacement-cost benefits.The insurer removed the case to the United States District Court for the Southern District of Indiana and moved for summary judgment, arguing that the church had not complied with the policy’s requirement to repair or replace the property promptly. The church, represented by counsel, responded with arguments about factual disputes over estimates and the credibility of insurance adjusters, but did not address the legal basis concerning the contractual precondition for replacement-cost benefits. The district court granted summary judgment to the insurer, finding the church had failed to engage with the insurer’s core argument.On appeal, with new counsel, the church raised for the first time that ongoing disputes over replacement-cost estimates excused its failure to begin repairs, citing two Indiana Court of Appeals cases. The United States Court of Appeals for the Seventh Circuit held that this argument was waived because it was not presented to the district court. The Seventh Circuit further held that plain-error review in civil cases is available only in extraordinary circumstances not present here. The court affirmed the district court’s judgment in favor of the insurer. View "Crothersville Lighthouse Tabernacle Church v. Church Mutual Insurance Company" on Justia Law

An investment fund specializing in gems and minerals filed for bankruptcy in October 2019. Prior to this, one of the fund’s managing members, through his own companies, had engaged a law firm to represent him and his separate business interests in connection with federal investigations and anticipated arbitration involving the fund and its leadership. The law firm’s engagement letters were addressed to the individual and his other company, not the fund itself, and did not state that the fund was responsible for payment. Some of the legal work benefited all respondents, including the fund, and the fund issued two checks to the law firm. However, a significant balance remained unpaid.During the bankruptcy proceedings, the law firm filed a claim against the fund for unpaid legal fees. The Official Committee of Equity Security Holders, appointed to represent the fund’s equity holders, objected, arguing the fund was not liable for the debt. The United States Bankruptcy Court for the Eastern District of Wisconsin granted summary judgment to the Equity Committee, finding the fund had no obligation to pay the law firm based on the evidence presented. The law firm appealed to the United States District Court for the Eastern District of Wisconsin, which affirmed the bankruptcy court’s decision.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s affirmance de novo. The Seventh Circuit held that the law firm had not provided sufficient evidence of an enforceable promise by the fund to pay the legal fees, either as a primary obligor or under promissory estoppel. Additionally, the court found that neither Wisconsin’s statutory indemnification provision for LLC managers and members nor the fund’s operating agreement extended indemnification rights to the individual who had retained the law firm. The Seventh Circuit affirmed the district court’s judgment. View "Ballard Spahr LLP v Official Committee of Equity Security Holders" on Justia Law

An inmate at an Illinois women’s prison was repeatedly sexually assaulted by her assigned counselor, who used his authority over her access to her daughter as leverage. After the inmate’s cellmate reported the abuse to a prison investigator, the investigator and the prison warden, instead of moving to protect the victim, devised a plan to use her as unwitting “bait” to catch the counselor in the act. This plan failed, and the abuse continued. The prison’s toxic culture, where staff-on-inmate sexual abuse was widespread and often ignored, provided the backdrop for these events.In the United States District Court for the Central District of Illinois, the inmate filed a civil rights lawsuit under 42 U.S.C. § 1983 against the counselor (who defaulted), the investigator, and the warden, alleging Eighth Amendment violations for cruel and unusual punishment. The district court denied summary judgment for the investigator and warden on qualified immunity and liability, and a jury found all three defendants liable, awarding the plaintiff $19.3 million in compensatory and punitive damages. The district court also excluded evidence suggesting the plaintiff might have consented to the abuse, and denied the investigator and warden’s post-trial motions for judgment as a matter of law or a new trial.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s denial of judgment as a matter of law and denial of qualified immunity for the investigator and warden, holding that no reasonable official could have thought their response was appropriate. However, the appellate court reversed in part, ordering a new trial on compensatory and punitive damages (but not liability) against the investigator and warden, due to insufficient evidence supporting liability before they learned of the abuse, exclusion of relevant evidence affecting punitive damages, and failure to use a special verdict form to distinguish between theories of liability. The attorney fee award was also vacated and remanded for reconsideration. View "Doe v Macleod" on Justia Law

Police officers responded to an assault complaint at an apartment building in Racine, Wisconsin, where they found a stabbing victim, Cannon, who identified Johnnie Russell as his assailant. Both the victim and Russell lived in the building, but Russell’s whereabouts were unknown. Building staff informed the officers that Russell might have returned to his apartment. Before obtaining a warrant, officers, with the help of the property manager, entered Russell’s apartment and conducted a brief 37-second sweep to check for injured persons or threats. No one was found. Later, officers secured a search warrant and conducted a thorough search. Russell challenged only the initial sweep, claiming it violated his Fourth Amendment rights.The United States District Court for the Eastern District of Wisconsin granted summary judgment in favor of Officer Colin Powell, holding that the warrantless entry constituted a reasonable protective sweep under the Fourth Amendment, given the violent nature of the offense, uncertainty about Russell’s location, lack of information about possible other victims, and the brief, limited nature of the search.Russell appealed to the United States Court of Appeals for the Seventh Circuit, contesting the district court’s ruling and arguing that Powell was not entitled to qualified immunity. The Seventh Circuit reviewed the grant of summary judgment de novo. The court decided to resolve the case on qualified immunity grounds without reaching the constitutional question. It held that, based on existing precedent, it was not clearly established that the brief warrantless sweep under these circumstances was unconstitutional. Therefore, Powell was entitled to qualified immunity.The Seventh Circuit affirmed the district court’s grant of summary judgment in favor of Powell. View "Russell v. Comstock" on Justia Law

David Venkus sought to collect a $13,776,518 criminal restitution judgment against Thomas Lindstrom, his former employee, who had caused the collapse of Venkus’s trading firm through fraudulent activities. Lindstrom later worked for Ryan Building Group, Inc. (RBG), where he earned salary and accumulated stock options but also incurred significant debt to RBG. After Lindstrom was terminated by RBG for embezzlement, RBG paid him $73,090, labeling it a severance payment. This sum was allegedly calculated based on the value of Lindstrom’s expired stock options, offset by his debt to RBG. Venkus, having previously served RBG with a citation to discover assets pursuant to Illinois law, claimed the payment and the handling of the options violated the citation’s asset-transfer prohibitions.The United States District Court for the Northern District of Illinois denied Venkus’s motion, finding that because Lindstrom’s options had expired and thus had no value, RBG’s severance payment was hypothetical and not a violation of the citation. The district court also held that the severance was subject to Illinois’s 15% wage garnishment cap and that RBG was not liable for attorney’s fees.On appeal, the United States Court of Appeals for the Seventh Circuit found that material questions of fact existed regarding the true nature of the severance payment and whether RBG’s actions “frustrated” Venkus’s rights under the citation. The court held that the district court erred by not conducting an evidentiary hearing to resolve these questions. Accordingly, the Seventh Circuit reversed the district court’s decision and remanded the case for further proceedings, directing that the lower court hold an evidentiary hearing and, if necessary, address whether attorney’s fees should be awarded if a citation violation is found. View "USA v Lindstrom" on Justia Law

Three individuals carried out an armed robbery targeting customers at a Chicago convenience store, J&J Food and Grocery. The incident involved robbing a person just outside the store’s vestibule and several customers inside, all at gunpoint. The store, which operates around the clock but limits access to a vestibule in the evenings, temporarily shut down after the robbery for police investigation, resulting in lost business for approximately thirty to sixty minutes. The robbers did not attempt to steal from the store itself or make demands of its employees.The United States District Court for the Northern District of Illinois, Eastern Division, presided over the trial and ultimately convicted the defendants of Hobbs Act robbery and brandishing a firearm during a crime of violence, under 18 U.S.C. §§ 1951(a), 924(c)(1)(A). The defendants moved for judgment of acquittal, arguing that their actions did not affect interstate commerce as required by the Hobbs Act, since they robbed customers rather than the store. The district court denied this motion, and the defendants appealed.The United States Court of Appeals for the Seventh Circuit reviewed the convictions de novo and affirmed. The court held that the temporary closure of J&J due to the robbery constituted at least a “realistic probability” of affecting interstate commerce, satisfying the Hobbs Act’s jurisdictional requirement. The court also rejected the defendants’ claim that the jury could have convicted them solely based on robbing the customer outside the store, finding that the jury was not presented with separate legal theories for inside and outside robberies. As the Hobbs Act convictions were upheld, the related firearm convictions were affirmed as well. View "United States v. Demus" on Justia Law

The defendant traveled multiple times to the Philippines, where, according to the government, he solicited minors between the ages of eleven and seventeen to perform sex acts in exchange for money, gifts, and food. He was indicted on seven counts of traveling in foreign commerce to engage in sexual activity with minors and seven counts of sex trafficking of a minor. During his change-of-plea hearing, the defendant pleaded guilty to two counts of sex trafficking of a minor, confirming that he understood the plea agreement, was satisfied with his counsel, and entered the plea voluntarily. Afterward, he moved to withdraw his guilty plea, arguing that he felt pressured to sign the agreement the morning of the hearing and that taking the anxiety medication Clonazepam had impaired his cognition.The United States District Court for the Eastern District of Wisconsin held an evidentiary hearing on the motion to withdraw. The district court found that neither the plea colloquy nor the evidence supported the defendant’s claim that his plea was not knowing and voluntary; it relied on his in-court statements, his demeanor, and written admissions in the plea agreement. The district court denied the motion to withdraw his plea.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s denial for abuse of discretion and its factual findings for clear error. The appellate court concluded that the district court did not abuse its discretion. It found the defendant’s own statements and conduct during the plea hearing, as well as the signed plea agreement, adequately demonstrated that the plea was knowing and voluntary. The court also determined that the defendant’s evidence regarding the effects of his medication was insufficient to justify withdrawal. Therefore, the judgment was affirmed. View "United States v. Stenson" on Justia Law

Three employees at different Illinois schools declined to receive the COVID-19 vaccine, citing religious beliefs, after the Illinois Governor issued an Executive Order requiring school employees to either vaccinate or undergo weekly testing. The schools, in compliance with the Executive Order and state agency guidance, offered weekly testing as an accommodation for those claiming a religious exemption to vaccination. The employees refused the testing, asserting that submitting to it violated their moral consciences, and were either placed on unpaid leave or terminated.The employees filed suit in the United States District Court for the Central District of Illinois, alleging violations of Title VII of the Civil Rights Act, the Emergency Use Authorization Act, and the Illinois Health Care Right of Conscience Act. Each employer moved to dismiss the complaint. The district court dismissed the Title VII claim, finding that the plaintiffs failed to identify a religious belief that was violated by the testing requirement. The court also dismissed the Emergency Use Authorization Act claim, holding there was no private right of action, and declined supplemental jurisdiction over the state law claim. The employees appealed only the dismissal of their Title VII claim and, for the first time on appeal, raised a claim under the Illinois Public Health Code.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The court held that the plaintiffs failed to state a claim under Title VII because they did not allege a religious objection to testing; their objections were based on personal moral conscience, not religious belief. The court further held that Title VII does not require an employer to accommodate religious beliefs when doing so would cause the employer to violate the law. The court also found that any argument under the Illinois Public Health Code was waived. View "Bowlin v. Board of Directors, Judah Christian School" on Justia Law