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

In December 2015, sixteen-year-old Isaiah Taylor was stopped by Milwaukee police officers Justin Schwarzhuber and Jasen Rydzewski while running through his neighborhood to deliver a turkey. The officers frisked him, searched his bag, and detained him in their police car to check for outstanding warrants and recent robberies. Taylor later sued the officers under 42 U.S.C. § 1983, claiming an unreasonable search and seizure in violation of the Fourth Amendment and racial profiling in violation of the Equal Protection Clause of the Fourteenth Amendment.The United States District Court for the Eastern District of Wisconsin granted qualified immunity and summary judgment to the officers on Taylor’s Fourteenth Amendment claim and on the Fourth Amendment claim regarding the initial stop and frisk. However, the court denied qualified immunity on the issue of Taylor’s continued detention, sending it to trial. The jury found the officers not liable, and the court denied Taylor’s motion for post-trial relief under Federal Rule of Civil Procedure 59.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the grant of summary judgment on Taylor’s Fourteenth Amendment claim, finding insufficient evidence of racial profiling. However, it vacated the summary judgment on the Fourth Amendment claims related to the initial stop and frisk, concluding that the officers lacked reasonable suspicion for the stop and frisk based on clearly established law. The court also vacated the jury verdict on the continued detention issue, as it was intertwined with the initial stop's constitutionality, and remanded the case for a new trial on all Fourth Amendment claims. View "Taylor v. Schwarzhuber" on Justia Law

Kevin Brooks, an inmate at a federal prison camp, suffered from appendicitis, which was misdiagnosed by medical personnel as constipation and COVID-19. Despite his worsening condition, he was not sent to a hospital for over ten days, resulting in a ruptured appendix and peritonitis. Brooks eventually recovered but experienced severe pain during the ordeal. He filed a lawsuit seeking damages from five federal employees, three of whom treated him and two who were supervisors.The United States District Court for the Northern District of Illinois dismissed Brooks's suit, ruling that it presented a new context to which the doctrine of Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics does not extend. The court reasoned that Brooks's case differed from previous Bivens cases, particularly Carlson v. Green, due to the duration of his medical issue and the involvement of supervisory personnel.The United States Court of Appeals for the Seventh Circuit reviewed the case and disagreed with the district court's reasoning. The Seventh Circuit held that Brooks's claim did not present a new context, as it was similar to Carlson v. Green, where a prisoner alleged constitutionally inadequate medical care. The court found that the distinctions made by the district court regarding the duration of the medical issue and the involvement of supervisors were not sufficient to create a new context. The Seventh Circuit affirmed the dismissal of claims against the two supervisors but vacated the dismissal of claims against the three treating personnel, remanding the case for further proceedings. View "Brooks v. Richardson" on Justia Law

A tenured professor at the University of Illinois Chicago School of Law, Jason Kilborn, included an expurgated racial slur in a law school exam question. This led to an investigation by university officials, who found that Kilborn had created a racially hostile environment and violated the university's nondiscrimination policy. Consequently, Kilborn was suspended from teaching until he completed a diversity training program and was denied a two percent raise. Kilborn sued several university officials, alleging violations of his constitutional rights to free speech and due process.The United States District Court for the Northern District of Illinois dismissed Kilborn's federal claims with prejudice, finding that his speech was not constitutionally protected. The court also declined to exercise supplemental jurisdiction over his state law claims, dismissing them without prejudice. Kilborn appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case and reversed the dismissal of Kilborn's First Amendment retaliation claim, concluding that his speech was constitutionally protected under the Supreme Court's decisions in Connick v. Myers and Pickering v. Board of Education. The court found that Kilborn's speech addressed matters of public concern and that the university's actions could be seen as pretextual. However, the court affirmed the dismissal of Kilborn's remaining federal claims, including his compelled speech and procedural due process claims. The court also vacated the dismissal of Kilborn's state law claims for further consideration by the district court. View "Kilborn v. Amiridis" on Justia Law

The plaintiffs, Thomas Ghelf, Tricia Hansen, Constance and Thomas Klein, Maureen Sommerfeld, and Mississippi Sports and Recreation, Inc. (MSR), own abutting properties in the Town of Wheatland, Vernon County, Wisconsin. They alleged that the Town, its officials, Vernon County, the County Treasurer, and unknown agents and employees engaged in a harassment campaign against them. This included coordinated complaints about their businesses, unlawful arrests, failures to respond to emergency services, excessive property tax assessments, a foreclosure action, and the designation of a private driveway as a public road.The United States District Court for the Western District of Wisconsin dismissed the plaintiffs' tax assessment and road claims for lack of subject matter jurisdiction, abstained from exercising jurisdiction over the foreclosure claims, and dismissed the remaining claims for failure to state a claim. The court held that the Tax Injunction Act and principles of comity barred the tax assessment and foreclosure claims. It also found that the plaintiffs' claims related to events before September 15, 2016, were time-barred by the statute of limitations.The United States Court of Appeals for the Seventh Circuit affirmed the district court's dismissal of the tax assessment and foreclosure claims, agreeing that the Tax Injunction Act and comity principles deprived the district court of jurisdiction. The appellate court also upheld the dismissal of claims related to events before September 15, 2016, as time-barred. However, the Seventh Circuit reversed the dismissal of the plaintiffs' road claims, finding that these claims were not barred by claim or issue preclusion. The case was remanded for further proceedings on the road claims, and the court held that Town Chairman Jayne Ballwahn should not be dismissed from the suit at this stage. View "Ghelf v Town of Wheatland" on Justia Law

Jack William Morgan, a Messianic Jew, purchased a turkey log from the commissary at the Federal Correctional Institution (FCI) Thomson in May 2021, which led to the suspension of his kosher diet approval for thirty days by the institutional chaplain. Morgan claimed this forced him to choose between starvation and violating his religious beliefs, and he chose starvation. After exhausting administrative remedies, he sued the Federal Bureau of Prisons (BOP) and the prison warden, Andrew Ciolli, seeking changes to dietary policies and monetary damages under the Religious Freedom Restoration Act (RFRA). Morgan has since been transferred to a different BOP facility.The United States District Court for the Northern District of Illinois dismissed Morgan’s complaint with prejudice for failure to state a claim. The court found that Morgan did not provide sufficient factual allegations to show that the BOP’s dietary policies substantially burdened his religious exercise. Additionally, the court noted that the BOP is immune from suits for damages under RFRA and that Morgan’s complaint did not include allegations about Ciolli’s conduct.The United States Court of Appeals for the Seventh Circuit reviewed the case and focused on two threshold issues: subject-matter jurisdiction and sovereign immunity. The court determined that Morgan did not adequately allege standing to pursue his claim for injunctive relief, as his threat of future injury was too speculative. Furthermore, the court held that federal sovereign immunity barred Morgan’s claim for monetary damages, as RFRA does not waive the federal government’s sovereign immunity against damages suits. The court affirmed the district court’s dismissal but modified the judgment to reflect a jurisdictional dismissal. View "Morgan v BOP" on Justia Law

Breion Woodson was convicted in Wisconsin state court on charges of firearm and drug possession and sentenced to 19 years in prison. During sentencing, the government presented a video from social media showing men with guns and drugs, which the judge used to assess Woodson's character and danger to the community. Woodson argued that he was misidentified in the video, but the judge denied his motion for a new sentencing hearing. The Wisconsin Court of Appeals affirmed, stating Woodson failed to prove he was not the man in the video.Woodson then filed a federal habeas corpus petition in the Eastern District of Wisconsin, introducing booking photos from the time of his sentencing that suggested he was not the man in the video. However, the district court ruled it could not consider the photos since they were not presented in state court and denied his petition, finding the state appellate court's decision reasonable based on the evidence it had.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court held that under the Antiterrorism and Effective Death Penalty Act (AEDPA), habeas relief is unavailable unless the state court's decision was contrary to or an unreasonable application of federal law or based on an unreasonable determination of facts. The court found that Woodson's claim was not procedurally defaulted and that the actual innocence exception did not apply to his case. The court also ruled that it could not consider the new evidence (booking photos) under AEDPA's strict limitations. Consequently, the Seventh Circuit affirmed the district court's denial of Woodson's habeas petition. View "Woodson v Mlodzik" on Justia Law

Kurt Beathard, a football coach at Illinois State University (ISU), was terminated from his position as offensive coordinator after posting a handwritten message on his office door that read, "All Lives Matter to Our Lord & Savior Jesus Christ." This occurred during a period of tension and unrest on the ISU campus following the death of George Floyd. Beathard alleges that his termination was due to this personal speech, which he claims is protected by the First Amendment.In the District Court for the Central District of Illinois, Beathard filed a section 1983 action against Larry Lyons, the Athletic Director, and Brock Spack, the head football coach, asserting that his termination violated his First Amendment rights. The defendants moved to dismiss the complaint under Rule 12(b)(6), arguing that they were entitled to qualified immunity because it was not clear that Beathard's speech was protected as personal rather than official speech. The district court denied the motion to dismiss, stating that factual development was necessary before resolving the qualified immunity question.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court concluded that it lacked jurisdiction to hear the appeal because the district court had not made a definitive ruling on the qualified immunity defense but had instead postponed the decision, indicating that further factual development was needed. The Seventh Circuit emphasized that interlocutory orders, such as the denial of a motion to dismiss, are generally not immediately appealable unless they conclusively determine the disputed question. Consequently, the appeal was dismissed for want of appellate jurisdiction. View "Beathard v. Lyons" on Justia Law

Stanley Felton, also known as G’esa Kalafi, was incarcerated at the Wisconsin Secure Program Facility from 2007 to 2015. He filed a pro se complaint under 42 U.S.C. § 1983 against several prison employees, alleging Eighth and Fourteenth Amendment violations due to his prolonged solitary confinement and First Amendment violations for the confiscation of his outgoing mail. Felton claimed that Warden Tim Haines and his successor Gary Boughton were responsible for his continued solitary confinement, and that three other officials, Lebbeus Brown, Joseph Cichanowicz, and Daniel Winkleski, illegally confiscated his mail.The United States District Court for the Western District of Wisconsin dismissed Felton’s Eighth and Fourteenth Amendment claims after screening the complaint and denied his motion to file an amended complaint. After discovery, the court granted summary judgment against Felton on his First Amendment claims, concluding that the prison officials were entitled to qualified immunity and that the confiscation of Felton’s mail did not violate his First Amendment rights.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s decisions, holding that Felton did not adequately allege a Fourteenth Amendment due process violation, as the delayed review of his administrative confinement did not constitute a constitutional violation. The court also found that Felton had waived his Eighth Amendment claim on appeal by not sufficiently developing the argument. Regarding the First Amendment claims, the court concluded that the confiscation of Felton’s letter containing threatening language was justified and that the defendants were entitled to qualified immunity for retaining the state court order that accompanied the letter. The court emphasized that the defendants’ actions did not violate clearly established law. View "Felton v Brown" on Justia Law

Raquel Haro was arrested at a college party and subjected to a strip search, including a visual cavity inspection, during the booking process at Porter County Jail. The jail uses a body scanner for all arrestees, and Haro's scan revealed a small, unidentified object in her pelvic region. Haro admitted that the scan justified a strip search but argued that the search became unreasonable once it was revealed that she was wearing a bodysuit with metal snaps. She sued Porter County, the sheriff’s department, and the officer who conducted the search under 42 U.S.C. § 1983, claiming the search violated her Fourth and Fourteenth Amendment rights.The United States District Court for the Northern District of Indiana granted summary judgment in favor of the defendants, concluding that the strip search was justified and reasonable in scope. Haro appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The court held that the strip search was justified by reasonable suspicion due to the anomaly on the body scan. The court also found that it was reasonable for the officer to complete the strip search, including the visual cavity inspection, even after discovering the metal snaps on Haro's bodysuit. The court emphasized the deference given to jail officials in maintaining security and found no constitutional violation in the manner or scope of the search. Consequently, the court did not address the qualified immunity defense or the liability of the Porter County Sheriff’s Department under Monell. The decision of the district court was affirmed. View "Haro v. Porter County" on Justia Law

Jonathan Peoples pleaded guilty to felony possession of a controlled substance and was sentenced to one year of incarceration plus one year of mandatory supervised release. He received credit for time served, effectively completing his incarceration term. However, due to Illinois Department of Corrections (IDOC) policies, he was detained at Cook County Jail for four additional days until he could be transferred to IDOC for processing and release.Peoples filed a Section 1983 claim against Cook County and Sheriff Thomas J. Dart, alleging that his detention beyond his sentence violated his constitutional rights. The U.S. District Court for the Northern District of Illinois granted summary judgment in favor of the defendants, concluding that neither the Fourth nor the Fourteenth Amendments applied to Peoples's claim and that he failed to present a triable Eighth Amendment claim.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court determined that the Fourth Amendment did not apply to Peoples's post-conviction detention. Instead, the Eighth Amendment, which prohibits incarceration beyond the end of a sentence without penological justification, was applicable. The court found that the Cook County Sheriff's Office had a penological justification for detaining Peoples until IDOC could process him, as required by Illinois law and the court's commitment order.The Seventh Circuit affirmed the district court's decision, holding that Peoples failed to establish that the Sheriff acted with deliberate indifference, a necessary element for an Eighth Amendment violation. Consequently, without a constitutional injury, Peoples's Section 1983 claim could not succeed. View "Peoples v Cook County" on Justia Law