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

An Illinois state trooper stopped a car that had been speeding. The subsequent search of the car revealed 1.5 kilograms of cocaine, which the police seized. Defendant, who was one of two passengers in the car, was prosecuted in federal court for possessing and intending to sell the cocaine found in the car. Defendant filed a motion to suppress the cocaine evidence. The district judge denied the motion, concluding (1) as a passenger in the car, Defendant had no standing to challenge the search; and (2) even if Defendant had standing, the delay did not make the search unlawful. Defendant subsequently entered a conditional plea of guilty to the charges. The Seventh Circuit affirmed in part, reversed in part, and remanded, holding (1) Defendant’s conviction was proper; but (2) the district court erred in imposing certain conditions of supervised release as part of Defendant’s sentence. View "United States v. Sanford" on Justia Law

Francis Foster filed suit against Principal Life Insurance Company, alleging, inter alia, tortious interference with prospective economic advantage. Principal filed a motion to dismiss the complaint on the grounds that Foster lacked standing to sue and that he failed to state a claim. The district court dismissed the complaint but did so on the theory that Foster’s claims were “derivative” of a related lawsuit and that his settlement of that lawsuit barred his claim against Principal. The district court also denied Foster’s motion to amend his complaint. The Seventh Circuit vacated the judgment, holding (1) Foster’s complaint stated a claim for intentional interference with prospective economic advantage, and Foster’s claim was not precluded by any other litigation; and (2) on remand, the district court should consider anew Foster’s motion to amend the complaint. View "Foster v. Principal Life Ins. Co." on Justia Law

Appellant was convicted of failing to register as a sex offender. A federal district court sentenced Appellant to thirty months in prison, five years of supervised release, a special assessment, and a fine. As part of the sentence, the district court imposed several special conditions of supervised release. Appellant did not object to any of these conditions in the district court, but he challenged them on appeal, arguing that they were unjustified restrictions on his liberty. The Seventh Circuit affirmed, holding that the district court did not commit plain error in its decision to impose the challenged conditions of supervised release, as the conditions imposed no greater deprivation of liberty than was reasonably necessary for the purposes of supervised release. View "United States v. Douglas" on Justia Law

After a jury trial in an Illinois state court, Appellant was found guilty of murdering his girlfriend’s one-year-old daughter. After exhausting his state appeals, Appellant filed a federal habeas petition, claiming, inter alia, that the forty-two-month delay in bringing his case to trial violated his Sixth Amendment right to a speedy trial. The district court denied the habeas petition. On direct appeal, the Illinois Appellate Court concluded that the pretrial delay was presumptively prejudicial but that the delay was attributable to continuances requested by Appellant’s counsel and did not impair the defense. The Seventh Circuit affirmed, holding that the Illinois court’s decision was not an unreasonable application of federal law, and therefore, habeas relief was unwarranted. View "O'Quinn v. Spiller" on Justia Law

This appeal was the most recent appeal in a series of lawsuits that have arisen over the sale of bonds by a corporation wholly owned by the Lac du Flambeau Band of Lake Superior Chippewa Indians (collectively, “the Tribal Entities”). In a prior action, the Seventh Circuit held that a bond indenture constituted an unapproved management contract under the Indian Gaming Regulatory Act (“IGRA”) and was therefore void. Following more than three years of litigating the validity of other bond-related documents in federal and state court, the Tribal Entities instituted a tribal court action seeking a declaration that the bonds are invalid under the IGRA as well as tribal law. Certain “Financial Entities” and Godfrey & Kahn S.C. sought an injunction in the Western District of Wisconsin to preclude the Tribal Entities from pursuing their tribal court action. The district court preliminarily enjoined the Tribal Entities from proceeding against the Financial Entities but allowed the tribal action to proceed against Godfrey. The Seventh Circuit affirmed in part and reversed in part, holding that the district court (1) did not abuse its discretion in enjoining the tribal court action against the Financial Entities; but (2) made several errors of law in assessing whether Godfrey had established a likelihood of success on the merits. Remanded. View "Stifel, Nicolaus & Co., Inc. v. Lac Du Flambeau Band of Lake Superior Chippewa Indians" on Justia Law

Plaintiff, an employee of Costco Wholesale Corporation, made two requests for a medical leave under the FMLA. Costco granted both requests. During that time, Plaintiff was demoted from optical manager to cashier. Plaintiff filed this lawsuit against Costco and Gail Hinds, his supervisor, alleging retaliation and interference, both in violation of the FMLA, and discrimination based upon a disability and failure to accommodate, both in violation of the Americans with Disabilities Act. The district court granted summary judgment for Defendants on all of Plaintiff’s causes of action. The Seventh Circuit affirmed, holding that the district court (1) did not abuse its discretion in finding that Plaintiff failed to comply with the requirements of the Northern District of Illinois Local Rule 56.1; (2) properly granted summary judgment in favor of Defendants on Plaintiff’s FLMA retaliation and interference claims; and (3) properly granted summary judgment in favor of Defendants on Plaintiff’s reasonable accommodation claim. Lastly, Plaintiff waived any arguments with regard to disparate treatment. View "Curtis v. Costco Wholesale Corp." on Justia Law

Pursuant to a plea agreement, Defendant entered a plea of guilty to a drug conspiracy charge. The plea agreement contained a waiver of Defendant’s right to collaterally attack his conviction or sentence. The district judge did not expressly discuss the collateral-attack waiver with Coleman at the guilty-plea hearing. At sentencing, the district court imposed a term of supervised release that included “standard conditions.” The Seventh Circuit (1) affirmed the conviction, holding that the plea colloquy did not comply with Fed. R. Crim. P. 11 with respect to the collateral-attack waiver, but the omission did not affect Defendant’s substantial rights; and (2) remanded for resentencing, as certain conditions of supervised release imposed on Defendant were impermissibly vague. View "United States v. Coleman" on Justia Law

Anthony Zimmerman, the president and owner of Premier Forest Products Products, Inc. (together, Plaintiffs), was hired to harvest trees on certain property. When the landowner discovered that Zimmerman had been harvesting trees without regard to fence lines and had taken more trees than he was supposed to, the landowner warned Zimmerman to leave the property. When Zimmerman refused to do so, the landowner sought help from the Carroll County Sheriff’s Office. The sheriff’s office arrested Zimmerman for criminal trespass. Plaintiffs sued the sheriff’s office and its sheriff, deputy, chief deputy, and detective (collectively, Defendants), alleging that Defendants violated his constitutional rights in arresting him for criminal trespass. The district court granted summary judgment for Defendants, concluding that Defendants had probable cause to arrest Defendant and, alternatively, that Defendants were entitled to qualified immunity. The Seventh Circuit affirmed, holding that Zimmerman failed to establish that probable cause was lacking under the circumstances presented in this case or that Defendants engaged in arbitrary conduct unjustifiable by any government interest. View "Zimmerman v. Doran" on Justia Law

Sixteen days after Defendant, a dentist, learned Plaintiff, an inmate of Illinois’s Stateville prison, was complaining of a tooth abscess, Defendant diagnosed an abscessed molar, prescribed penicillin to bring the infection under control, and extracted the molar. Plaintiff sued the dentist and a prison guard (together, Defendants), charging them with deliberate indifference to his abscess. The district judge granted summary judgment in favor of Defendants. The Seventh Circuit reversed, holding that the evidence of deliberate indifference by Defendants to Plaintiff’s serious medical need precluded granting summary judgment in their favor. Remanded. View "Dobbey v. Mitchell-Lawshea" on Justia Law

Several multi-employer health and welfare funds filed this suit under the Employee Retirement Income Security Act seeking approximately $70,000 in alleged delinquent contributions. The assertedly delinquent employer, Con-Tech Carpentry, did not file an answer within the statutory period and was found in default. The district court subsequently entered a judgment in the funds’ favor and awarded damages. Con-Tech subsequently filed a Fed. R. Civ. P. 60(b) motion, which also invoked Fed. R. Civ. P. 55(c). The judge denied the Rule 60(b) motion. The Seventh Circuit affirmed, holding that because Con-Tech made a deliberate decision to disregard the pending suit, there was no reason for the district judge to excuse Con-Tech’s conduct in retrospect. View "Mid-Central Illinois Reg’l v. Con-Tech Carpentry, LLC" on Justia Law