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

In this case involving the fifty-year-old decision of a federal district court entering the 1972 "Shakman decree" precluding the Governor of Illinois and units of local government from conditioning governmental employment on political patronage the Seventh Circuit held that the power to hire, fire, and establish accompanying policies needs to return to the people of Illinois and the Governor they elected.In 2019, the Clerk of Cook County filed a motion to vacate the Shakman decree. The magistrate judge denied the motion, and the Clerk appealed. The Seventh Circuit court affirmed. Governor J.B. Pritzker then moved under Fed. R. Civ. P. 60(b)(5) to vacate the decree, claiming that the State had satisfied the requirements of the decree and that ongoing enforcement of the decree offended principles of federalism. The district court denied the motion. The Seventh District reversed and remanded with instructions to vacate the 1972 consent decree as it applied to the Illinois Governor, holding that Governor Pritzker had satisfied the objectives of the decree. View "Shakman v. Pritzker" on Justia Law

The Seventh Circuit affirmed the judgment of the district court denying Appellant's petition for a writ of habeas corpus, holding that the Wisconsin Supreme Court's decision affirming Defendant's conviction did not reflect an unreasonable application of clearly established law.Defendant moved to suppress incriminating statements he made to a detective, arguing that his statement "I don't want to talk about this" expressed an unambiguous intention to cut off all further questioning and that the detective's continued questioning violated Miranda v. Arizona, 384 U.S. 436 (1966). The trial court denied the motion, after which Defendant pleaded guilty to armed robbery and first-degree reckless injury. The Wisconsin Supreme Court affirmed, holding that there was no abuse of Miranda. Thereafter, Appellant brought his habeas petition. The Seventh Circuit affirmed the district court's denial of the petition, holding that the Wisconsin Supreme Court's decision amounted to a reasonable application of the Supreme Court's Miranda line of cases. View "Smith v. Boughton" on Justia Law

The Seventh Circuit affirmed the judgment of the district court denying the motion filed by the Word Seed Church after the district court dismissed this suit for lack of standing, holding that Word Seed failed to show exceptional circumstances warranting relief from the denial of that motion.Word Seed and an organization to which it belonged (collectively, Word Seed) brought this action against the Village of Homewood, Illinois alleging violations of the Religious Land Use and Institutionalized Persons Act and the Equal Protection Clause of the Fourteenth Amendment. The district court dismissed the suit for lack of standing after concluding that Word Seed did not suffer an injury and denied Word Seed's ensuing motions to reconsider. In the second motion, which the district court considered under Fed. R. Civ. P. 60(b), Word Seed raised for the first an argument that could have been raised before the district court entered judgment dismissing the case. The district court denied the motion. The Seventh Circuit affirmed, holding that the court did not abuse its discretion in denying Word Seed's Rule 60(b) motion. View "Word Seed Church v. Village of Homewood" on Justia Law

The Seventh Circuit affirmed the judgment of the district court denying Defendant's motion to suppress without holding an evidentiary hearing, holding that the district court did not abuse its discretion by denying an evidentiary hearing.A law enforcement officer stopped Defendant while he was riding a motorized bicycle and arrested him under the theory that his bicycle was a motor vehicle requiring a license. During the arrest, police searched Defendant and found various drugs and drug paraphernalia. Defendant filed a motion to suppress, arguing that the government needed to establish probable cause that he was driving a motor vehicle on a revoked license. The district court summarily denied the motion. The Seventh Circuit affirmed, holding that the evidence established that the arresting officer had probable cause to believe that Defendant rolled past a stop sign, which independently supported Defendant's arrest. View "United States v. Norville" on Justia Law

In this complaint brought under 42 U.S.C. 1983 and 42 U.S.C. 1985(3) relating to the custody of Plaintiffs' children, the Seventh Circuit affirmed the judgment of the district court dismissing this suit seeking damages for alleged violations of Plaintiffs' constitutional rights to familial integrity, free exercise of religion, and due process of law, holding that there was no error.Plaintiffs brought this action seeking money damages and equitable relief for actions Defendants took with respect to three of their daughters. On appeal, Plaintiffs challenged the dismissal of their claims for money damages regarding the custody of S.M. and D.M. The Seventh Circuit affirmed, holding (1) the judge properly dismissed as untimely all claims relating tot he custody of S.M.; and (2) as to the remaining claims, the trial judge properly concluded that the complaint failed to allege conduct plausibly exposing Defendants to liability and that other claims were foreclosed by absolute immunity. View "Milchtein v. Milwaukee County" on Justia Law

The Seventh Circuit reversed the order of the district court granting summary judgment and dismissing this complaint brought by Plaintiff after he was fired from his commissary job while incarcerated at Indiana State Prison, holding that the district court erred in finding that Plaintiff failed to comply with the Prison Litigation Reform Act's (PLRA) exhaustion requirement, 42 U.S.C. 1997e(a).Plaintiff was hired for a job in the commissary with the understanding that he would miss work on Fridays to attend the prison's weekly Jumu'ah Muslim prayer service. When Officer Julie Anton refused to allow Plaintiff to attend Jumu'ah and he went anyway, Anton fired Plaintiff based on a work evaluation accusing Plaintiff of theft. Plaintiff sued Anton under 42 U.S.C. 1983, alleging a violation of his First Amendment rights. The district court dismissed the complaint because Plaintiff did not file a formal grievance before bringing suit. The Seventh Circuit reversed, holding that the prison's grievance policy excepted Plaintiff's claim from the prison's administrative process. View "Miles v. Anton" on Justia Law

In this action brought the estate of Jonah Marciniak and Marciniak's son pursuing both federal and state claims stemming from Marciniak's arrest and ensuing suicide, the Seventh District held that the district court did not err in granting summary judgment in favor of the Village of Shorewood and three of its officers who arrested Marciniak after his roommate fell from a fourth story window, holding that there was no error.After arresting Marciniak and placing him in a booking cell, Marciniak used his t-shirt to hang himself. Marciniak died six days later. Plaintiffs brought this action alleging that the three officers falsely arrested Marciniak without probable cause and failed to provide medical care and attention and to protect from self-harm. The district court granted summary judgment in favor of Defendants. The Seventh Circuit affirmed, holding (1) Defendants had an absolute defense of probable cause to Plaintiffs' claims; and (2) even if the officers did not have probable cause to arrest for battery, they were still entitled to qualified immunity. View "Jump v. Village of Shorewood" on Justia Law

The Seventh Circuit affirmed the order of the district court granting summary judgment to Defendants and dismissing Plaintiffs' claims that three police officers unlawfully stopped, searched, and arrested them in violation of their First and Fourth Amendment rights, holding that Plaintiffs could not prevail on the merits of any of their claims.The three plaintiffs in this case were arrested after following a woman home and confronting her, but the District Attorney's office declined to pursue criminal charges. Plaintiff brought this action under 42 U.S.C. 1983 against the arresting officers. The district court granted summary judgment to Defendants. The Seventh Circuit affirmed, holding (1) the officers had reasonable suspicion for the initial stop and probable cause to arrest, and therefore, Plaintiffs' Fourth Amendment claims failed; and (2) Plaintiffs were not engaged in constitutionally-protected speech, and therefore, their First Amendment retaliation claim failed. View "Lyberger v. Snider" on Justia Law

The Seventh Circuit affirmed the judgment of the district court dismissing this action challenging the conduct of the Lake County Election Board, holding that the Election Board did not violate Joseph Hero's First and Fourteenth Amendment rights.Hero, a registered republican for forty years, opposed the decision of his town council to exercise its eminent-domain authority to seize the property of predominantly lower-income homeowners. Hero backed two independent candidates for town council running against two incumbent, pro-development candidates. Thereafter, the Indiana Republican Party banned Hero from the Republican Party for ten years. In 2019, Hero attempted to appear as a Republican candidate in the 2019 election, but the Election Board concluded that Hero could not run. Hero subsequently filed a complaint arguing that the Election Board violated his First and Fourteenth Amendment rights. The district court dismissed for lack of standing. The Seventh Circuit affirmed, holding (1) Hero had standing to sue; and (2) the Election Board did not violate Hero's constitutional rights. View "Hero v. Lake County Election Bd." on Justia Law

The Seventh Circuit affirmed Defendants' convictions for arson stemming from their participation in riots in Madison, Wisconsin following the shooting of a Black man by a police officer in Kenosha, Wisconsin, holding that the district court properly held that 18 U.S.C. 844(i) is constitutional.Defendants Willie Johnson and Anessa Fierro moved to dismiss the indictment against them, arguing that the federal arson statute is facially unconstitutional because its enactment exceeded Congress's authority under the Commerce Clause. The district court denied the motion, after which Defendants entered into conditional plea agreements. The Seventh Circuit affirmed, holding that section 844(i) was validly enacted pursuant to Congress's authority under the Commerce Clause. View "United States v. Fierro" on Justia Law