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

Thomas was wanted by Indiana officials and warrants had been issued for his arrest. Thomas obtained fake identification documents, including one issued by North Carolina under the name “Alredius”. Using that fictitious identity, Thomas leased an Atlanta condominium. Federal officials arrested him outside the building. Thomas’s landlord stated that she had rented the unit to “Alredius Frieson.” With the landlord’s consent, officers searched the condo, finding drugs, drug paraphernalia, and cell phones. After obtaining warrants to search the phones, the officers discovered evidence that Thomas was trafficking methamphetamine. Charged under 21 U.S.C. 841(a)(1), 841(b)(1)(A), 846, Thomas unsuccessfully moved to suppress the evidence.The Seventh Circuit reversed. A tenant lawfully may exclude others, even when the landlord consents to a search. Using an alias to sign a lease does not deprive a tenant of a legitimate expectation of privacy. A Georgia tenant who deceives or even defrauds a landlord is entitled to retain possession of the residence until the landlord has provided notice and obtained a judicial order. Thomas’s landlord could not summarily terminate his protections without violating Georgia law, nor could she consent to a warrantless search of his condo. A breach of a rental agreement does not automatically deprive the breaching party of a legitimate expectation of privacy. View "United States v. Thomas" on Justia Law

People working part-time may qualify for weekly unemployment benefits, but must accurately report their income so the Indiana Department of Workforce Development can reduce their benefits accordingly. A claimant who knowingly fails to disclose earnings on a weekly application must repay all benefits received for that week and is subject to a civil penalty of 25% of that forfeited amount. Grashoff omitted her part-time income on 24 weekly applications. The Department determined that she knowingly violated the law and assessed a forfeiture and penalty totaling $11,190. An ALJ affirmed the sanction. Grashoff did not seek state judicial review but filed suit under 42 U.S.C. 1983 alleging that the sanction violates the Eighth Amendment’s Excessive Fines Clause. The district court rejected the claim, classifying the entire forfeiture as remedial rather than punitive. The penalty is a punitive sanction subject to Eighth Amendment scrutiny but is not grossly disproportionate to the seriousness of the offense.The Seventh Circuit affirmed. Grashoff conceded that the difference between the benefits she received and the smaller amount she would have received had she reported her income is purely remedial. The remaining forfeiture amount, even when considered together with the 25% penalty, is not a grossly disproportionate sanction for Grashoff’s knowing violations of the law. View "Grashoff v. Payne" on Justia Law

Williams was a key facilitator in a years-long cocaine trafficking scheme. In 2001, he was convicted of federal drug and conspiracy charges, 18 U.S.C. 841(a)(1), 846 and given life sentences. Williams appealed the denial of his 18 U.S.C. 3582(c)(1)(A) motion for a reduced sentence, arguing that the district court erred in holding that it was not permitted to consider whether Williams’s unconstitutionally imposed mandatory life sentence contributed to “extraordinary and compelling reasons” for the reduction of his sentence.The Seventh Circuit affirmed, declining to reconsider its 2021 "Thacker" decision, stating it would make no difference to Williams’s case. The district court held in the alternative that even if Williams was eligible for a reduction in his sentence, this relief was not warranted in light of 18 U.S.C. 3553(a)'s factors. The court acknowledged different approaches among the circuits regarding the bounds of court discretion to find extraordinary and compelling reasons for early release— specifically, whether the two-step process employed by the Seventh Circuit is correct or if a more holistic approach is called for. The court noted that the U.S. Sentencing Commission is in the process of studying the issue, and recently has proposed defining “extraordinary and compelling reasons” to include circumstances in which “[t]he defendant is serving a sentence that is inequitable in light of changes in the law.” View "United States v. Williams" on Justia Law

Dr. Bounds was hired for one year beginning in July 2019 as an at-will employee. In February 2020, Dr. Scott stated that Scott would recommend that Bounds's contract be renewed. Scott notified Bounds and others on March 24 that she would email approved contracts and that they had until March 31 to sign and return the contracts. Upon receiving the contract, Bounds noted that her vacation days had been reduced. Scott told Bounds to contact the Board. Later that day, Bounds became ill and was advised to quarantine for 14 days. Bounds testified that she made inquiries to the Board but never received a reply. On April 1, Scott telephoned Bounds, who had not returned the signed contract. Bounds replied that she wanted her attorney to review the agreement. Scott warned that the Board previously had released another administrator who did not sign her contract by the deadline. The following day, Scott advised Bounds that the Board had requested that her position be posted as vacant. On April 14, Bounds was notified that her position had been posted.Bounds filed suit, 42 U.S.C. 1983, contending that the Board had deprived her of procedural due process by rescinding her contract and posting her position without notice or the opportunity to be heard. The Seventh Circuit affirmed summary judgment in favor of the defendants. Bounds did not have a property interest subject to due process protections. Bounds had no enforceable expectation as to her continued employment. View "Bounds v. Country Club Hills School District 160" on Justia Law

Brownsburg Community School Corporation requires its high school teachers to call all students by the names registered in the school’s official student database. Kluge, a teacher, objected on religious grounds to using the first names of transgender students to the extent that he deemed those names not consistent with their sex recorded at birth. After Brownsburg initially accommodated Kluge’s request to call all students by their last names only, the school withdrew the accommodation when it became apparent that the practice was harming students and negatively impacting the learning environment for transgender students, other students in Kluge’s classes and in the school generally, and the faculty.Kluge brought a Title VII religious discrimination and retaliation suit after he was terminated from his employment. The district court granted the school summary judgment, concluding that the school was unable to accommodate Kluge’s religious beliefs and practices without imposing an undue hardship on the school’s conduct of its business of educating all students and rejected Kluge’s retaliation claim.The Seventh Circuit affirmed. The undisputed evidence demonstrates that Kluge’s accommodation harmed students and disrupted the learning environment. No reasonable jury could conclude that harm to students and disruption to the learning environment are de minimis harms to a school’s conduct of its business. View "Kluge v. Brownsburg Community School Corp." on Justia Law

In July 2013, Koger began serving a 300-day sentence in Cook County Jail. While incarcerated, he received 42 books by mail. Per Jail policy, contained in the Inmate Information Handbook, inmates can keep no more than three books or magazines (excluding religious texts) in their cell at any time. Koger received a copy of the Handbook. Inmates with excess books can mail them out of the Jail using supplies available at the Jail commissary, can have someone outside the Jail pick up personal property, and are free to donate their books to other inmates. The policy was not strictly enforced during Koger’s stay.In October 2013, Jail administrators warned Koger they would soon search cells and take excess books. On October 5, officers searched the cells and took all but three books from Koger’s cell. Koger did not file a grievance. The Jail acknowledges the search but disputes whether any books were taken and what became of them. The Jail has no policy for dealing with confiscated books. The Jail released Koger on October 24, 2013; he died in 2020.Koger’s suit under 42 U.S.C. 1983 has twice previously been before the Seventh Circuit, which affirmed the district court’s summary judgment rejection of Koger’s claim that the county deprived him of his books without due process. Koger received constitutionally sufficient due process surrounding any property deprivation, and presented insufficient evidence to hold the county liable under “Monell.” View "Orozco v. Dart" on Justia Law

The primary source of incriminating information against Taylor was “Doe,” a woman with whom Taylor and his wife were intimately involved. Law enforcement presented a warrant application to an Indiana judge, seeking to search Taylor’s residence for evidence of child pornography and bestiality. The affidavit did not disclose that two officers involved in the investigation had been competing with Taylor for Doe’s affection. The judge signed a typed warrant that authorized the search of Taylor’s residence for evidence of child pornography; it did not mention bestiality. At a time unknown and under unknown circumstances, the lead detective apparently made handwritten alterations, adding “bestiality” to the warrant’s scope. When officers executed the altered warrant, they found substantial evidence that Taylor was producing and distributing child pornography. They found no evidence relating to bestiality. Taylor's motion to suppress and request for a Franks hearing were denied. Taylor pled guilty and was sentenced to 324 months.The Seventh Circuit vacated. An evidentiary hearing is needed to determine whether the judge approved the alterations before the warrant's execution. Questions surrounding those alterations are relevant to the good-faith exception to the exclusionary rule so the hearing must encompass false statements and material omissions in the affidavit and law enforcement’s subjective good faith in seeking the warrant. The affidavit did not support probable cause to search for evidence of child pornography but did support probable cause to search for evidence of crimes of bestiality. View "United States v. Taylor" on Justia Law

Another detainee threw hot coffee on King while the assigned tier officer, Szul, was gone, assisting another officer. When Szul returned, King stated that he needed medical attention. King was not examined until the next day. He was transferred to Stroger Hospital. A jail employee gave King an Inmate Grievance Response/Appeal Form for his failure-to-protect grievance, stating: “Your allegation(s) have been forwarded to the Offices of Professional Review [OPR] and Divisional Superintendent for review and/or investigation. You may follow-up with [OPR]”; “[t]o exhaust administrative remedies, grievance appeals must be made within 15 calendar days." The response to his delayed-treatment grievance stated only that he had been treated at Stroger Hospital and referred to exhausting administrative remedies. King appealed that response. King was later interviewed for the OPR investigation and signed a “Detainee/Complaint Notification,” stating, “I understand that if I do not file a complaint register within 10 days that OPR will close the investigation.” King did not file a complaint register.In King's section 1983 suit, the court granted the defendants summary judgment for failure to exhaust administrative remedies. Although King appealed his delayed-medical-treatment grievance, he failed to give the defendants notice of the claim because it did not allege wrongdoing by any correctional officer. The Seventh Circuit reinstated the failure-to-protect claim. Because the jail’s procedure for grievances that are referred to OPR is so obscure that no ordinary prisoner could understand it, the remedy was unavailable. View "King v. Dart" on Justia Law

Officer Sandoval encountered inmate Hacker, who is almost totally deaf, and ordered him to return to his bed. Hacker, unable to hear, did not comply. Sandoval shoved Hacker, who awoke handcuffed to a bed. He filed an administrative grievance and received notice that it had been referred to the Office of Professional Responsibility and the Divisional Superintendent, with a form allowing Hacker to appeal within 15 days. Neither document gave any timeline for OPR’s disposition of Hacker’s grievance. More than three months later, an OPR investigator concluded he could not substantiate Hacker’s claims; his superior officer signed the memorandum to approve the closure of the referral. The document does not state that the grievance process as a whole had ended, nor mention an appeals process. Hacker apparently received no communication from the Superintendent.Hacker had already filed suit. The district court granted the defendants summary judgment, citing failure to exhaust claims under the Prison Litigation Reform Act and to comply with other PLRA requirements, 42 U.S.C. 1997e(a). The Seventh Circuit vacated. The jail’s grievance procedures became unavailable to Hacker after the jail involved OPR; various communications forced Hacker to “go beyond the established system and guess” what he needed to do. One of Hacker’s claims under the ADA and Rehabilitation Act failed because his grievance did not give fair notice that he was requesting a personal listening device; his other claim, concerning missing medications, was not tied to a physical injury as required to recover damages under the PLRA. View "Hacker v. Cook County, Illinois" on Justia Law

In a custody dispute between Hadzi-Tanovic and her former husband, Pavlovich, an Illinois state court ordered that Hadzi-Tanovic’s parenting time with her children be supervised. She filed suit in federal court under 42 U.S.C. 1983 and 1985 against her ex-husband, the children’s guardian ad litem, and the state court judge, alleging they conspired to violate her and her children’s rights to family association and her right to a fair and unbiased trier of fact. The district court dismissed her complaint on abstention grounds.The Seventh Circuit affirmed. It is well established that federal courts do not have jurisdiction to review such state court decisions. The Rooker-Feldman doctrine imposes a “jurisdictional bar” that prohibits federal courts other than the U.S. Supreme Court from reviewing final state court judgments The state court order at issue is final, so the Rooker-Feldman doctrine’s finality requirement is met. Allegations of state court corruption are not sufficient to avoid the application of the Rooker-Feldman doctrine. Hadzi-Tanovic has not argued that state law or procedures prevented her from raising her federal constitutional issues in state court. Parties may raise procedural and substantive due process challenges to custody orders in Illinois state court. View "Hadzi-Tanovic v. Johnson" on Justia Law