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

Robert Panton arrived in the United States in 1970 as a lawful permanent resident. In the late 1980s, he became involved in a major drug conspiracy and was convicted in 1992, receiving a life sentence. After serving over 25 years, he was released on compassionate grounds in 2020. Upon release, immigration authorities initiated removal proceedings to Jamaica. Panton claimed protection under the Convention Against Torture, but an Immigration Judge rejected this claim and ordered his removal. Panton later sought a U visa, arguing he was a victim of crime and assisted law enforcement, but his U visa application was still pending during these proceedings. He also needed a waiver of inadmissibility due to his conviction and removal order.Following the Immigration Judge’s removal order, Panton appealed to the Board of Immigration Appeals (BIA), but was unsuccessful. He then obtained certification from the New York Police Department confirming he was a crime victim and had assisted in the investigation, but this evidence was received too late for the Immigration Judge. Panton filed a motion to reopen his case with the BIA, citing delays in obtaining the certification. The BIA denied the motion, stating that reopening was only possible sua sponte given the elapsed 90-day deadline and incorrectly dismissed the possibility of equitable tolling. The BIA also conflated the issuance of a U visa with the waiver of inadmissibility and failed to address Panton’s request for discretionary closure pending the Department of Homeland Security’s visa decision.The United States Court of Appeals for the Seventh Circuit granted Panton’s petition for review and remanded the case to the BIA. The court held that the BIA erred by failing to address equitable tolling and conflating visa issuance with waiver authority, and it must properly consider Panton’s arguments and the agency’s responses on remand. View "Panton v Blanche" on Justia Law

Federal agents arrested a man after a sting operation involving a confidential informant. The informant identified the defendant as someone involved in drug transactions and arranged a meeting where agents observed the defendant accepting sham cocaine. Upon arrest, agents found heroin, crack cocaine, and cash in the defendant’s vehicle. The defendant admitted to prior drug dealings with the informant. He was charged with possession of heroin with intent to distribute and went to trial, where a jury convicted him.Before the United States District Court for the Northern District of Illinois, the defendant’s sentencing included two enhancements: one under 21 U.S.C. § 841(b)(1)(B) for a prior felony drug conviction and another under § 4B1.1 of the Sentencing Guidelines for being a career offender. Defense counsel did not challenge these enhancements. The defendant was sentenced to 20 years in prison and 8 years of supervised release. On direct appeal, his conviction was affirmed by the United States Court of Appeals for the Seventh Circuit. He subsequently filed a motion for postconviction relief under 28 U.S.C. § 2255, arguing ineffective assistance of counsel for failure to object to the sentencing enhancements and to certain testimony at trial. The district court denied relief, finding the enhancements valid and counsel’s performance reasonable.On collateral review, the United States Court of Appeals for the Seventh Circuit found that counsel’s failure to challenge the § 841(b)(1)(B) statutory enhancement was objectively unreasonable and prejudicial, as it affected both the advisory Guidelines range and mandatory minimums. However, the court rejected claims regarding the career-offender enhancement and admission of the agent’s testimony, finding no prejudice or legal error. The Seventh Circuit vacated the sentence and remanded for resentencing, while affirming the conviction. View "Cherry v USA" on Justia Law

In this case, Indiana enacted legislation in 2021 that imposed new requirements on public school teachers who wished to have union dues automatically deducted from their paychecks. These requirements included submitting a written authorization containing a specific statement regarding their First Amendment rights, annual renewal of the authorization, confirmation via official work email, and annual notice of their right to resign from the union. These procedures applied only to teachers and not to other public employees in Indiana.Previously, the United States District Court for the Southern District of Indiana reviewed the case after teachers’ unions and individual members challenged the law, arguing it violated their First Amendment rights to free speech and association. The district court initially found that the mandated statement on the authorization form constituted compelled speech and issued a preliminary injunction. After Indiana amended the statute in response, the district court concluded that the revised law no longer violated the Free Speech Clause, but still found that the additional requirements on teachers constituted viewpoint discrimination against their freedom of association. The court permanently enjoined enforcement of the provisions and the State appealed.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s judgment. The Seventh Circuit held that the authorization form’s required statement was government speech, not compelled private speech, and did not violate the Free Speech Clause. However, the court agreed with the district court that the additional requirements imposed only on teachers and their unions amounted to unconstitutional viewpoint discrimination under the First Amendment’s Freedom of Association protections. The court applied strict scrutiny and found Indiana’s justifications insufficient. As a result, the Seventh Circuit affirmed the district court’s judgment permanently enjoining enforcement of the challenged provisions. View "Anderson Federation of Teachers v. Rokita" on Justia Law

Ashley Energy, an energy company in Missouri, experienced flooding at its plant and leased a boiler and water treatment trailer from Indeck Power Equipment to maintain operations. The lease required Indeck to provide a “like-new” boiler and new trailer, and Ashley to operate and maintain the equipment according to industry standards, specifically ABMA guidelines, and pay for repairs beyond ordinary wear and tear. After the boiler was returned, Indeck discovered scale and debris, attempted to clean it, and ultimately sued Ashley, alleging breach of contract and seeking over $3 million in damages. Ashley had previously sued Indeck in Missouri state court, but that case was dismissed due to a forum selection clause.The United States District Court for the Northern District of Illinois conducted a jury trial. The jury found that Indeck had performed its contractual obligations and that Ashley had breached the contract. However, the jury concluded that Indeck failed to prove it had sustained damages as a result of Ashley’s breach, finding insufficient evidence that Ashley’s actions directly caused damage beyond normal wear and tear. Indeck’s post-trial motions for a new trial and for attorneys’ and experts’ fees were denied, with the district court explaining that the verdict could be rationally explained by evidence that Indeck’s own actions or equipment contributed to any damage or that no damage beyond ordinary wear and tear occurred.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The appellate court held that the jury’s verdict was not irreconcilably inconsistent and was supported by plausible explanations from the record, and that Indeck was not entitled to attorneys’ fees as a non-prevailing party under the lease’s provisions. View "Indeck Power Equipment Co. v Ashley Energy LLC" on Justia Law

The case concerned the rights to publish an unpublished article, “Psychopathology of Awareness,” written by Dr. Frederick Perls. Dr. Perls’s widow, Laura Perls, inherited the copyright to this article. In 1991, her estate entered an agreement with the Center for Gestalt Development, granting the Center exclusive rights to publish a collection of Dr. Perls’s unpublished manuscripts, which included the article. However, the Center did not publish the collection until 2021. In the mid-2010s, Charles Bowman acquired a copy of the article and, together with Jean-Marie Robine, decided to publish it with additional commentary. Before publishing, Bowman and Robine sought and received permission from Dr. Perls’s children, who had inherited the copyright to the article itself, to include it in their book.After learning of Bowman and Robine’s plans, the Center contacted them to assert its own purported rights, but the Center refused their offers of collaboration. Bowman and Robine then obtained an oral license from the Perls siblings, communicated through Leslie Gold, authorizing them to use the article. In 2021, following litigation, the Perls siblings assigned their rights in the article to the Center until the conclusion of this lawsuit.The Center sued Bowman and Robine for copyright infringement in the United States District Court for the Southern District of Indiana. The district court found that the Center’s 1991 agreement conveyed rights only in the collection as a whole, not in the article individually. It further determined that Bowman and Robine had an irrevocable oral license to use the article before the Center acquired the copyright.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s entry of summary judgment for Bowman and Robine. The main holding was that ownership of a compilation copyright does not confer rights in the individual components, and the oral license granted to Bowman and Robine precluded infringement claims by the Center. View "Center for Gestalt Development, Inc. v Bowman" on Justia Law

Mary Jane Sweet Spot, LLC and its principal, Ashley McCoy, applied for a business license to operate a bakery in Blue Island, Illinois. After initially positive interactions with city officials, the license was denied based on the City’s finding that the applicants had hosted unapproved, paid events involving “infused” treats and entertainment, which the City deemed inconsistent with the intended bakery business. The City also cited evasive conduct by McCoy during inspections. The denial was sustained after an administrative hearing, and the applicants did not pursue further administrative review before the City Council as required by municipal code.Instead of completing the administrative review, the plaintiffs sought judicial review in the Circuit Court of Cook County, which dismissed the petition for failure to exhaust administrative remedies and for untimely filing. The Illinois Appellate Court affirmed the dismissal based on failure to exhaust administrative remedies. While that appeal was pending, the plaintiffs filed a federal suit in the United States District Court for the Northern District of Illinois, raising constitutional and state-law claims stemming from the license denial.The district court dismissed the federal suit for lack of subject matter jurisdiction, relying on the Rooker-Feldman doctrine, concluding that the plaintiffs were seeking review of a state-court judgment. On appeal, the United States Court of Appeals for the Seventh Circuit held that Rooker-Feldman did not apply because the plaintiffs’ alleged injuries resulted from the City’s administrative action, not the state-court judgment. The appellate court vacated the dismissal and remanded for further proceedings, noting that claim preclusion, not Rooker-Feldman, might bar the suit, but left that issue for the district court if raised by defendants. View "Mary Jane Sweet Spot, LLC v City of Blue Island" on Justia Law

Several candidates, including Georgia’s Lieutenant Governor and Secretary of State, sought the Republican nomination for Governor in Georgia’s 2026 primary. Under Georgia law, only certain officeholders, such as the incumbent Lieutenant Governor, could establish “leadership committees,” which allowed them to raise and spend unlimited funds and coordinate directly with their campaigns. Safe Affordable Georgia, a hybrid PAC chaired by Secretary Raffensperger, could not coordinate with his campaign or raise unlimited funds to support him.Safe Affordable Georgia filed suit in the United States District Court for the Northern District of Georgia against state officials, arguing that Georgia’s campaign finance scheme violated the First Amendment by treating it differently from leadership committees. The PAC sought a preliminary injunction to bar enforcement of contribution and coordination limits against it, aiming to support Raffensperger in the ongoing primary. The district court denied the request for emergency injunctive relief, and the PAC appealed to the United States Court of Appeals for the Eleventh Circuit.While the appeal was pending, the primary election concluded and Raffensperger’s campaign ended. The United States Court of Appeals for the Eleventh Circuit determined that, because the election was over and the PAC’s requested relief focused specifically on the 2026 primary, federal courts could no longer offer meaningful relief. The court held that the case was moot and did not qualify for the “capable of repetition, yet evading review” exception because there was no reasonable expectation the same situation would recur for the same party. The Eleventh Circuit dismissed the appeal and remanded the case to the district court with instructions to dismiss it as moot. View "USA v. Waeckerle" on Justia Law

The plaintiff, a former web designer with an associate’s degree in computer programming, sought supplemental security income and disability insurance benefits, claiming that depression, anxiety, and obsessive-compulsive disorder rendered him unable to work. He had received both inpatient and outpatient mental health treatment prior to his application. During two administrative hearings, he described significant difficulty with social interaction, compulsive behaviors, and daily functioning, although he managed some tasks independently and engaged in therapy and medication management.After his application was denied, the plaintiff requested a hearing before an Administrative Law Judge (ALJ). The ALJ found severe impairments, including depressive disorder, anxiety disorder, autism spectrum disorder, and ADHD, but ultimately concluded that the plaintiff did not meet the criteria for disability under the relevant statutory and regulatory framework. The ALJ determined that the plaintiff retained the mental capacity to perform simple, routine, repetitive tasks with accommodations and could work in jobs available in the national economy. The ALJ discounted certain expert opinions that found greater limitations, concluding those were inconsistent with the overall medical evidence and the plaintiff’s activities. The plaintiff then challenged this decision in the United States District Court for the Eastern District of Wisconsin, arguing that the ALJ failed to properly consider his OCD and related limitations. The district court affirmed the ALJ’s decision.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s ruling de novo, applying a deferential standard to the ALJ’s findings. The appellate court held that the ALJ’s decision was supported by substantial evidence and complied with applicable regulations and precedents. The court rejected the plaintiff’s arguments regarding the treatment of his OCD and the weighing of medical opinions. The judgment of the district court was affirmed. View "Lewis v Bisignano" on Justia Law

Two individuals loaned money to entities for which a third person guaranteed repayment. When those loans went unpaid, the lenders obtained a default judgment of approximately $4.5 million against the guarantor. The guarantor did not pay the judgment, leading the lenders to initiate post-judgment proceedings to discover and collect his assets. They issued a citation on funds previously held in escrow by a lender as security for loans on properties owned by entities the guarantor controlled. After property sales fully repaid the loans, the escrowed funds remained frozen pending resolution of who was entitled to them. Several limited liability companies (LLCs) associated with the guarantor, as well as his estranged wife, intervened, each asserting claims to the funds.The United States District Court for the Northern District of Illinois appointed a Special Master to determine the ownership of the escrowed funds. After discovery and a hearing, the Special Master found that the funds belonged to the guarantor, not the LLCs, based on evidence that he exercised complete control over similar proceeds and used them for personal expenses without objection from the LLCs. The district court adopted these findings and ordered further proceedings to determine if the wife’s claim for unpaid child and spousal support had priority. Before those proceedings concluded, the wife and the lenders agreed to split the funds, and the district court approved this resolution, over objections from the LLCs.On appeal, the United States Court of Appeals for the Seventh Circuit held that it had jurisdiction over the LLCs’ appeal and dismissed the guarantor’s appeal for lack of standing. The court affirmed the district court’s determination that the escrowed funds belonged to the guarantor and could be used to satisfy the judgment. It also rejected the argument that the proceedings improperly pierced the corporate veil or violated procedural requirements under Illinois law. View "Zhu Zhai Holdings Limited v Ivankovich" on Justia Law

Several patients brought class action lawsuits against Indiana health care providers, alleging that their medical information was improperly shared with Facebook through the use of the Meta Pixel embedded in online patient portals. The plaintiffs asserted state law claims including breach of implied contract, unjust enrichment, and violations of the Indiana Deceptive Consumer Sales Act and Indiana Wiretapping Act. The health care providers had established these online portals to comply with federal regulations encouraging electronic health records, which offered incentive payments and imposed penalties for non-compliance.The health care providers removed the cases from Indiana state court to the United States District Court for the Southern District of Indiana, arguing that federal jurisdiction was proper under 28 U.S.C. § 1442(a)(1). They claimed they were “acting under” the Department of Health and Human Services when creating and maintaining their portals. District courts in multiple consolidated cases rejected this argument, finding that the providers did not meet the statutory requirements for removal under § 1442(a)(1). The courts concluded that while the providers were highly regulated and incentivized by federal policies, their actions did not amount to performing basic governmental tasks or operating under the direction of a federal officer.The United States Court of Appeals for the Seventh Circuit reviewed the consolidated appeals de novo. It held that compliance with federal regulations and incentives for patient portals did not constitute “acting under” a federal officer. The court found that the health care providers’ relationship to the federal government lacked the unusually close supervision and delegation required for federal officer removal. The court affirmed the district courts’ remand orders, holding that federal subject matter jurisdiction was not established under § 1442(a)(1). View "Chiaro v Methodist Hospitals, Inc." on Justia Law