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

Nathaniel Jacobs was found guilty by a jury of several drug and gun possession offenses, as well as witness tampering. The case began when Jacobs appeared at a hospital with a gunshot wound and admitted to police that he had accidentally shot himself with a firearm he was not legally allowed to possess. A search of his home revealed firearms, ammunition, and drug-related evidence, including methamphetamine and paraphernalia. Jacobs was indicted on multiple counts, including illegal possession of firearms, possession with intent to distribute methamphetamine, possession of a firearm in furtherance of a drug trafficking crime, and witness tampering.The United States District Court for the Southern District of Indiana handled the initial proceedings. During pretrial, the court granted a government motion to exclude evidence of Jacobs’s girlfriend’s pending criminal charges, which Jacobs wanted to use to suggest her potential bias. The jury trial proceeded, and Jacobs was convicted on all counts.The United States Court of Appeals for the Seventh Circuit reviewed the case. Jacobs raised two issues on appeal: a violation of his Sixth Amendment rights due to the district court's restriction on cross-examining his ex-girlfriend about her potential bias, and a Fourth Amendment challenge regarding the admission of drug evidence found in his home. The appellate court found that any potential Sixth Amendment violation was harmless beyond a reasonable doubt due to the overwhelming evidence against Jacobs. Additionally, the court determined that Jacobs had not shown good cause for failing to file a suppression motion regarding the drug evidence and that the search of the tobacco cans was within the scope of the warrant.The Seventh Circuit affirmed the district court’s judgment, upholding Jacobs’s convictions. View "United States v. Jacobs" on Justia Law

Efrain Leonides-Seguria, a Mexican citizen without legal status in the United States, was detained by Immigration and Customs Enforcement (ICE) on June 15, 2021, for illegal reentry. Six days later, ICE referred him for criminal prosecution. On June 23, federal prosecutors filed a criminal complaint, and a magistrate judge issued an arrest warrant. Leonides-Seguria remained in immigration custody until June 28, when he was arrested on the criminal complaint. He later waived prosecution by indictment, consenting to the filing of a criminal information on July 27.The United States District Court for the Northern District of Illinois denied Leonides-Seguria’s motions to dismiss the federal charge, arguing that the government violated the Speedy Trial Act and that 8 U.S.C. § 1326 is unconstitutional. He pled guilty but reserved the right to appeal these denials. The district court sentenced him to 51 months’ imprisonment.The United States Court of Appeals for the Seventh Circuit reviewed the case. Leonides-Seguria argued that the Speedy Trial Act was violated because the criminal information was filed more than 30 days after his apprehension. He urged the court to recognize a "ruse exception," where civil detention by immigration authorities is used to delay criminal prosecution. The Seventh Circuit declined to resolve the legal question of the ruse exception, finding that the facts did not support its application. The court found no evidence of collusion between ICE and federal prosecutors to circumvent the Speedy Trial Act. The court affirmed the district court’s denial of the motion to dismiss and upheld the constitutionality of 8 U.S.C. § 1326, consistent with precedent. The Seventh Circuit affirmed the district court’s judgment. View "USA v Leonides-Seguria" on Justia Law

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

Plaintiffs, LSP Transmission Holdings II, LLC, and affiliates, sought to build and operate interstate electricity transmission lines in Indiana. An Indiana statute granted incumbent electric companies the right of first refusal to build and operate new interstate transmission facilities connecting to their existing facilities. Plaintiffs argued that this statute violated the dormant commerce clause of the U.S. Constitution. The district court issued a preliminary injunction preventing the Indiana Utility Regulatory Commission (IURC) Commissioners from enforcing the statute.The IURC Commissioners and several intervening defendants appealed the injunction. They argued that the IURC did not enforce the rights of first refusal and that the injunction would not redress plaintiffs' injuries. The district court had found that plaintiffs had standing because it believed the IURC enforced the rights of first refusal and that an injunction would prevent MISO from recognizing the statute.The United States Court of Appeals for the Seventh Circuit vacated the preliminary injunction, finding that plaintiffs lacked standing. The court concluded that the IURC had no relevant responsibilities for enforcing the challenged statute and that any genuine redress would have to operate against MISO, a non-governmental entity not party to the lawsuit. The court noted that MISO had made clear it would not respond to the preliminary injunction as plaintiffs and the district court expected. The court also rejected a dissenting opinion's novel theory of standing, which was not presented by plaintiffs or adopted by the district court. The case was remanded to the district court for further proceedings. View "LSP Transmission Holdings II, LLC v Commonwealth Edison Company of Indiana, Inc." 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

In August 2022, Jamond Rush was charged with possessing an unregistered firearm, specifically an AR-15 rifle with a 7.5-inch barrel, in violation of the National Firearms Act (NFA). Rush moved to dismiss the indictment, arguing that the statute under which he was charged was unconstitutional based on the Supreme Court's decision in N.Y. State Rifle & Pistol Ass’n, Inc. v. Bruen. The government opposed, citing the Supreme Court's earlier decision in United States v. Miller, which upheld similar regulations. The district court denied Rush's motion, holding that Bruen did not affect the constitutionality of regulating unregistered short-barreled rifles. Rush entered a conditional guilty plea, reserving the right to appeal the denial of his motion to dismiss, and was sentenced to 30 months in prison.The United States District Court for the Southern District of Illinois reviewed the case and denied Rush's motion to dismiss, leading to his appeal. The court held that Rush's conduct was not protected by the Second Amendment's plain text or historical understanding.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's decision, holding that the NFA's requirement to register certain firearms, including short-barreled rifles, is constitutional. The court relied on the precedent set by United States v. Miller, which upheld similar regulations, and found that the NFA's provisions are consistent with the historical tradition of firearm regulation. The court concluded that the regulation of short-barreled rifles does not violate the Second Amendment, as these weapons are not typically possessed by law-abiding citizens for lawful purposes like self-defense. The court affirmed Rush's conviction and the denial of his motion to dismiss. View "United States v. Rush" on Justia Law

Edward Gibbs was indicted in August 2018 for conspiracy to possess with intent to distribute and to distribute 500 grams or more of methamphetamine mixture. He pleaded guilty in November 2020 and was sentenced to 200 months of imprisonment and 5 years of supervised release. Gibbs appealed the sentence, and the case was remanded for resentencing due to a sentencing error. Before resentencing, the United States Probation Office recommended twenty-one conditions of supervised release, including conditions "m" and "r."The United States District Court for the Southern District of Indiana, Evansville Division, resentenced Gibbs to 180 months of imprisonment and 5 years of supervised release. During the resentencing hearing, Gibbs confirmed that he had reviewed the proposed conditions of supervision with his attorney and had no objections. He also waived a formal reading of the conditions. The district court entered an amended final judgment on September 1, 2023.The United States Court of Appeals for the Seventh Circuit reviewed the case. Gibbs argued for the first time on appeal that two conditions of his supervised release were unconstitutionally vague and overbroad. The court determined that Gibbs had waived his objections to these conditions by affirmatively stating at the resentencing hearing that he had no objections and by waiving the formal reading of the conditions. The court held that this waiver precluded appellate review of his claims. Consequently, the Seventh Circuit affirmed the judgment of the district court. View "USA v Gibbs" 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

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.The United States District Court for the Central District of Illinois reviewed the case. The defendants, Larry Lyons and Brock Spack, filed a motion to dismiss the complaint under Rule 12(b)(6), arguing that they were entitled to qualified immunity. The district court denied the motion, stating that factual development was necessary before resolving the question of qualified immunity. The court found that Beathard had made a viable claim that his speech was personal and protected, but it was premature to engage in the Pickering balancing test at the pleading stage.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 pending further factual development. 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 issue of qualified immunity, which was not the case here. Therefore, the appeal was dismissed for want of appellate jurisdiction. View "Rogers v. Byroad" 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