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

Williams, a Racine County Jail pre-trial detainee, suffers from osteoarthritis, for which he has received Social Security disability insurance since 1982. Although the Jail typically provides inmates with a single mattress to sleep on, when the jail places inmates in disciplinary segregation it does not allow them to keep their mattresses in their cells during the daytime hours. Medical staff provided Williams with double mattresses to sleep on as an accommodation for his osteoarthritis and allowed him to keep a single mattress in his cell during the day. Months later, the medical staff concluded that Williams’s medical condition no longer required a second mattress. During the following months, Williams had several disciplinary issues and served time in segregation without a mattress accommodation. The jail staff conducted hearings to evaluate Williams’s write-ups. Williams refused to participate. The jail’s medical staff continued to address Williams’s medical complaints and Williams continued to correspond with officers concerning his grievances. Williams appealed one of the disciplinary determinations. The district court screened Williams’s 42 U.S.C. 1983 complaint and allowed claims alleging retaliation, harassment, conspiracy to fabricate disciplinary tickets, and medical deliberate indifference to proceed but later granted the defendants summary judgment, finding that Williams failed to exhaust his administrative remedies. The Seventh Circuit affirmed. Williams never made a timely appeal of his grievances; the defendants did not provide him with objectively unreasonable medical care. View "Williams v. Ortiz" on Justia Law

Janusiak called 911 to report that Payten, a friend’s baby in her care, was not breathing. Paramedics took Payten to the hospital while officers talked to Janusiak. The police returned about eight hours later, and Janusiak, then eight months pregnant, agreed to go to the police station for an interview. Police questioned her about Payten’s death for about seven hours. Toward the end of the interrogation, Janusiak made statements about what happened to Payten that were used to impeach her testimony at trial. After Peyten died Janusiak was convicted of first‐degree intentional homicide. On direct appeal, Wisconsin courts rejected her argument that statements she made during the interrogation were involuntary and should have been suppressed. The Seventh Circuit affirmed the denial of her petition for habeas corpus relief, 28 U.S.C. 2254. The court rejected Janusiak’s arguments that her statements were coerced by comments that law enforcement made to her about keeping access to her children, the length and other features of the interrogation, and her vulnerability as a pregnant woman and mother. The state appellate court reasonably applied the correct standard to determine that Janusiak’s statements were voluntary. View "Janusiak v. Cooper" on Justia Law

For two years, Alliance was unable to obtain a license from the Indiana State Department of Health to open a South Bend clinic to provide medication abortion care. After two unsuccessful applications, a statutory amendment, and a “moving target of wide-ranging requests for information,” Alliance concluded that its attempts were futile and sought a preliminary injunction. The district court granted preliminary relief, holding that Alliance has shown a likelihood of success on the merits of its claim that Indiana’s requirement of licensure for clinics that provide only medication abortions (induced exclusively by taking pills), as applied to Alliance's clinic, violates the Due Process and the Equal Protection Clauses.The Seventh Circuit held that the district court’s broad condemnation of Indiana’s licensing scheme runs contrary to Supreme Court precedent. While this litigation is pending, the state may, for the most part, administer that system. The court expressed concerns about the handling of Alliance’s application. Indiana may use licensing as a legitimate means of vetting and monitoring providers, but, to the extent that Indiana is using its licensing scheme to prevent the South Bend clinic from opening simply to block access to pre-viability abortions, it is acting unconstitutionally. The district court must modify the injunction to instruct Indiana to treat the Alliance’s South Bend facility as though it were provisionally licensed. View "Whole Woman's Health Alliance v. Hill" on Justia Law

Simon was stopped for failing to signal sufficiently ahead of turning. A drug-sniffing dog alerted on Simon’s car. Officers searched it. They did not find drugs, but found a gun. The government charged Simon as a felon-in-possession. The Seventh Circuit affirmed the denial of Simon’s motions for recusal, suppression, and supplementation. The court rejected an argument that the judge should have recused himself because, before he was a judge, he supervised a prior prosecution of Simon. The district court properly assessed credibility and found that the officers had probable cause to initiate the traffic stop and did not prolong the stop to allow for the dog sniff. The mere absence of drugs does not undermine the probable cause to search for drugs, provided there was probable cause in the first place. The judge conducted the proper Harris evaluation and concluded the dog’s satisfactory certification and training provide sufficient reason to trust his alert. The judge did not abuse his discretion in denying a motion to supplement the record, after the denial of the suppression motion, with a nighttime video. The nighttime video would not capture the actual visual capabilities of the officers, who credibly testified about how close Simon was to the intersection when he signaled. View "United States v. Simon" on Justia Law

Adams, his girlfriend, Brandon, and another person were stopped for speeding. Adams was the subject of anonymous tips regarding drug activity at his house and had a previous conviction for conspiracy to distribute methamphetamine. The third person was also the subject of anonymous tips regarding drug activity and had outstanding arrest warrants. During the traffic stop, the deputy smelled marijuana from the car. The car was searched, and deputies found a meth pipe, paraphernalia used with marijuana, and marijuana. Brandon, after receiving Miranda warnings, told the deputy that additional drug paraphernalia, a gun, and a safe containing methamphetamine pipes were at Adams’ house; that she also stayed in the house; and that she had been there earlier that day. She described the house’s layout, Adams’ bedroom, the gun, and paraphernalia. The police obtained a state-court search warrant, which they executed the same day as the traffic stop. In Adams’ room, they found a locked plastic gun case that Brandon had described, a handgun, and loaded magazines. Adams later admitted that Brandon bought the gun for him. Charged with unlawful possession of a firearm by a felon, 18 U.S.C. 922(g), Adams unsuccessfully moved to suppress the evidence. The Seventh Circuit affirmed. The issuing judge had a “substantial basis for determining the existence of probable cause” and, if “it didn’t ... there is good faith.” The district court properly calculated Adams’ guideline range, taking into account his prior drug conspiracy conviction. View "United States v. Adams" on Justia Law

In 2007, Campbell pleaded guilty to first-degree sexual assault of a child and was sentenced to 34 years in prison. Campbell has gender dysphoria; she is biologically male but identifies as female. Department of Corrections (DOC) medical staff treat Campbell’s condition with hormone therapy. Beginning in 2013, Campbell repeatedly requested sex-reassignment surgery. National standards of care recommend that patients undertake one year of “real life” experience as a person of their self-identified gender before resorting to irreversible surgery, which presents challenges in sex-segregated prisons. DOC officials consulted an outside expert, who determined that Campbell was a potential surgical candidate if DOC officials developed a safe, workable solution to the real-life-experience dilemma. Citing these concerns and DOC policy, officials denied Campbell’s request. After exhausting administrative remedies, Campbell sued under 42 U.S.C. 1983, alleging deliberate indifference to her serious medical needs.The Seventh Circuit reversed the denial of defendants’ claim of qualified immunity. Qualified immunity shields public officials from suits for damages unless precedent clearly puts them on notice that an action is unconstitutional. The Eighth Amendment requires prison healthcare professionals to exercise medical judgment when making decisions about an inmate’s treatment; they cannot completely deny care for a serious medical condition. Those broad principles could not have warned these defendants that treating an inmate’s gender dysphoria with hormone therapy and deferring consideration of sex-reassignment surgery violates the Constitution. The defendants followed accepted medical standards and are immune from damages liability. View "Campbell v. Kallas" on Justia Law

Landlords challenged a Hammond ordinance that they either obtain a city license or hire licensed contractors to perform repairs and renovations to their properties. Obtaining a license involves a test, payment of a fee, and a criminal background check. The ordinance does not apply to individual homeowners working on the properties in which they reside. On summary judgment, the district court rejected their argument that the ordinance impermissibly burdens owners who do not reside in Hammond. The Seventh Circuit affirmed. The ordinance does not discriminate against non-residents and is supported by a rational basis. The court noted the significant differences between resident owners and landlords and the city’s interests in safety and the habitability of dwellings. View "Regan v. City of Hammond" on Justia Law

Clark was convicted under 21 U.S.C. 841(a)(1), having been found in a hotel room with more than 80 grams of a mixture of heroin and fentanyl, a digital scale, and cellophane bags. He appealed the denial of his motion for a Franks hearing challenging the search warrant; the denial of his motion to suppress without an evidentiary hearing; the guideline treatment of his conviction for drug distribution that occurred in Illinois seven months after his Wisconsin arrest and one condition of supervised release.The Seventh Circuit vacated Clark’s conviction and remanded for an evidentiary hearing on his Franks challenge. Merely to obtain a Franks hearing, a defendant need only make a substantial preliminary showing that the warrant application contained a material falsity or omission that would alter the issuing judge’s probable cause determination and that the affiant included the material falsity or omitted information intentionally or with a reckless disregard for the truth. Clark asserted that the police investigator who applied for the warrant deliberately or recklessly omitted critical information affecting the credibility of the unidentified informant who told police about drug distribution at the hotel. Here, the foundation for probable cause independent of the credibility of the informant was so meager that the informant's credibility was material for Franks purposes. The police had provided no information about the informant’s credibility. The court rejected Clark's other claims. View "United States v. Clark" on Justia Law

While Giles was in solitary confinement following state robbery convictions, FBI agents questioned Giles about another bank robbery. DNA recovered from a glove found next to dye-stained stolen money matched Giles’s DNA. Giles agreed in writing to be questioned without an attorney present. After he was shown the DNA report, Giles confessed to the robbery and agreed to a cheek swab after being advised of his right to refuse. Giles was indicted for bank robbery, 18 U.S.C. 2113, and using a firearm in relation to a crime of violence 18 U.S.C. 924(c). He unsuccessfully moved to suppress the confession, arguing that neither his Miranda waiver nor his confession were voluntary, given his long-term confinement in a “small windowless cell” with little opportunity for human interaction. A psychiatrist who had conducted a forensic psychiatric evaluation and reviewed medical records testified that prolonged isolation could result in impaired function and that Giles's history of psychological disorders and head trauma made him particularly vulnerable to the effects of isolation. A fellow inmate testified that he spoke to Giles regularly. Bacha testified that Giles showed no signs of mental distress. The Seventh Circuit affirmed and upheld his sentence, which effectively added 18 years to the term he was serving, reasoning that there was enough evidence to convict Giles without the confession. His conduct and statements reflected a clear, intelligent, and knowledgeable thought process. View "United States v. Giles" on Justia Law

The Prison Litigation Reform Act (PLRA) “three strikes” provision, 28 U.S.C. 1915(g), specifies that a prisoner may not proceed in forma pauperis if she “has, on [three] or more prior occasions, while incarcerated or detained in any facility, brought an action or appeal in a court of the United States that was dismissed on the grounds that it is frivolous, malicious, or fails to state a claim upon which relief may be granted.” Many courts require prisoner‐litigants to identify their entire litigation histories. The Northern District of Illinois’s form requires 42 U.S.C. 1983 inmate-plaintiffs to list the name of each case, assigned judge and court, docket number, filing date, all plaintiffs (with aliases), all defendants, a description of claims made, the disposition and date of disposition. In cases consolidated on appeal, the district court concluded that inmate-plaintiffs committed fraud. The Seventh Circuit vacated. District courts must ensure that a prisoner’s negligent or even reckless mistake is not improperly characterized as an intentional and fraudulent act. Even prisoners with no incentive to lie may not have ready access to their litigation documents and may not remember all of the details. When viewed in the liberal light appropriate for pro se pleadings, one inmate’s explanation of his mental health issues and illiteracy indicated he did not fully understand what was being asked of him; the omissions were inadvertent. None of the cases omitted by the inmates met applicable standards for materiality. View "Johnson v. Dalke" on Justia Law