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

The case revolves around Dylan Ostrum, who was under investigation for drug dealing and possession of firearms. During a search of his home, Ostrum revealed that he had moved his belongings, including his car, to his father's house. However, the car, which was reported stolen by a rental company, was found nearby with Ostrum's belongings inside, including a gun, methamphetamine, and marijuana, all stashed in two safes. The key issues on appeal were whether Ostrum had standing to challenge the search of the stolen car and whether the search violated his Fourth Amendment rights.The investigation into Ostrum began after law enforcement agents found text messages between him and another individual, Ricky Blythe, showing that they repeatedly sold each other methamphetamine and marijuana. Based on this evidence and information from confidential informants, law enforcement obtained a valid warrant to search Ostrum’s residence. However, the search turned up little, and Ostrum informed the officers that he had moved his belongings to his father's house. The officers later located the car, which was reported stolen, and discovered the safes inside.Ostrum was charged with multiple counts related to drug possession and distribution, and being a felon in possession of a firearm. He moved to suppress the evidence found inside the car, arguing that it was the fruit of an illegal search. The district court denied the motion, finding that Ostrum lacked standing to challenge the search because the car was stolen, and that the search was valid under the automobile exception to the Fourth Amendment’s warrant requirement. Ostrum was convicted on all counts and received a 240-month sentence.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court found that Ostrum failed to meet his burden on standing and that the existence of probable cause justified the search under the automobile exception to the Fourth Amendment’s warrant requirement. The court concluded that Ostrum had no reasonable expectation of privacy in the stolen car or its contents, and thus no standing to object to its search. View "USA v. Ostrum" on Justia Law

The plaintiff, Richard Rodgers, a prisoner with a history of scoliosis and back pain, had steel rods implanted in his back prior to his incarceration. During his time in prison, the rods broke, but this went undetected for over a year due to two radiologists misreading his x-rays. The prison's primary care physician, Dr. William Rankin, discovered the broken rods and arranged for corrective surgery. Rodgers sued the radiologists and Dr. Rankin, alleging violation of his Eighth Amendment rights.The district court dismissed Rodgers' claims against the radiologists, finding that he did not state a viable constitutional claim against them. The court allowed Rodgers to proceed against Dr. Rankin but eventually granted summary judgment in his favor. The court found that Rodgers had not provided evidence that would allow a reasonable jury to find that Dr. Rankin had violated the Eighth Amendment by acting with deliberate indifference toward Rodgers' serious medical condition.The United States Court of Appeals for the Seventh Circuit affirmed the district court's judgment. The court agreed that Rodgers' allegations against the radiologists amounted to no more than negligence, which is insufficient to state a viable Eighth Amendment claim. Regarding Dr. Rankin, the court found that the evidence would not support a reasonable finding that he acted with deliberate indifference to Rodgers' serious medical condition. The court noted that Dr. Rankin was the one who discovered the radiologists' errors and arranged for Rodgers' corrective surgery. View "Rodgers v. Rankin" on Justia Law

On July 4, 2021, Gavin Wallmow was arrested for violating his probation and was taken to Oneida County jail. During his booking, Wallmow denied any suicidal tendencies or mental health issues. Two days later, Wallmow's probation officer visited him and noticed a change in his behavior, including him hitting himself and expressing "demonic" thoughts. The officer reported this to a corrections officer at the jail, who then informed her superior. Despite these reports, Wallmow was observed behaving normally during routine checks. On July 8, Wallmow was found unresponsive in his cell, having committed suicide. His estate brought a series of constitutional claims under 42 U.S.C. § 1983, alleging that the jailers failed to protect Wallmow from himself.The United States District Court for the Western District of Wisconsin granted summary judgment to the defendants, concluding that the record did not support an inference that any defendant knew Wallmow faced a serious risk of harm. The court also found no reason to think the County's policies were inadequate, given the absence of any pattern of suicides to put it on notice.Upon appeal, the United States Court of Appeals for the Seventh Circuit affirmed the lower court's decision. The appellate court found that the jail's employees had taken reasonable precautions, including checking on Wallmow at least 37 times per day. The court also noted that Wallmow had thrice disavowed any risk of suicide, and nothing indicated otherwise after his talk with his probation officer. The court concluded that the jail's actions complied with the Constitution's requirements. View "Estate of Wallmow v. Oneida County, Wisconsin" on Justia Law

The case involves Jacob Lickers, who was convicted for transporting and possessing child pornography. The conviction was based on evidence found on Lickers' devices, which were seized during a traffic stop and subsequent arrest for drug possession. The initial search of the devices was authorized by a state court warrant, which later suppressed the evidence due to the unconstitutionality of the initial stop and arrest. However, the case was referred to federal authorities who conducted a second search of the devices under a federal warrant. The federal warrant application did not mention the state court's suppression ruling.In the lower courts, Lickers' attorney challenged the constitutionality of the initial stop and arrest, and the adequacy of the state search warrant. The state court agreed, suppressing all evidence seized during the stop and any statements made by Lickers. The state charges were subsequently dismissed. However, in the federal court, the same arguments were unsuccessful. Lickers pleaded guilty, reserving the right to appeal the denial of his motion to suppress. The district court sentenced him to concurrent terms of 132 months' imprisonment on each count.In the United States Court of Appeals For the Seventh Circuit, Lickers argued that his trial and appellate counsel rendered ineffective assistance by failing to argue that the federal agent acted in bad faith by omitting the state court's suppression ruling from the federal warrant application. The court disagreed, finding that the link between the state court's suppression ruling and the federal warrant application was too attenuated to obligate the attorneys to explore the possibility of bad faith. The court affirmed the district court's denial of relief. View "Lickers v. United States" on Justia Law

The case revolves around Anthony Gay, a convicted felon, who was found guilty of possessing firearms and ammunition, both of which he was prohibited from possessing due to his prior felony convictions. Gay was a passenger in a car that was stopped by the police, and upon being pursued, he fled on foot. The police testified that they found a gun where Gay had fallen and later discovered bullets in a motel room he had rented. Gay was subsequently indicted and convicted on one firearms count and one ammunition count, leading to a sentence of 84 months' imprisonment on each count, to run concurrently, plus three years' supervised release.Previously, Gay had contested the admissibility of the bullets found in the motel room, arguing that their discovery violated his Fourth Amendment rights. However, the district court denied his motion to suppress the bullets, stating that Gay's right to occupy the room had expired, the motel manager had found the bullets before the police were involved, and the manager had the right to admit the police under state law. Furthermore, the court noted that Gay, being on parole, had a diminished expectation of privacy.In the United States Court of Appeals for the Seventh Circuit, Gay argued that the evidence did not support his conviction on the firearms charge, suggesting that the weapon may have been planted. However, the court found that the evidence, including the bullets found in the motel room, supported the firearms charge. The court also dismissed Gay's argument that the reduction of two weeks in preparation time for his second trial was prejudicial, stating that the parties had just been through a trial and the evidence had been assembled.Gay also contended that the prosecution was unconstitutional, arguing that the Second Amendment permits persons with felony convictions to possess firearms and ammunition. However, the court affirmed the lower court's decision, citing precedents that upheld the validity of "longstanding prohibitions on the possession of firearms by felons." The court concluded that Gay, having been convicted of 22 felonies and being on parole, did not fit the description of a "law-abiding, responsible citizen" who has a constitutional right to possess firearms. View "United States v. Gay" on Justia Law

The case involves Harold McGhee, who was convicted and sentenced for drug trafficking. In August 2021, law enforcement received information from a confidential source about a drug dealer distributing large amounts of cocaine in Peoria, Illinois. The dealer was said to drive a Chevy Malibu and supplied cocaine to a house on West Millman Street. With this information, along with details from other informants and a tracking warrant, the police identified McGhee as the suspected dealer. They conducted three controlled buys and a trash pull at McGhee's residence, which led to the discovery of rubber gloves and baggies with a white powdery residue that tested positive for cocaine. This evidence led to a search warrant for McGhee's residence, vehicle, person, and electronic devices, resulting in the discovery of nearly a kilogram of various drugs, a handgun, and other drug trafficking paraphernalia.McGhee sought to suppress the evidence recovered at his residence and moved for a hearing to challenge the validity of the search warrant. He argued that the affidavit's use of "SUBJECT PREMISES," in reference to both his residence and the Millman Street house, was impermissibly ambiguous. The district court denied the motion. McGhee later renewed his motion to suppress, arguing that the trash pull was constitutionally unreasonable because it was executed without a warrant. The court denied this motion as well.On appeal, McGhee raised ten challenges to the criminal proceedings resulting in his convictions and sentence. The court considered some of his arguments on the merits and resolved others on procedural grounds. Ultimately, the court affirmed the judgment of the district court in all respects. View "United States v. McGhee" on Justia Law

The case concerns Thomas Osadzinski, who was convicted for providing material support to a terrorist organization. In 2019, Osadzinski, a computer science student, developed a software program to facilitate the rapid duplication of terrorist propaganda videos for ISIS. He shared this program with people he believed were ISIS supporters, taught them how to use it, and used it to assemble and distribute a large collection of ISIS media. Osadzinski appealed his conviction, arguing that it violated the First Amendment because his actions constituted free expression. He also contended that he lacked fair notice that his actions violated the material-support statute.The United States Court of Appeals for the Seventh Circuit disagreed with Osadzinski's arguments. The court held that although Osadzinski's actions could be regarded as expressive activity, this activity was coordinated with or directed by ISIS, a known terrorist organization, and therefore was not protected by the First Amendment. The court also rejected Osadzinski's claim that he lacked fair notice that his actions violated the material-support statute. The court affirmed Osadzinski's conviction, ruling that his conduct fell outside First Amendment protection, clearly violated the material-support statute, and provided a reasonable basis for the jury to return a guilty verdict. View "USA v. Osadzinski" on Justia Law

The case involves Janay Garrick, a former instructor at Moody Bible Institute, who alleged sex discrimination and other Title VII violations. Garrick claimed that she was subjected to hostile treatment due to her gender and the Institute's religious beliefs. Moody argued that her suit was barred by Title VII’s religious exemptions and the First Amendment doctrine of church autonomy. The district court denied Moody's motion to dismiss in part, leading to Moody's appeal.However, the United States Court of Appeals for the Seventh Circuit dismissed the appeal for lack of jurisdiction. The court reasoned that it could only review a small class of interlocutory orders under the collateral order doctrine, and Moody's appeal did not fit within this class. The court found that the district court's denial of Moody's motion to dismiss was not conclusive, did not resolve important questions separate from the merits of the case, and would not effectively be unreviewable on appeal from a final judgment.The appellate court also emphasized that Moody's defense, based on the doctrine of church autonomy, was not separate from the merits of Garrick's gender discrimination claims. Furthermore, the court noted that Moody's argument that it would experience irreparable harm without immediate review was unavailing, as the district court could limit discovery to instances of discriminatory treatment not implicated by Moody's religious beliefs. The court concluded that religious autonomy to shape and control doctrine would not be threatened by the further progression of Garrick's lawsuit. View "Garrick v. Moody Bible Institute" on Justia Law

A private Catholic high school in Madison, Wisconsin, sued the city and other defendants, claiming that the city's decision to deny the school permission to install lights for nighttime athletic events violated the Religious Land Use and Institutionalized Persons Act (RLUIPA) and the Free Exercise Clause of the U.S. Constitution. The school also claimed a vested property right under Wisconsin law.In the United States Court of Appeals for the Seventh Circuit, the school argued that the city's actions amounted to unequal treatment and a substantial burden on its religious exercise. However, the court found that the school, as a master plan institution under the city's Campus-Institutional District ordinance, was not comparably situated to other institutions that had been granted lighting permits. The court also ruled that the city's denial of the permit did not amount to a substantial burden on the school's religious exercise under RLUIPA.Furthermore, the court found that the school's Free Exercise claim provided no additional protections beyond those under RLUIPA and thus could be dismissed. Lastly, the court rejected the school's vested rights claim, as the lighting permit application did not conform to the municipal zoning requirements in effect at the time. Consequently, the court affirmed the lower court's summary judgment in favor of the city. View "Edgewood High School of the Sacred Heart, Incorpor v. City of Madison, Wisconsin" on Justia Law

In a case heard by the United States Court of Appeals for the Seventh Circuit, the defendant, Deny Mitrovich, was indicted for possession of child pornography following a multinational investigation that used a software program to unmask his computer. Mitrovich requested detailed technical information about the software program, which was used by Australian and New Zealand authorities, to aid his defense. However, the United States government did not have this information and was unsuccessful in obtaining it despite repeated efforts. Mitrovich argued that the government was obligated to provide this information under Rule 16(a)(1)(E) of the Federal Rules of Criminal Procedure and the Due Process Clause of the Fifth Amendment.The court disagreed with Mitrovich, stating that Rule 16 does not require the production of documents held exclusively by foreign authorities. Furthermore, Mitrovich was unable to demonstrate that the government's inability to provide the requested information resulted in prejudice, a necessary condition to establish a Brady violation. Therefore, the court affirmed the district court's decision not to impose sanctions on the government for failure to disclose the requested information.The court also clarified that while the doctrine of constructive possession could extend to co-participants in a joint international investigation under the Due Process Clause, this would not apply if the U.S. lacks the capacity to access or obtain the information through reasonable means. The court also emphasized that mere speculation about the content of the missing information is not sufficient to establish prejudice under Brady. View "United States v. Mitrovich" on Justia Law