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

This case involves a federal habeas corpus petition by Darnell Dixon, who was convicted of home invasion and murder by an Illinois state court and sentenced to life imprisonment. Dixon's habeas petition primarily focused on claims of actual innocence and prosecutorial misconduct. The United States Court of Appeals for the Seventh Circuit affirmed the denial of his habeas petition by the United States District Court for the Northern District of Illinois.The case involved a series of events including a drug-related robbery and subsequent murders. Dixon and Eugene Langston were implicated in the murders, with Langston identified in a police lineup by a witness, Horace Chandler. However, Chandler later recanted this identification. The state's case against Dixon relied heavily on a confession that Dixon later claimed was false. Dixon's confession and Chandler's identification of Langston were central to the state's theory of accomplice liability, arguing that Dixon was accountable for Langston's acts.In his habeas petition, Dixon argued that he was denied due process when the trial court excluded evidence that charges against his alleged accomplice, Langston, were dismissed. He also asserted that his trial counsel was ineffective for failing to object to the exclusion of that evidence. Furthermore, Dixon claimed that the state committed prosecutorial misconduct by presenting conflicting positions regarding Langston's involvement in the murders at trial and during post-conviction proceedings.However, the Seventh Circuit found that Dixon's claim of actual innocence, based on the state's post-conviction contention that Langston's involvement was irrelevant and evidence of abusive and perjurious conduct by the case's police detective, did not meet the high standard required to conclusively prove his innocence. The Seventh Circuit also rejected Dixon's arguments of prosecutorial misconduct and ineffective assistance of counsel, finding no clear error in the district court's factual findings on these issues. View "Darnell Dixon v. Tarry Williams" on Justia Law

In the case at hand, the plaintiff, Benjamin Adams, an inmate at Indiana’s Plainfield Correctional Facility, sued the current and former commissioners of the Indiana Department of Corrections and various other officials pursuant to 42 U.S.C. § 1983, alleging that they violated his First and Eighth Amendment rights, as well as his Fourteenth Amendment rights to due process and equal protection. Adams was sentenced to a prison term of 30 years for attempted murder and a consecutive term of four years for involuntary manslaughter. He was assigned to work in the prison kitchen, but that assignment was rescinded due to concerns that he might use the assignment to smuggle drugs into the prison. He was later charged with offense A-100 for engaging in criminal gang activity related to an assault in the prison. Disciplinary Hearing Officer J. Peltier found Adams guilty of that offense on March 16. He was ordered to spend one year in disciplinary segregation, 365 days of his earned good time credits were revoked, and he was demoted from credit-earning class 1 to class 3.The United States Court of Appeals for the Seventh Circuit affirmed the district court's grant of summary judgment in favor of the defendants. The appellate court concluded that Adams' claim of First Amendment retaliation lacked sufficient evidence to suggest that the defendants were motivated by a retaliatory intent to pursue the assault charge against him. The court also held that Adams was not deprived of his Fourteenth Amendment due process rights, as prison disciplinary hearings require only informal due process, which leaves substantial flexibility in the hands of prison administrators. Regarding the Equal Protection claim, the court found no evidence that Adams was treated differently based on his race. Lastly, the court concluded that the defendants could not be held liable for violating Adams' Eighth Amendment rights as there was no evidence that they had control over the conditions of restrictive housing where Adams was placed. View "Adams v. Reagle" on Justia Law

In a case before the United States Court of Appeals For the Seventh Circuit, plaintiff Catherine Erdman, a firefighter from Janesville, Wisconsin, applied for a position with the Madison fire department. Erdman claimed that the Madison fire department's Physical Abilities Test (PAT), which she failed to pass, had a disparate impact on women, violating Title VII of the Civil Rights Act of 1964. Erdman proposed an alternative test, the Candidate Physical Abilities Test (CPAT), licensed by the International Association of Fire Fighters (IAFF), which she claimed would have less disparate impact on women while still effectively measuring an applicant's physical abilities.The district court found that Erdman had shown the Madison PAT had a prima facie disparate impact on women. However, it also found that the Madison PAT was job-related and served the city’s legitimate needs, and that Erdman had failed to prove that the IAFF test would adequately serve the city’s legitimate needs. Erdman appealed the decision.The appeals court affirmed the district court's ruling. It agreed that the Madison PAT as a whole, not its individual components, should be considered as the "particular employment practice" for the purpose of determining disparate impact. The court found that Erdman had established her prima facie case of disparate impact as the Madison PAT as a whole showed a statistically significant disparate impact on female applicants.However, the appeals court also agreed with the district court's finding that Erdman failed to prove that the IAFF test would serve the Madison fire department's legitimate needs as well as the Madison PAT. This was based on testimony that certain elements of the Madison PAT were specifically designed for Madison, considering the city’s characteristics, the fire department’s equipment, and safety considerations. Also, the court noted that the Madison fire department had a higher-than-average rate of hiring and retaining female firefighters compared to the national average, suggesting the effectiveness of the Madison PAT. View "Erdman v. City of Madison" on Justia Law

This case concerns Johnnie Wesley, who was brought in for questioning by Wisconsin police in connection with a murder investigation. Wesley invoked his right to remain silent during the initial interrogation, and the interrogation ceased. However, he was interrogated two more times, during which he made incriminating statements implicating himself in the murder. Wesley was subsequently charged with felony murder. He moved to suppress the incriminating statements on two grounds: (1) the officers did not honor his initial invocation of his right to remain silent, and (2) he unequivocally invoked his right to remain silent during the third interrogation. The motion was denied and Wesley was convicted. He then petitioned for a writ of habeas corpus in the Eastern District of Wisconsin, which was dismissed.On appeal to the United States Court of Appeals for the Seventh Circuit, the court affirmed the lower court's decisions. It held that the Wisconsin Court of Appeals reasonably applied Supreme Court precedent to Wesley’s case. The court determined that Wesley's right to remain silent was "scrupulously honored" after he invoked it during the first interrogation, and that he did not unequivocally invoke his right to remain silent during the third interrogation. The court reasoned that Wesley's statements during the third interrogation could reasonably be interpreted as exculpatory, rather than as an invocation of silence. View "Wesley v. Hepp" on Justia Law

This case involves Daryl McGhee, who was charged with several federal offenses related to possession of a firearm and cocaine. The charges arose after the police received a 911 call from McGhee's wife reporting domestic violence and alleging that McGhee had left their house carrying a gun and a leather bag. The police followed footprints in the snow to find McGhee and later found the bag, which contained the gun and cocaine, under a nearby dumpster. During the trial, the United States District Court for the Central District of Illinois issued an order prohibiting McGhee from testifying about the domestic violence incident, even to deny the allegation, threatening to jail him and his defense counsel if they violated the order.The United States Court of Appeals for the Seventh Circuit found that while the district court's decision to limit McGhee's testimony was valid as it avoided turning the trial into a domestic dispute, the order was overly broad as it completely silenced McGhee, leaving the jury to potentially conclude that he did hit his wife. Despite this, the appellate court concluded that the exclusionary order did not have a substantial influence over the jury and did not result in a verdict inconsistent with substantial justice. The court expressed concerns about the district court's treatment of McGhee's defense counsel but ultimately affirmed the district court's judgment. View "USA v. McGhee" on Justia Law

In this case, the United States Court of Appeals for the Seventh Circuit affirmed a district court's decision to grant summary judgment in favor of the defendants on all federal claims made by the plaintiff. The plaintiff, Lamont Moore, was an inmate who filed a suit against a prison guard and the prison where he was subsequently sent to, alleging failure to protect him from another inmate's attack, violation of his rights under the Americans with Disabilities Act (ADA), and a conspiracy among the investigating officers to falsify the official report of the incident.The court found that Moore was unable to demonstrate that the prison guard was aware of and disregarded an excessive risk to his safety, a requirement for a successful claim of failure to protect. Moore's testimony indicated that his complaints to the guard about the other inmate were about annoyance and horseplay, not a fear for his safety.Regarding his ADA claim, the court found that Moore failed to demonstrate that any disability-based discrimination was intentional. Moore complained about the distance to the healthcare unit but never alerted anyone at any prison that he required an accommodation in order to access services. He was able to access every service in prison, albeit more slowly due to his loss of vision in one eye. There was no evidence that any defendant knew that he could not access any services or made a deliberate choice to deny him access to services.After resolving all of the federal claims, the court declined to exercise supplemental jurisdiction over the state law claims. View "Moore v. Western Illinois Correctional Center" on Justia Law

The case involves Timothy Bell, who, after serving a sentence for sexual assault, remained incarcerated in an Illinois prison for over 16 years under the state’s Sexually Violent Persons Commitment Act. Bell sued two state officials under 42 U.S.C. § 1983, claiming that his civil commitment had exceeded the duration allowed by the Act. The district court dismissed Bell's case, citing the Supreme Court’s 1994 decision in Heck v. Humphrey as barring his claims. On appeal, the United States Court of Appeals for the Seventh Circuit agreed with the lower court's judgment.The main holding in the case is that Heck v. Humphrey's favorable-termination requirement, which prevents prisoners from using § 1983 to challenge the fact or duration of their confinement unless their conviction or disciplinary sanction has been invalidated, applies to civil detainees such as those confined under the Illinois Sexually Violent Persons Commitment Act. The court reasoned that like a prisoner wishing to contest a criminal conviction or sentence, a civil detainee cannot sue a state official under § 1983 for violating his constitutional rights when a judgment in the plaintiff’s favor would necessarily imply the invalidity of his confinement, unless the grounds for the confinement have already been set aside in other proceedings. This conclusion remains the same regardless of whether the individual is civilly committed or criminally imprisoned.Furthermore, the court pointed out that Bell's release from confinement to home confinement did not change the court's conclusion. The Heck bar applies until the judgment that caused the detention is invalidated, even after a detainee's release. Therefore, Bell must wait until he receives a favorable termination of his civil commitment before seeking relief under § 1983 for his allegedly excessively long confinement. View "Bell v. Raoul" on Justia Law

In this case heard by the United States Court of Appeals For the Seventh Circuit, Kimberly Barnes-Staples applied for a Real Estate Director position with the General Services Administration (GSA). However, the GSA hired another candidate. Barnes-Staples subsequently sued the GSA, alleging that the interview process discriminated against her because of her race and sex in violation of Title VII of the Civil Rights Act. The district court granted summary judgment in favor of the GSA.Barnes-Staples argued that the GSA did not follow its internal anti-discrimination procedures, which she claimed allowed the GSA to hire a less qualified candidate. She also contended that she was the superior candidate, so the GSA's assertion that the other candidate was more qualified was pretextual. Furthermore, Barnes-Staples asserted that there was a systemic practice of discrimination against Black candidates and employees within the GSA.The Appeals Court, however, found that Barnes-Staples was not "clearly better qualified" than the candidate who was hired. It also found no evidence that the GSA created interview questions to favor the other candidate, nor was there evidence that the GSA violated its own guidelines during the interview process. The court also noted that while Barnes-Staples presented data on promotion and employment rates within the GSA, she failed to provide sufficient context or detail for this data to support her claim of systemic discrimination.The Appeals Court affirmed the district court's grant of summary judgment in favor of the GSA. Additionally, it found that Barnes-Staples had waived her sex discrimination claim as she did not properly develop this argument before the district court. View "Barnes-Staples v. Carnahan" on Justia Law

In this case, the United States Court of Appeals for the Seventh Circuit examined the constitutionality of Cook County, Illinois's use of cameras to record holding cell toilets in courthouses throughout the county. The plaintiffs, pretrial detainees, claimed that the cameras infringed upon their Fourth Amendment privacy interests and also constituted an intrusion upon seclusion under Illinois law. The district court granted summary judgment in favor of the defendants, Cook County and Sheriff Thomas J. Dart, and the plaintiffs appealed.The Court of Appeals held that the plaintiffs did not have a reasonable expectation of privacy when using the toilets in courthouse holding cells. While it acknowledged that there are questions around the extent to which detainees have a reasonable expectation of privacy in their bodies while in a holding cell, it found that any privacy rights are substantially diminished. The court further held that Cook County's use of cameras in courthouse holding cells was reasonable due to the security risks inherent in the setting. The court also determined that one of the plaintiffs, Alicea, had standing to sue, but the other plaintiffs did not.Furthermore, the court affirmed the district court's decision to grant summary judgment on the plaintiffs' claim for intrusion upon seclusion. It held that the plaintiff had not met his burden on the fourth element of the claim, anguish and suffering.Lastly, the court affirmed the district court's decisions related to discovery and attorneys' fees. The court held that the district court did not abuse its discretion in these decisions. Thus, the judgment of the district court was affirmed. View "Alicea v. County of Cook" on Justia Law

Federal prisoner Sargeant filed a grievance against a prison official, Cruze, after she commented on his sexual preferences and refused to give him books that he had ordered. When Sargeant's case manager, Barfield, showed Sargeant the prison’s response, Sargeant noticed that it was signed by Cruze and pointed out that, under the prison’s rules, Cruze should not have seen a grievance lodged against her. Barfield then told others about the grievance. Sargeant filed a separate grievance against Barfield. In retaliation, Barfield “repeatedly” put Sargeant, who had cooperated with the government, in cells with prisoners known to be violent. This led to fights until Sargeant was transferred to another prison.Sargeant sued seeking monetary damages, alleging that Barfield retaliated against him for filing grievances. He did not identify which of his constitutional rights she had allegedly violated. In screening under 28 U.S.C. 1915A, the judge decided that Sargeant could proceed only on a First Amendment retaliation claim and did not discuss any possible Eighth Amendment claim. The Seventh Circuit affirmed the dismissal of the complaint. Under the Bivens doctrine, a federal prisoner cannot recover damages for a violation of First Amendment rights. Recognizing a failure-to-protect claim in this context would risk intrusion with the federal prison system; the claim presents separation-of-powers concerns and special factors not accounted for by any of the Supreme Court’s Bivens precedents. View "Sargeant v. Barfield" on Justia Law