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

A sixteen-year-old, Donnell Wilson, was convicted of two murders, armed robbery, and criminal gang activity in Gary, Indiana. Wilson and his accomplice, Jonte Crawford, harassed and robbed a teenager before encountering and fatally shooting two brothers affiliated with a rival gang. Wilson was sentenced to 183 years in prison, which was later reduced to 181 years on appeal due to a vacated gang activity conviction.Wilson sought post-conviction relief, arguing ineffective assistance of counsel and that his sentence violated the Eighth Amendment under Miller v. Alabama, which prohibits mandatory life without parole for juveniles. The Indiana Supreme Court found his trial counsel effective but agreed his appellate counsel was ineffective for not challenging the sentence under Indiana Appellate Rule 7(B). The court then reduced Wilson’s sentence to 100 years, considering his youth as a mitigating factor.Wilson filed a federal habeas corpus petition, arguing his 100-year sentence was a de facto life sentence violating the Eighth Amendment. The United States District Court for the Northern District of Indiana found the petition timely but denied relief, stating no clearly established law extended Miller to de facto life sentences. The United States Court of Appeals for the Seventh Circuit affirmed, agreeing the petition was timely but holding that the Indiana Supreme Court’s decision was not contrary to or an unreasonable application of clearly established federal law. The Seventh Circuit concluded that Miller’s protections did not extend to Wilson’s 100-year sentence, thus affirming the denial of his habeas petition. View "Wilson v. Neal" on Justia Law

Gary Hicks, a corrections sergeant, was suspended for 10 days by the Illinois Department of Corrections after an internal investigation into his Facebook posts, which were described as "Islamophobic" and "offensive" by a news article. The investigation concluded that Hicks violated Department policies prohibiting conduct unbecoming of a State employee or that may reflect unfavorably on the Department. Hicks admitted to making the posts, which included derogatory comments about various groups and a prayer for a civil war or government overthrow. He sued the Department and officials under 42 U.S.C. § 1983, alleging First Amendment retaliation and a Fourteenth Amendment challenge to the Department’s policies.The United States District Court for the Central District of Illinois granted summary judgment in favor of the defendants on both claims. The court held that Hicks’s suspension did not violate the First Amendment because his posts were not on matters of public concern, and the Department’s interest in maintaining discipline outweighed his interest in speaking. The court also found that the Department’s policies were not impermissibly vague as applied to Hicks’s conduct and granted qualified immunity to the defendants.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The court concluded that the Department’s interest in managing its affairs outweighed Hicks’s interest in posting the content, thus he could not sustain a First Amendment retaliation claim. Additionally, the court found that the Department’s code of conduct was not impermissibly vague as applied to Hicks, as a reasonable officer would understand that his posts were unbecoming and could reflect unfavorably on the Department. Therefore, the court affirmed the summary judgment in favor of the defendants on both the First and Fourteenth Amendment claims. View "Hicks v. Illinois Department of Corrections" on Justia Law

Phillip Robbin was removing a tree from a residential lot in the City of Berwyn when he was confronted by Sarah Lopez, a city inspector. Lopez berated Robbin using racial slurs, which led Robbin to demand disciplinary action against her. The Mayor of Berwyn denied Robbin's request for Lopez's termination, leading Robbin to sue the City, the Mayor, and Lopez for violations of his substantive due process rights under the Fourteenth Amendment and state law.The United States District Court for the Northern District of Illinois dismissed Robbin’s complaint under Federal Rule of Civil Procedure 12(b)(6), finding that he failed to state a federal claim. The court also declined to exercise supplemental jurisdiction over the state law claims, leading to Robbin's appeal.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court held that Robbin failed to allege a violation of a fundamental right and that the conduct described did not "shock the conscience," which are necessary elements for a substantive due process claim under the Fourteenth Amendment. The court noted that while Lopez's use of racial slurs was deplorable, it did not rise to the level of a constitutional violation. Consequently, the Seventh Circuit affirmed the district court's dismissal of Robbin's complaint. View "Robbin v. City of Berwyn" on Justia Law

Three sets of parents refused to allow their newborns to receive Vitamin K shots at private hospitals in Illinois, citing concerns about risks and religious reasons. Hospital staff reported the refusals to the Illinois Department of Children and Family Services (DCFS), which investigated the parents for medical neglect. In one case, hospital staff took temporary protective custody of the child. The parents sued the hospitals and certain medical professionals under 42 U.S.C. § 1983, alleging violations of their Fourth and Fourteenth Amendment rights.The United States District Court for the Northern District of Illinois dismissed the cases, ruling that the private entities could only be liable under § 1983 if they were engaged in state action. The court found that the hospitals and their staff were not acting under color of state law when they reported the parents to DCFS or took temporary custody of the children. The parents appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's dismissal. The appellate court held that the hospitals and their staff did not act under color of state law. The court found no evidence of a conspiracy or joint action between the hospitals and DCFS to infringe on the parents' constitutional rights. The court also determined that the hospitals were not performing a public function traditionally reserved to the state, as the mere threat of taking protective custody did not constitute state action. Additionally, the court found no entwinement or symbiotic relationship between the hospitals and the state that would make the hospitals state actors. Therefore, the parents' § 1983 claims could not proceed. View "Scott v. University of Chicago" on Justia Law

Three sets of parents refused to allow their newborns to receive Vitamin K shots at private hospitals in Illinois due to concerns about risks and religious reasons. Hospital staff reported the refusals to the Illinois Department of Children and Family Services (DCFS), which investigated the parents for medical neglect. In one case, hospital staff took temporary protective custody of the child. The parents sued under 42 U.S.C. § 1983, alleging violations of their Fourth and Fourteenth Amendment rights by the hospitals and medical professionals.The United States District Court for the Northern District of Illinois dismissed the cases, ruling that the private entities were not engaged in state action and thus not liable under § 1983. The parents appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the private hospitals and their staff did not act under color of state law. The court found no evidence of a conspiracy or joint action between the hospitals and DCFS to infringe on the parents' constitutional rights. The court also determined that the hospitals were not performing a public function traditionally reserved to the state, as the mere threat of taking protective custody did not constitute state action. Additionally, the court found no symbiotic relationship or entwinement between the hospitals and the state to the point of largely overlapping identity.The Seventh Circuit affirmed the district court's dismissal of the parents' claims, concluding that without state action, there could be no § 1983 liability. View "Bougher v. Silver Cross Hospital and Medical Centers" on Justia Law

The case involves a property owned by Indiana Land Trust #3082, located in Hammond, Indiana, which houses a lucrative fireworks and tobacco business operated by Omar and Haitham Abuzir. The City of Hammond seeks to use its eminent domain power to take this property to build a road connecting Indianapolis Boulevard and the Water Gardens neighborhood. The Abuzirs allege that the City’s actions are part of a conspiracy involving political motives and favoritism towards competitors who support the mayor.The Hammond Redevelopment Commission initially offered to purchase the property in 2018, but the Abuzirs declined. Consequently, the Commission initiated a condemnation action in Indiana state court under the state’s eminent domain statute. The Abuzirs objected, arguing that the taking was for a private purpose and motivated by ill will. Unable to assert counterclaims in state court, they filed a federal lawsuit alleging constitutional and federal law violations, including claims under the Fourteenth Amendment and 42 U.S.C. § 1983.The United States District Court for the Northern District of Indiana dismissed the Abuzirs' third amended complaint with prejudice, finding that the City had a legitimate government interest in building a road and that the Abuzirs failed to state a claim for equal protection, substantive due process, or civil conspiracy. The court noted that the Abuzirs' complaint itself provided a rational basis for the City’s actions.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The appellate court held that the Abuzirs failed to state a class-of-one equal protection claim because the City’s actions had a rational basis. The court also found that the proposed substantive due process claim was futile as the Abuzirs did not allege a deprivation of a protected interest. Lastly, the court upheld the denial of leave to add a § 1983 conspiracy claim, as the Abuzirs failed to establish any underlying constitutional violation. View "Indiana Land Trust #3082 v. Hammond Redevelopment Commission" on Justia Law

The case revolves around Larry Sapp, an Army veteran with a history of felony drug convictions, who was elected to the Sauk Village Board of Trustees in Illinois. However, his felony convictions came to the attention of the Cook County State’s Attorney’s Office, which used two Illinois statutes to remove him from his position. These statutes bar certain felons from holding public office. Sapp challenged the constitutionality of these statutes, arguing that they violated the Eighth Amendment's clauses on Cruel and Unusual Punishment and Excessive Fines by barring him from public service and depriving him of the income a career in public service would generate.The Cook County Circuit Court rejected Sapp's arguments, ruling that the statutes' enforcement did not violate the Eighth Amendment. The court held that Sapp was ineligible to serve as a Board Trustee and removed him from his position. Sapp then filed a federal lawsuit against Illinois Governor J.B. Pritzker and State’s Attorney Kimberly Foxx, seeking to bar the Cook County State’s Attorney from enforcing either statute against him in future elections. He reiterated his Eighth Amendment arguments and added a new one, claiming that enforcing the statutes against him would violate the Cruel and Unusual Punishment Clause.The United States Court of Appeals for the Seventh Circuit affirmed the dismissal of Sapp’s complaint. The court did not reach the merits of Sapp's constitutional arguments, instead ruling that they were foreclosed by Illinois principles of collateral estoppel and res judicata. The court held that Sapp's federal lawsuit arose from the same group of operative facts as the State’s Attorney’s quo warranto action in Cook County Court, and thus constituted the same "cause of action" under Illinois law. As a result, Sapp was barred from raising arguments in the federal suit that were available to him in the quo warranto action. View "Sapp v. Foxx" on Justia Law

The case revolves around a traffic stop in Wisconsin where police officers used a K-9 unit to sniff a car they suspected was involved in drug trafficking. The dog signaled the presence of drugs, leading to a search of the car and the discovery of almost eleven pounds of methamphetamine. The defendant, Juventino Plancarte, who was in the car during the stop, challenged the district court's denial of his motion to suppress the evidence.The lower courts had indicted Plancarte on two counts related to methamphetamine distribution. He moved to suppress the evidence obtained after the dog's sniff, arguing that the dog could identify both illegal marijuana products and legal products that come from cannabis plants. Therefore, he contended that the sniff violated the Fourth Amendment as it was a warrantless search unsupported by probable cause. However, the district court adopted the magistrate judge's recommendations denying Plancarte's suppression motion, leading to his guilty plea to both drug charges.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court held that the dog sniff did not constitute a Fourth Amendment search as it did not disrupt any reasonable expectation of privacy. The court noted that the dog sniff occurred outside the home, in a public area, and during a lawful traffic stop, which generally does not implicate legitimate privacy interests. The court also pointed out that the dog's sniff was not designed to disclose any information other than the presence or absence of narcotics. Therefore, the court concluded that the district court appropriately denied Plancarte's motion to suppress. View "United States v. Plancarte" on Justia Law

Raynard Jackson, a prisoner at the Wisconsin Secure Program Facility (WSPF), was placed in a cell without running water for five days. He alleged that Lieutenant Dane Esser, among other WSPF staff, knew that he did not have water and yet failed to turn the water on. After Jackson showed another staff member that he did not have water, the water was promptly turned on; however, he claimed Lt. Esser and other WSPF staff failed to provide him with medical care for his dehydration. Jackson filed grievances pertaining to these issues. After he exhausted his administrative remedies within the WSPF, he sued Lt. Esser and other WSPF staff under 42 U.S.C. § 1983 for violating his Eighth and Fourteenth Amendment rights.The district court, only considering the processed grievances, and without holding an evidentiary hearing, found that Jackson had not exhausted his administrative remedies as to certain claims and defendants. Additional defendants, Nurse Beth Edge and Captain Dale Flannery, were dismissed at summary judgment, leaving only the claims against Lt. Esser for trial. The jury found for Lt. Esser on both claims.The United States Court of Appeals for the Seventh Circuit agreed with Jackson that the district court should not have disregarded his allegedly unprocessed grievances without holding an evidentiary hearing. However, the court found no error in the district court’s conclusion that Jackson’s processed grievances did not exhaust remedies as to all his claims. The court also found no error in the district court’s grant of summary judgment to Nurse Edge or its evidentiary rulings before trial. The court affirmed in part, reversed in part, and remanded for a hearing on the allegedly unprocessed grievances. View "Jackson v. Esser" on Justia Law

The case revolves around Seldrick Carpenter, who was serving a six-year term of supervised release after completing a federal sentence for distributing fentanyl. After the death of his mother, Carpenter began using drugs and acting out against his probation officer. When behavioral therapy failed to address these issues, his probation officer petitioned to revoke his supervised release. Carpenter was then suspected of setting a car on fire. The Probation Office alleged that Carpenter committed several supervised release violations, including arson, criminal damage to property, intimidation, and aggravated battery. Before the revocation hearing, Carpenter requested a jury trial under the Sixth Amendment and Article III, § 2, cl. 3. The district court denied the motion and presided over Carpenter’s revocation hearing without a jury. The court found Carpenter guilty of several violations and revoked his supervised release, imposing a revocation sentence of 30 months’ imprisonment.The United States Court of Appeals for the Seventh Circuit was tasked with determining whether a supervised release revocation proceeding held under 18 U.S.C. § 3583(e)(3) constitutes the “trial of [a] crime” or a “criminal prosecution” within the meaning of either clause. The court agreed with the district court's decision that it does not. The court concluded that neither the Sixth Amendment nor Section 2 of Article III of the U.S. Constitution guarantee a jury trial in a revocation hearing like Carpenter’s. A defendant in Carpenter's situation is entitled only to those procedures dictated by the Federal Rules of Criminal Procedure and the Due Process Clause of the Fifth Amendment. The court also rejected Carpenter's argument that Article III, § 2 can apply to proceedings outside the scope of the Sixth Amendment. The court affirmed the district court's decision. View "United States v. Carpenter" on Justia Law