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

Bailey was detained for 23 days while police investigated a 2009 Chicago schoolyard brawl that resulted in the death of another student. A video of the incident showed an attacker who punched victim as he tried to stand up. Detectives showed the video to Officer Massey, who was assigned to the school and had worked there for several years. Massey identified Bailey and another student as assailants. She claimed that she had known Bailey for 18 months, and recognized his face. They also showed the video to another student (then-suspect) who witnessed the fight; he identified Bailey as one of the attackers and told detectives that he knew him from school. Two school staff members also identified Bailey on the video. The charges against him were ultimately dropped after the investigation revealed that five other persons, but not Bailey, were involved in the fight. Bailey sued, claiming malicious prosecution, intentional infliction of emotional distress, and violations of his civil rights under 42 U.S.C. 1983. The district court granted summary judgment for the defendants. The Seventh Circuit affirmed, finding no evidence that the delay was imposed for improper motivations such as punishing Bailey or drumming up evidence to justify his arrest. View "Bailey v. City of Chicago" on Justia Law

Since 1982 Chicago has provided free or subsidized health care to certain retirees who receive pension benefits. In 2013 the ordinance establishing those benefits expired. After being notified that they would have to pay more for medical coverage in 2014, the retirees filed suit, alleging that any reduction of health care or increase in the retirees’ contribution toward it violated Art. XIII 5 of the Illinois Constitution, which says that “[m]embership in any pension or retirement system of … any unit of local government … shall be an enforceable contractual relationship, the benefits of which shall not be diminished or impaired” and the Contracts Clause of the U.S. Constitution. Following removal, the district court dismissed the suit, ruling that the Illinois Pensions Clause does not apply to health care. While the case was on appeal, the Supreme Court of Illinois held that the Pensions Clause applies to health benefits. The Seventh Circuit vacated, noting that the Illinois case did not address the exact issue in this case. Because the Supreme Court of Illinois has granted review of a similar case and because this suit began in state court, relinquishing supplemental jurisdiction is preferable to certifying questions to the state judiciary. View "Underwood v. City of Chicago" on Justia Law

Austin, an Indiana inmate, was assigned, for one day, to do construction work in the crawl space of a parole office near the prison. Austin was punished in a prison disciplinary proceeding for having attempted to traffic in tobacco. He lost 60 days of good-time credit, was demoted from “credit class 1” to “credit class 2” (inmates in the first class earn one day of good time credit for each day of imprisonment; in the second class they earn one day for every two days), was given 20 hours of extra work duty, and was denied access to the commissary for 25 days. The evidence consisted of a guard’s statement: shaking down the crawl spase [sic] at the Gary Parole Office … found 5 packs of Bugler cigarette papers, 1 ziploc bag that appears to have tobacco in it, 2 ziplock [sic] bags filled with more ziplock [sic] bags … Austin … was assigned to this area. Austin sought habeas corpus relief, 28 U.S.C. 2254. The district court denied relief, ruling that the evidence, though scanty, was adequate to prove “constructive possession” of tobacco. The Seventh Circuit reversed, stating that, convicted without evidence of guilt, Austin was denied due process of law. View "Austin v. Pazera" on Justia Law

McManus, on trial for murdering his wife and young daughters, decompensated during testimony. He had several panic attacks; his symptoms required two trips to the emergency room. He was treated with a combination of psychotropic drugs—including one that knocks out memory—and an opioid painkiller. He remained on mind-altering medications for the duration of the trial. The judge never ordered a competency evaluation, but focused on getting McManus “fixed up” enough to complete the trial, and sentenced him to death. The Indiana Supreme Court affirmed on direct appeal, but on post-conviction review the trial judge found McManus intellectually disabled and ineligible for the death penalty (IND. CODE 35-36-9-6). The Indiana Supreme Court disagreed and reimposed the death sentence. McManus sought federal habeas review. The district court denied relief. The Seventh Circuit reversed. While McManus is not entitled to habeas relief on his claim of categorical ineligibility for the death penalty, the powerful effect of the medications alone created substantial doubt about his fitness for trial. The approach taken by the trial judge failed to apply the correct legal framework for competency questions. The Indiana Supreme Court recited the correct legal standard but did not actually apply it. View "McManus v. Neal" on Justia Law

Defendant-appellant Christopher Baines pled guilty to one count of conspiracy to possess with the intent to distribute heroin, for which he received a 240-month sentence in prison. Defendant appealed, raising three issues: (1) the district court improperly attributed significant quantities of heroin to him a relevant conduct in determining his sentence; (2) the district court failed to sufficiently account for his mitigation evidence; and (3) in light of a recent amendment to the Sentencing Guidelines with regard to certain drug trafficking offenses, defendant qualified for a lesser sentence. Finding no reversible error, the Seventh Circuit Court of Appeals affirmed defendant's conviction and sentence. View "United States v. Baines" on Justia Law

The Driver’s Privacy Protection Act (DPPA), 18 U.S.C. 2721, prohibits individuals from knowingly obtaining or disclosing “personal information” from a motor vehicle record. Chicago police officers brought suit against Sun-Times Media, alleging that the publishing company violated the DPPA by obtaining each officer’s birth date, height, weight, hair color, and eye color from the Illinois Secretary of State’s motor vehicle records, and publishing that information in a newspaper article that criticized a homicide investigation lineup in which the officers participated. Sun-Times unsuccessfully moved to dismiss the officers’ complaint, arguing that the published information does not constitute “personal information” within the meaning of the DPPA, or, in the alternative, that the statute’s prohibition on acquiring and disclosing personal information from driving records violates the First Amendment’s guarantees of free speech and freedom of the press. The Seventh Circuit affirmed. DPPA’s definition of “personal information” extends to the details Sun-Times published here; Sun-Times possesses no constitutional right either to obtain the officers’ personal information from government records or to subsequently publish that unlawfully obtained information. View "Dahlstrom v. Sun-Times Media, LLC" on Justia Law

Wagoner, a paraplegic since a 1996 accident, is incarcerated by IDOC. Five years into his confinement, Wagoner filed a complaint, asserting that IDOC failed to accommodate his disability, citing humiliating toileting arrangements; a cell so small that Wagoner had to move his wheelchair to allow his cellmate to use the toilet; sidewalks that caused him to tip out of his wheelchair; no access to the weight room or the library; problems with his wheelchair; failures to provide other medical supplies; exclusion from job training; and transportation in a vehicle not equipped for wheelchairs. IDOC argued that Wagoner had failed to exhaust administrative remedies, citing the Prison Litigation Reform Act, 42 U.S.C. 1997e(a). Wagoner sought a “Pavey hearing.” The court denied the motion, stating that Wagoner had not established that a dispute of fact existed and could use his response to Defendants’ summary judgment motion to create a record. Wagoner filed a brief opposing summary judgment and a second Pavey motion, with a deposition excerpt detailing IDOC’s threats when he filed grievances and support for his futility claim. The district court granted IDOC summary judgment, refusing to consider the Pavey motion. The Seventh Circuit affirmed. It is better practice to hold a Pavey hearing before considering summary judgment, but there was no reversible error. The court correctly concluded that no material facts were disputed. View "Wagoner v. Ind. Dep't of Corrs." on Justia Law

Jones was charged with a 1998 Chicago shooting and convicted of first-degree murder and first-degree attempted murder. After exhausting state appeals and post-conviction remedies, he sought habeas relief under 28 U.S.C. 2254, claiming: that his convictions were based on insufficient evidence; that he received ineffective assistance from his trial and appellate counsel; and that his rights to due process were violated by the denial of a post-conviction petition. The Seventh Circuit affirmed the district court’s denial of relief. The court noted that the primary witness’s testimony was corroborated; that, in light of all of the evidence, Jones was not prejudiced by any of his attorney’s claimed failings; and that, absent a constitutional claim, the district court was correct in denying habeas relief for the failure of the Illinois courts to hold an evidentiary hearing. View "Jones v. Butler" on Justia Law

After his acquittal by a jury on burglary charges, Saunders-El sued members of the Rockford, Illinois police department, alleging that they planted his blood at the crime scene in an attempt to frame him. His complaint included a 42 U.S.C. 1983 claim that by fabricating evidence, the officers offended his due process rights, and state law claims for malicious prosecution and intentional infliction of emotional distress. The district court granted summary judgment for the officers, reasoning that fabricating evidence does not violate a defendant’s due process rights and cannot support a section 1983 action; such an allegation must instead be brought as a state law claim for malicious prosecution. The Seventh Circuit affirmed the dismissal on different grounds. A criminal defendant’s due process rights may be violated—actionable by way of 42 U.S.C. 1983—when the evidence against him is fabricated. However, due process is not implicated when, as here, the defendant is released on bond following his arrest and acquitted at trial. The rule cannot be circumvented simply by reframing such an allegation as a Brady claim: alleging that the police officers who supposedly fabricated the evidence failed to reveal their misconduct to the prosecution. View "Saunders-El v. Rohde" on Justia Law

Taylor engaged in sexual acts in front of a webcam during online chats with a law-enforcement officer posing as a 13-year-old girl. He was convicted of attempting to use the facilities of interstate commerce to engage in criminal sexual activity with a minor, 18 U.S.C. 2422(b). The Seventh Circuit reversed, holding that “sexual activity” under 2422(b) requires evidence of physical contact. Taylor was recharged and convicted for the same conduct for attempting to transfer obscene material to a minor using a means of interstate commerce, 18 U.S.C. 1470. The Seventh Circuit affirmed, rejecting arguments based on the Double Jeopardy Clause; the district court’s handling of strikes for cause during jury selection; limitations on his cross-examination of law-enforcement officers; and the court’s determination that his conviction triggers the registration requirements of the Sex Offender Registration and Notification Act, 42 U.S.C. 16911(5)(A)(ii), (7)(I). The court noted that Taylor’s double-jeopardy claim is foreclosed by Supreme Court precedent; that Taylor used peremptory strikes to remove two of the three jurors about whom he complained and did not object to the third; that the relevance of the excluded cross-examination was tenuous at best; and that a procedural impediment prevents review of the SORNA ruling. View "United States v. Taylor" on Justia Law