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

The case concerns the plaintiff, Tina Gerlach, who claimed that Indiana officials violated her right to just compensation under the Fifth Amendment's Takings Clause. Gerlach's unclaimed property had been taken into custody by the state under the Revised Indiana Unclaimed Property Act. She asserted that Indiana did not compensate her for interest accrued while the state held her property.Gerlach filed a lawsuit against several state officials, seeking declaratory and injunctive relief, as well as compensation. The defendant officials moved for judgment on the pleadings, arguing that Gerlach's claim for prospective relief was moot and her claims for retrospective relief were barred by the Eleventh Amendment. The district court granted the defendants' motion, and Gerlach appealed.The United States Court of Appeals for the Seventh Circuit affirmed the district court's dismissal. The court found Gerlach's claim for prospective relief was moot due to Indiana's new legislation requiring the payment of interest on all recovered property. The court also held that Gerlach could not obtain compensation in federal court from the Indiana officials because no exception to Eleventh Amendment sovereign immunity applied, and Indiana state courts were open to hear Gerlach's claims. Lastly, the court concluded that Gerlach's claim for compensatory relief was actually against the State of Indiana, and therefore barred by sovereign immunity and Section 1983 of the Civil Rights Act, which does not create a cause of action against a state. View "Gerlach v. Rokita" on Justia Law

In the case before the United States Court of Appeals for the Seventh Circuit, the plaintiff, Candice Martin, represented herself and the estate of her deceased husband, Rodney Martin. The defendants were Goodrich Corporation and PolyOne Corporation, both of which Rodney had worked for. Rodney had been exposed to a hazardous chemical, vinyl chloride monomer (VCM), during his employment and was later diagnosed with angiosarcoma of the liver, a disease allegedly linked to VCM exposure.The case revolved around the interpretation and application of the Illinois Workers' Occupational Diseases Act (ODA), which provides compensation for employees who contract diseases through their employment. The Act also has an exclusivity provision, which restricts employees from seeking compensation outside of the statutory scheme.The plaintiff argued that her claim was not subject to the ODA's exclusivity provisions due to an exception introduced by the Illinois legislature in 2019, which allows claims to proceed outside the ODA if they would be barred by any period of repose or repose provision. The defendants argued that this exception did not apply in this case, as Rodney's exposure to VCM had occurred decades prior to the enactment of the exception.Due to the complexity of the statutory provisions and the implications of their interpretation, the Court of Appeals decided to certify three questions to the Illinois Supreme Court. The questions pertained to whether a specific provision of the ODA constituted a period of repose, whether the 2019 exception applied retrospectively, and whether the application of this exception to past conduct would violate the due process protections of the Illinois Constitution. View "Martin v. Goodrich Corporation" on Justia Law

Donald Pierce was convicted of multiple counts of child molestation and of being a repeat sexual offender. The case revolved around the testimonies of the victim and several adults who had been told about the incidents. Pierce's lawyer did not object to the sequence of these testimonies, which violated an Indiana evidentiary rule. Pierce later petitioned for post-conviction relief, arguing that his lawyer's failure to object meant he was deprived of constitutionally adequate representation. This was denied by the Indiana Court of Appeals, which found that the lawyer's failure to object was strategic and did not constitute constitutionally deficient performance. Pierce then sought habeas relief, alleging the state appellate court had unreasonably applied Supreme Court precedent and made an unreasonable fact determination. However, the United States Court of Appeals for the Seventh Circuit affirmed the previous decision, finding that the state court did not unreasonably apply the precedent and its fact determination was not unreasonable. View "Pierce v. Vanihel" on Justia Law

In this case, the United States Court of Appeals for the Seventh Circuit addressed a dispute involving the owners of two parcels of real estate in Chicago who contended that banks tried to collect notes and mortgages that belonged to different financial institutions. The state judiciary had ruled that the banks were entitled to foreclose on both parcels, but the properties had not yet been sold and no final judgments defining the debt were in place. The plaintiffs attempted to initiate federal litigation under the holding of Exxon Mobil Corp. v. Saudi Basic Industries Corp., arguing that their case was still pending. However, the district court dismissed the case, citing the Rooker-Feldman doctrine, which states that only the Supreme Court of the United States can review the judgments of state courts in civil suits.The Appeals court held that the application of the Rooker-Feldman doctrine was incorrect in this case because the foreclosure litigation in Illinois was not yet "final". According to the court, the foreclosure process in Illinois continues until the property is sold, the sale is confirmed, and the court either enters a deficiency judgment or distributes the surplus. Since these steps had not occurred, the plaintiffs had not yet "lost the war", and thus parallel state and federal litigation could be pursued as per Exxon Mobil Corp. v. Saudi Basic Industries Corp.However, by the time the district court dismissed this suit, the state litigation about one parcel was over because a sale had occurred and been confirmed, and by the time the Appeals court heard oral argument that was true for the second parcel as well. The Appeals court stated that Illinois law forbids sequential litigation about the same claim even when the plaintiff in the second case offers novel arguments. The court found that the plaintiffs could have presented their constitutional arguments in the state court system and were not free to shift what is effectively an appellate argument to a different judicial system.The court also noted that Joel Chupack, the lead defendant, was the trial judge in the state case and was not a party to either state case. He did not claim the benefit of preclusion. Judge Chupack was found to be entitled to absolute immunity from damages, as he acted in a judicial capacity.The judgment of the district court was modified to reflect a dismissal with prejudice rather than a dismissal for lack of jurisdiction, and as so modified it was affirmed. View "Bryant v. Chupack" on Justia Law

Adrian L. Johnson was pulled over by a Deputy Sheriff for driving with a suspended license. The officer's trained dog indicated the presence of a controlled substance in Johnson's car, leading to a search of the vehicle. The officer found drugs, drug paraphernalia, and two handguns. Johnson was subsequently charged with possession of drugs with intent to distribute and possession of a firearm in furtherance of a drug trafficking crime. He moved to suppress all evidence, arguing that the search of his car violated his Fourth Amendment rights. The district court denied the motion, and Johnson pled guilty, reserving his right to appeal the suppression ruling. The United States Court of Appeals for the Seventh Circuit agreed with the district court, holding that the officer did not unconstitutionally prolong the stop to conduct the dog sniff, and that the subsequent search of Johnson's car did not violate the Fourth Amendment. The officer had probable cause to search the car because the dog's alerts indicated the presence of contraband. Therefore, the judgment of the district court was affirmed. View "USA v. Johnson" on Justia Law

In this federal case before the United States Court of Appeals for the Seventh Circuit, Thomas Moorer, who had been arrested and indicted on charges including murder and attempted murder, challenged the constitutionality of his pretrial detention, claiming that there was no probable cause for his arrest. Moorer was ultimately acquitted by a jury of all charges. The defendants in the case were officers of the Chicago Police Department.The case arose from a fatal shooting that took place in an apartment shared by multiple people. Multiple witnesses, including Edwin Ramos, whose brother Edward was killed in the shooting, identified Moorer as the perpetrator. Edwin informed the police that the man who entered the apartment was nicknamed “Boom.” Moorer was subsequently arrested and charged with first-degree murder and other crimes, and a grand jury returned a 135-count indictment against him.Moorer claimed that the witness identifications were unreliable and that police failed to properly investigate his alibi. He argued that the prosecutors would have concluded there was no probable cause if they had been properly informed of all the facts known to the officers.However, the Court of Appeals found that the officers did have probable cause to arrest and detain Moorer, based on seven independent witness identifications. The court noted that the question for pretrial detention is not whether the officers have proof beyond a reasonable doubt that the accused committed the crime, but whether a reasonable person would have a sound reason to believe the suspect committed a crime. The court concluded that Moorer had not identified any facts known to the defendants that would eliminate probable cause.Therefore, the court affirmed the decision of the district court, which had granted summary judgment in favor of the defendants. View "Moorer v. City of Chicago" on Justia Law

Four Iranian nationals, who had previously completed mandatory military service in Iran's Islamic Revolutionary Guard Corps (IRGC), were denied visas to enter the United States. Their family members, three U.S. citizens and one lawful permanent resident, filed a suit against the President and several federal officials responsible for visa applications. They alleged that the defendants unlawfully deprived visa applicants the opportunity to establish eligibility for terrorism-related inadmissibility grounds (TRIG) exemptions, violating their rights under the Administrative Procedure Act and the Fifth Amendment’s Due Process Clause. The district court dismissed the case under the doctrine of consular nonreviewability, which bars judicial review of consular decisions. The Plaintiffs appealed, and the United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court held that the doctrine of consular nonreviewability applied, and that the plaintiffs failed to show any evidence of bad faith that could overcome this doctrine. The court also held that the applicants were not entitled to any more explanation for their visa denials than the citation to the section of the law on which the denial was based. View "Pak v. Biden" on Justia Law

In this case, the United States Court of Appeals for the Seventh Circuit reviewed an appeal related to a Fourth Amendment issue involving a warrantless search of a vehicle. The defendant, Charles Hays, was stopped by the police while driving, and his passenger was found in possession of methamphetamine. The police officers then searched the vehicle's interior but found no drugs. However, under the hood of the car, inside the air filter, they discovered more methamphetamine.Hays was indicted and later moved to suppress the evidence obtained during the traffic stop, arguing that the officers did not have probable cause to search under the hood and in the air filter. The district court denied his motion, and Hays subsequently pleaded guilty to possession with the intent to distribute 50 grams or more of methamphetamine, preserving his right to appeal the denial of his motion to suppress.The Seventh Circuit affirmed the district court's decision, holding that under the automobile exception to the Fourth Amendment's warrant requirement, officers may conduct a warrantless search of a vehicle, including all parts of the vehicle where there is a fair probability contraband could be concealed, as long as there is probable cause to believe it contains contraband or evidence of illegal activity. The court found that given the totality of the circumstances, including the passenger's possession of methamphetamine, Hays's previous drug-related arrest, and the presence of a screwdriver in the car - a tool known to be used for hiding drugs in vehicles - officers had a fair probability to believe that methamphetamine could be concealed in the car, including under its hood. View "United States v. Hays" on Justia Law

In this case heard in the United States Court of Appeals For the Seventh Circuit, the defendant, Henry Underwood, had chosen to represent himself in a trial where he was charged with being a felon in possession of a firearm. During the trial, Underwood refused to answer a question during cross-examination and was subsequently held in criminal contempt. He was convicted of the charged offense and appealed against the conviction, arguing that his pretrial waiver of counsel was not knowing and voluntary and that the criminal contempt finding was improper.The court rejected both arguments. First, it found that the defendant's waiver of counsel was knowing and voluntary. It took into consideration the extent of the court's formal inquiry into the defendant's waiver, evidence in the record showing the defendant understood the dangers of self-representation, the defendant's background and experience, and the context of the choice to proceed pro se.Secondly, the court found that the criminal contempt finding was appropriate because the defendant had improperly refused to testify on cross-examination in the judge’s presence, which met the literal requirements of Rule 42(b) that permits summary disposition of criminal contempt. Furthermore, the court held that by choosing to testify, the defendant had waived his Fifth Amendment right against self-incrimination, and could not refuse to answer questions relevant to his testimony.The decision of the district court was affirmed. View "USA v. Underwood" on Justia Law

In this case, the United States Court of Appeals for the Seventh Circuit examined the constitutionality of Cook County, Illinois's use of cameras to record holding cell toilets in courthouses throughout the county. The plaintiffs, pretrial detainees, claimed that the cameras infringed upon their Fourth Amendment privacy interests and also constituted an intrusion upon seclusion under Illinois law. The district court granted summary judgment in favor of the defendants, Cook County and Sheriff Thomas J. Dart, and the plaintiffs appealed.The Court of Appeals held that the plaintiffs did not have a reasonable expectation of privacy when using the toilets in courthouse holding cells. While it acknowledged that there are questions around the extent to which detainees have a reasonable expectation of privacy in their bodies while in a holding cell, it found that any privacy rights are substantially diminished. The court further held that Cook County's use of cameras in courthouse holding cells was reasonable due to the security risks inherent in the setting. The court also determined that one of the plaintiffs, Alicea, had standing to sue, but the other plaintiffs did not.Furthermore, the court affirmed the district court's decision to grant summary judgment on the plaintiffs' claim for intrusion upon seclusion. It held that the plaintiff had not met his burden on the fourth element of the claim, anguish and suffering.Lastly, the court affirmed the district court's decisions related to discovery and attorneys' fees. The court held that the district court did not abuse its discretion in these decisions. Thus, the judgment of the district court was affirmed. View "Alicea v. County of Cook" on Justia Law