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

After being stopped by Illinois State Police for speeding, a driver was questioned about his criminal history and denied a request to search his vehicle. The officer issued only a warning and allowed the driver to leave. However, the officer notified a nearby canine unit about his suspicions. Less than two hours later, the canine officer observed the driver commit another traffic infraction, pulled him over, and conducted a dog sniff that led to the discovery of drugs in the vehicle. The driver was subsequently indicted for possession with intent to distribute cocaine base.Reviewing the case, the United States District Court for the Central District of Illinois denied the driver’s motion to suppress the drug evidence, finding the second traffic stop was independently justified by a new traffic violation and that the dog sniff did not unreasonably prolong the stop. The district court also denied the driver’s motion to dismiss the indictment for vindictive prosecution and selective enforcement, concluding that there was no evidence of impermissible motives or that similarly situated individuals were treated differently. The driver entered a conditional guilty plea, reserving the right to appeal these rulings.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s decisions. The appellate court held that the initial traffic stop was unreasonably prolonged but that the evidence from the second stop was attenuated from this violation, as the second stop was based on an independent traffic infraction. The court also found the second stop was not unlawfully prolonged and that the dog sniff occurred during the normal course of the traffic warning process. Regarding the motion to dismiss, the court held the driver failed to raise a reasonable doubt that enforcement was selectively or vindictively motivated and upheld the denial of an evidentiary hearing. View "USA v Pennington" on Justia Law

The defendant was charged with producing, distributing, and possessing AI-generated images that depicted minors engaged in sexually explicit conduct, as well as transferring such material to a minor. The images were alleged to be created using Stable Diffusion, a text-to-image generative AI program, and did not involve real children. Law enforcement linked the defendant to these images after a report by Meta Platforms, which found the material sent to a minor on Instagram. A search of the defendant’s devices revealed hundreds of similar AI-generated images.In the United States District Court for the Western District of Wisconsin, the defendant moved to dismiss the count charging him with knowing possession of obscene virtual child sexual abuse material (CSAM) in violation of 18 U.S.C. § 1466A(b)(1). The district court granted the motion as to the possession charge, concluding that the statute was unconstitutional as applied in this context. The court reasoned that, under Stanley v. Georgia, individuals have a First Amendment right to possess obscenity in their homes, and that this right extends to virtual CSAM, especially in light of the Supreme Court’s decision in Ashcroft v. Free Speech Coalition, which distinguished virtual CSAM from material involving actual children. The court left the production and distribution charges intact.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s dismissal de novo. The Seventh Circuit held that Supreme Court precedent—specifically Stanley v. Georgia and Ashcroft v. Free Speech Coalition—controls the as-applied challenge. The court found that, because the images did not depict real children, the government’s justifications for banning their possession in the home had been expressly rejected by the Supreme Court. Accordingly, the Seventh Circuit affirmed the district court’s judgment, holding that 18 U.S.C. § 1466A(b)(1) is unconstitutional as applied to the defendant’s in-home possession of obscene virtual CSAM. View "USA v Anderegg" on Justia Law

In September 2020, Microsoft and Google each reported to the National Center for Missing and Exploited Children (NCMEC) that images suspected to be child sexual abuse material (CSAM) were uploaded from the same IP address to their platforms. The images were not viewed by the companies or by NCMEC; instead, they were flagged by automated systems after matching hash values of known CSAM. NCMEC forwarded these reports to the Wisconsin Department of Justice, which traced the IP address to Peter Braun's residence. Special Agent Aaron Koehler viewed the images without a warrant, conducted surveillance, and obtained a prior report from 2015 indicating Braun had been observed chatting online with very young girls. Based on this information, Koehler applied for and obtained a state search warrant for Braun’s home, leading to charges of producing CSAM.The United States District Court for the Eastern District of Wisconsin, after referral to a magistrate judge, granted Braun’s motion to suppress the evidence from the search. The district court found that Agent Koehler’s warrantless viewing of the images was unlawful, and that, excluding his descriptions of the images, the warrant affidavit did not establish probable cause. The court also determined that the good-faith exception to the exclusionary rule did not apply. The government appealed this decision.The United States Court of Appeals for the Seventh Circuit reviewed the case, applying de novo review to legal conclusions and clear error review to factual findings. The Seventh Circuit held that, even without the descriptions of the images obtained from the unlawful search, Agent Koehler’s affidavit contained sufficient information—such as the reliability of the reporting sources, the incriminating file name, and corroborating evidence regarding Braun’s prior behavior—to establish probable cause for the search. The court concluded that the decision to seek the warrant was not prompted by the unlawfully obtained information. Accordingly, the Seventh Circuit reversed the district court’s order suppressing the evidence. View "USA v. Braun" on Justia Law

An inmate incarcerated at an Indiana prison was twice transported by correctional officers between the facility and a hospital in June 2019. During the first transport, after a medical appointment, the inmate was placed in a van in restraining gear that prevented him from buckling his seatbelt, and the officers refused to buckle it for him. One of the officers then drove the van in a manner the inmate described as reckless, resulting in a sudden stop that threw the inmate to the floor and caused a broken collarbone. The inmate alleged the officers made threatening remarks referencing his prior grievances against staff and later colluded to create consistent incident reports. On the second transport, after surgery, the inmate was buckled in but not placed in the more secure area he requested. Officers drove in a way that jostled his recent injuries, deliberately drove over rough terrain and railroad tracks, and laughed in response to his pain.The United States District Court for the Southern District of Indiana allowed the inmate’s Eighth Amendment claims against three officers to proceed, along with First Amendment retaliation claims. At summary judgment, the district court granted qualified immunity to all three officers on the Eighth Amendment claims, finding that the law was not clearly established for the conduct alleged, and entered judgment for the officers. The court analyzed the claims under both deliberate indifference and excessive force standards, depending on the officer’s role and the facts alleged.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed in part and vacated in part. The court held that the officer who failed to buckle the inmate’s seatbelt and did not intervene during reckless driving on the first transport was not entitled to qualified immunity, as it was clearly established that subjecting a restrained inmate to reckless driving without a seatbelt posed a substantial risk of serious harm. However, the court affirmed summary judgment for the officers involved in the second transport, finding the law was not clearly established that their conduct—though troubling—violated the Eighth Amendment under the specific facts presented. The case against the first officer was remanded for further proceedings. View "Smith v. Price" on Justia Law

A nonprofit organization dedicated to election integrity requested a copy of Wisconsin’s voter registration list, seeking access under the National Voter Registration Act (NVRA). Wisconsin, however, is exempt from the NVRA because it has permitted same-day polling-place registration since before August 1, 1994. The state processed the request under its public-records law, which required redaction of birth dates and imposed a fee of $12,500 due to the size of the list. The organization objected to both the fee and the redactions, arguing that Wisconsin’s exemption from the NVRA was unconstitutional.The United States District Court for the Western District of Wisconsin dismissed the case. The district judge held that the plaintiff’s claims—asserting violations of the “equal state sovereignty” principle from Shelby County v. Holder and the “congruence and proportionality” requirement from City of Boerne v. Flores—were not supported by law. While the judge found that the plaintiff had Article III standing due to the alleged financial injury, he expressed doubt about prudential standing but decided the case on the merits, concluding that neither cited Supreme Court decision undermined the validity of Wisconsin’s exemption.The United States Court of Appeals for the Seventh Circuit reviewed the dismissal de novo. The court agreed that the plaintiff had Article III standing but questioned prudential standing, as the legal theories invoked state, rather than individual, rights. Nonetheless, the court bypassed this issue, holding that the NVRA’s exemption for states like Wisconsin does not violate equal state sovereignty or the congruence and proportionality standard. The court emphasized that the exemption relieves, rather than imposes, federal regulatory burdens and that Congress acted under its Elections Clause authority, making City of Boerne inapplicable. The Seventh Circuit affirmed the district court’s dismissal. View "Public Interest Legal Foundation, Inc. v. Wolfe" on Justia Law

In 2017, Indiana enacted a statute known as the “aid-or-assist” law, which prohibits any person from knowingly or intentionally assisting an unemancipated pregnant minor in obtaining an abortion without fulfilling the state’s parental consent and notice requirements. Planned Parenthood, a nonprofit operating health centers in Indiana, regularly provides minors with factually accurate information and referrals about lawful abortion services in neighboring states, particularly after Indiana enacted more restrictive abortion laws following Dobbs v. Jackson Women’s Health Organization. Both parties agreed that, without adherence to Indiana’s parental consent law, providing such information would violate the aid-or-assist statute, exposing Planned Parenthood and its physicians to civil liability and professional discipline.After the law’s passage, Planned Parenthood filed suit in the United States District Court for the Southern District of Indiana, challenging the statute under the First Amendment as applied to its provision of information and referrals to minors about lawful out-of-state abortion services. The district court initially granted a preliminary injunction, and after changes in federal and state abortion law, ultimately issued a permanent injunction preventing enforcement of the aid-or-assist law as applied to Planned Parenthood’s speech and referrals about legal abortion practices in other states. The district court reasoned that the statute was a content-based restriction on protected speech and failed strict scrutiny.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the permanent injunction, with one modification: it removed the Commissioner of Health as a defendant because the Commissioner no longer had authority to provide relief. The Seventh Circuit held that Planned Parenthood’s provision of information and referrals about legal out-of-state abortion services was protected speech under the First Amendment. The court found that Indiana’s law, as applied, was a content- and viewpoint-based restriction that failed strict scrutiny, as it was not narrowly tailored to serve compelling state interests. The injunction was affirmed as modified. View "Planned Parenthood Great Northwest, Hawai'i v Commissioner of the Indiana State Department" on Justia Law

Derek Fields was involved in a violent kidnapping in September 2015, during which he and his co-defendants abducted Adrian Harris, inflicted physical harm, and demanded ransom. Fields was arrested within days alongside his co-defendants and indicted on several charges, including kidnapping, making a ransom demand, and firearm offenses. The government extended multiple plea offers, each carrying substantial prison time, but Fields consistently rejected them, viewing sentences over twenty years as tantamount to a life sentence. After his motion to suppress evidence was denied, Fields proceeded to trial, was convicted on all counts, and originally sentenced to 53 years. On appeal, his conviction under one firearm statute was vacated pursuant to United States v. Davis, 588 U.S. 445 (2019), and he was resentenced to 43 years.After his conviction became final, Fields filed a motion under 28 U.S.C. § 2255 in the United States District Court for the Northern District of Indiana, arguing that his last counsel was constitutionally ineffective for failing to adequately advise him about an alleged 37-year plea offer presented during jury selection. The district court denied the motion without an evidentiary hearing, focusing primarily on a different plea agreement attached to Fields’s reply brief, and concluded that Fields failed to show prejudice because he did not establish a reasonable probability he would have accepted the offer and received a lower sentence.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s denial de novo for legal questions and for abuse of discretion regarding the lack of an evidentiary hearing. The Seventh Circuit assumed, for argument’s sake, that the alleged 37-year plea offer existed and that counsel’s advice was inadequate, but found that Fields did not demonstrate a reasonable probability he would have accepted the plea or received a lower sentence. The court therefore affirmed the district court’s denial of Fields’s § 2255 motion without an evidentiary hearing. View "Fields v. USA" on Justia Law

In 1977, a 14-year-old was questioned by police in Peoria, Illinois, about the murder of two teenagers. Over roughly two days, police and a polygraph examiner interrogated him, at times using harsh tactics. He eventually confessed and was convicted of first-degree murder. The state appellate court later overturned the conviction, finding the confession involuntary. He was retried, convicted again, and served decades in prison before being released on parole in 2006. In 2014, he was pardoned by the governor. Years later, he filed a civil suit under 42 U.S.C. § 1983 against 16 former police officers, the City of Peoria, and the polygrapher, alleging unlawful detention, coercion of his confession, and destruction and fabrication of evidence.The United States District Court for the Central District of Illinois denied summary judgment to the defendants, concluding that material factual disputes precluded resolution of the unlawful detention claim, that clearly established law would have put the officers and the polygrapher on notice their interrogation tactics were unconstitutional, and that a reasonable jury could find evidence destruction and fabrication in violation of established law.On appeal, the United States Court of Appeals for the Seventh Circuit reversed. The court held the officers were entitled to qualified immunity for the unlawful detention claim, finding they had arguable probable cause based on the totality of the circumstances. The court also found no evidence the officers destroyed evidence in bad faith or at a time when its exculpatory value was apparent, and held there was no clearly established law making their actions unconstitutional at the relevant times. Additionally, the court concluded that the coercion claim failed because no then-existing precedent put the unconstitutionality of the officers’ interrogation methods “beyond debate.” Finally, the court held the officers were entitled to absolute immunity for testimony at trial, even if it was consistent with allegedly fabricated evidence not introduced at trial. Accordingly, the district court’s denial of immunity was reversed. View "Savory v Andrews" on Justia Law

Four professors employed by Indiana’s public universities brought a facial constitutional challenge against a new state law, which mandates that university boards adopt and enforce policies promoting “free inquiry, free expression, and intellectual diversity.” The law conditions tenure and promotion decisions, as well as periodic reviews of tenured faculty, on compliance with these principles. The professors argued that these requirements, and related university policies, compelled them to alter their teaching and course materials, thereby chilling their First Amendment rights. They described changes they made to their syllabi and teaching practices out of concern for violating the law or university policies, but none had faced discipline or explicit threats as a result.Previously, the United States District Court for the Southern District of Indiana dismissed the professors’ initial suit for lack of standing, finding no credible threat of enforcement since the law regulated university boards rather than faculty directly. After the universities adopted “interim” policies to implement the law, the professors sued again, targeting both the statute and these new policies. The district court again dismissed the case, reasoning that the professors’ fears of enforcement were speculative because the policies were not final and no actions had been taken against them under the new regime.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal for lack of subject-matter jurisdiction. The Seventh Circuit held that the professors failed to establish Article III standing, as they did not demonstrate a credible threat that the law or university policies would actually be enforced against them, nor an objectively reasonable chilling effect on their speech. The court emphasized that neither the indirect application of the law nor the interim status of the policies categorically precluded standing, but found that the record did not support a sufficient injury-in-fact to proceed. View "McDonald v Trustees of Indiana University" on Justia Law

The case involves a criminal defendant who was convicted on federal charges after law enforcement conducted a search of his home. The search was carried out pursuant to a warrant, and evidence seized during the search was used to support the prosecution’s case. The defendant challenged the lawfulness of the search, arguing that the affidavit supporting the warrant application contained misrepresentations or omissions that were material to the finding of probable cause.At trial in the United States District Court for the Northern District of Illinois, the defendant sought to suppress the evidence obtained during the search, contending that the warrant was not supported by probable cause due to false or misleading statements in the supporting affidavit. The district court denied the motion to suppress, finding that the affidavit provided a sufficient basis for probable cause and that any alleged inaccuracies were not material. The defendant was subsequently convicted, and he appealed, renewing his arguments regarding the validity of the search warrant.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s denial of the suppression motion. The appellate court held that in order to invalidate a search warrant under Franks v. Delaware, 438 U.S. 154 (1978), a defendant must show that the affidavit included deliberately or recklessly false statements, and that those statements were necessary to a finding of probable cause. The Seventh Circuit found that the defendant failed to make this showing. The court concluded that, even excising the challenged statements, the remaining contents of the affidavit were sufficient to establish probable cause. Therefore, the court affirmed the judgment of the district court, upholding the defendant’s conviction. View "Sunco International Inc. v Jiangsu Sunco Boiler Co., Ltd." on Justia Law