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

Lorenzo Johnson ran an online child-pornography scheme, inducing financially desperate women to send him sexually explicit photos of their young children by promising them money. Law enforcement identified Johnson's IP address, social media accounts, and cellphone, leading to a search of his home where they found his phone containing evidence of the crimes and a handgun. Johnson confessed to key details of his scheme in two recorded interviews with FBI agents. A jury found him guilty of conspiracy to produce child pornography, distribution of child pornography, and unlawful possession of a firearm as a felon.The United States District Court for the Northern District of Indiana, Hammond Division, handled the initial trial. Johnson's requests for new counsel were denied by both the magistrate judge and the district judge. The district judge also denied Johnson's motion for a new trial based on a late disclosure of potential Brady/Giglio evidence, which involved a romantic relationship between two FBI agents. Additionally, Johnson argued that the judge made an improper factual finding at sentencing regarding his causal role in the suicide of one of the women involved in his scheme.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the lower court's decisions, holding that the magistrate and district judges appropriately exercised their discretion in denying Johnson’s requests for new counsel. The district judge properly denied Johnson’s motion for a new trial because it was undeveloped and the new information was deemed immaterial. Lastly, the court found that the judge’s comments at sentencing about the co-conspirator’s suicide were part of a holistic assessment of the seriousness of the crimes and did not amount to a factual finding that Johnson was causally responsible. The Seventh Circuit affirmed the district court's rulings and Johnson's conviction and sentence. View "U.S. v. Johnson" on Justia Law

Taibian Harris and his cousin Treveon Smith robbed a cell phone store in South Bend during a blizzard. Harris acted as the getaway driver while Smith stole items from the store. Unbeknownst to them, one of the stolen phones was a bait phone that sent GPS signals to the police. The police tracked them to a gas station, and after a brief encounter, Harris led the police on a high-speed chase through snowy, icy streets, running stop signs and red lights. The chase ended when Harris collided with a police car. Both were apprehended after attempting to flee on foot.Harris and Smith were indicted for robbery under 18 U.S.C. § 1951 and both pled guilty. The Presentence Investigation Report recommended a two-level enhancement for Harris for recklessly creating a substantial risk of death or serious bodily injury while fleeing law enforcement. Harris objected, arguing there was no reliable evidence of reckless driving and that no police officer was in actual pursuit. The government called Smith as a witness, who described the high-speed chase in detail. The district court credited Smith’s testimony and overruled Harris’s objection, applying the two-level enhancement.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the district court did not clearly err in finding that Harris drove recklessly, as his actions met the recklessness standard under U.S.S.G. § 3C1.2. The court also found that Harris was knowingly fleeing from law enforcement, as evidenced by his erratic driving and attempts to evade police. The Seventh Circuit affirmed the district court’s application of the two-level enhancement to Harris’s sentence. View "United States v Harris" on Justia Law

Correctional officers at an Illinois state prison brutally beat inmate Larry Earvin, who later died from his injuries. Todd Sheffler and two others were charged with various federal crimes related to the killing and its cover-up. After a mistrial, Sheffler was retried and found guilty by a jury.In the United States District Court for the Central District of Illinois, Sheffler was convicted on five counts, including conspiracy to deprive civil rights, deprivation of civil rights, conspiracy to engage in misleading conduct, obstruction-falsification of documents, and obstruction-misleading conduct. Sheffler argued that there was no reasonable likelihood that his incident report and interview with state police would reach federal officials, challenging his convictions under 18 U.S.C. § 1512 and § 1519. He also contended that the district court erred in ruling he breached a proffer agreement and allowed a biased juror to sit on his trial. Additionally, he claimed prosecutorial misconduct during the rebuttal closing argument.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that sufficient evidence supported Sheffler’s convictions, as it was reasonably likely that his false statements would reach federal officials, given the severity of the crime and the cooperation between state and federal authorities. The court also found no clear error in the district court’s conclusion that Sheffler breached the proffer agreement by making false statements during FBI interviews. Furthermore, the court determined that the district court did not abuse its discretion in handling the juror bias issue or in denying Sheffler’s motion for a new trial based on alleged prosecutorial misconduct.The Seventh Circuit affirmed the district court’s denial of Sheffler’s motion for a new trial and upheld his convictions. View "USA v Sheffler" on Justia Law

Ricky Patterson was convicted by an Illinois jury in 2003 for first-degree murder, arson, and felony concealment of a homicide related to the 2002 death of Derrick Prout. Patterson had arranged to buy marijuana from Prout, who went missing after their meeting. Evidence showed Patterson killed Prout, attempted to clean the crime scene, set his house on fire, and later burned Prout’s car with the body inside. DNA evidence linked Prout’s blood to Patterson’s home. Patterson was sentenced to 55 years in prison, and the Illinois Supreme Court affirmed the judgment.Patterson filed a petition for state postconviction relief and a motion for additional DNA testing, which led to protracted state court proceedings. The Illinois Appellate Court affirmed the denial of his postconviction petition but remanded for further DNA testing, which confirmed the initial DNA match. Patterson’s subsequent appeals were denied, and his motion to file a late petition for leave to appeal was also rejected by the Illinois Supreme Court.The United States Court of Appeals for the Seventh Circuit reviewed Patterson’s federal habeas petition, which was filed more than six years after the one-year limitation period had expired, even accounting for tolling. Patterson argued for an exception based on actual innocence, but the court found his evidence insufficient to meet the demanding standard required to bypass the time bar. The court affirmed the district court’s dismissal of Patterson’s habeas petition as untimely, concluding that the new evidence presented did not establish a probability that no reasonable juror would have found him guilty. View "Patterson v. Adkins" on Justia Law

Nathaniel Pryor was stopped by police in Aurora, Illinois, after officers received a tip about drug activity linked to a van. Pryor exited the van quickly, and an officer ordered him to the ground, took him down, struck him twice, and searched him. No drugs were found, and Pryor was charged with obstructing/resisting a police officer, but the charge was later dropped. Pryor then sued several officers and the City of Aurora, alleging multiple federal and state law claims, including under 42 U.S.C. § 1983.The United States District Court for the Northern District of Illinois granted in part the defendants' motion for summary judgment, dismissing some claims and allowing others to proceed to trial. At trial, the jury found in favor of the defendants on the remaining claims. Pryor appealed, arguing that the district court erred in its summary judgment decision and in various evidentiary and procedural rulings during the trial.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the district court did not err in granting summary judgment on Pryor’s false arrest claim, finding that the officers had probable cause to arrest him for obstruction of justice and resisting arrest. The court also upheld the district court’s decision to grant qualified immunity to the officer for the leg sweep and tackle, as Pryor failed to show that the use of force was clearly established as excessive under the circumstances. Additionally, the court found that the searches conducted by the officer were proper incidents to Pryor’s arrest and were not extreme or patently abusive.The Seventh Circuit also affirmed the district court’s evidentiary and procedural rulings, including the admission of drug surveillance evidence, the exclusion of certain testimony by Pryor, and the handling of jury instructions. The court concluded that the district court did not abuse its discretion in these decisions and that any errors were harmless. The judgment of the district court was affirmed in full. View "Pryor v. Corrigan" on Justia Law

Police officers in Fitchburg, Wisconsin, responded to a noise complaint at a house party. Upon arrival, Sergeant Dan Varriale observed a physical altercation between Anthony Bailey and a woman. After separating them, Varriale handcuffed Bailey and, upon questioning, discovered Bailey had a gun. Bailey, a felon, was charged with unlawful possession of a firearm.Bailey moved to suppress the gun, arguing his arrest lacked probable cause. A magistrate judge found Varriale's testimony credible and concluded there was probable cause under Wisconsin’s disorderly conduct statute. The district judge adopted these findings and denied the suppression motion. Bailey entered a conditional guilty plea, reserving the right to appeal the suppression decision.The United States Court of Appeals for the Seventh Circuit reviewed the case. Bailey argued that the body-camera footage contradicted Varriale’s testimony, particularly regarding the presence of snow on the clothing of the individuals involved. The court found the video did not contradict the sergeant’s account and upheld the credibility of Varriale’s testimony. The court concluded that the physical fight observed by Varriale provided probable cause for arrest under Wisconsin’s disorderly conduct statute.The Seventh Circuit affirmed the district court’s decision, denying Bailey’s motion to suppress the firearm. View "USA v. Bailey" on Justia Law

Devontae Martin was involved in a drug distribution operation in Gary, Indiana, led by Teddia Caldwell. In July 2017, Caldwell proposed robbing Kevin Hood, a local car wash owner believed to have a large stash of drugs and money. Martin, armed with an AK-47, and his accomplice Taquan Clarke, armed with a pistol, attempted the robbery at Hood's car wash. During the confrontation, Clarke shot and killed Hood. Martin was subsequently charged with federal drug and firearms offenses and chose to go to trial.The United States District Court for the Northern District of Indiana, Hammond Division, presided over Martin's trial. A jury found Martin guilty of drug conspiracy and using a firearm during a drug offense. At sentencing, the district court considered the advisory range of life imprisonment under the U.S. Sentencing Guidelines and the factors in 18 U.S.C. § 3553(a). The court emphasized the violent nature of Martin's actions and ultimately sentenced him to life imprisonment, despite acknowledging his difficult upbringing.The United States Court of Appeals for the Seventh Circuit reviewed Martin's appeal. Martin argued that the district court procedurally erred by believing it could only impose a life sentence if a departure ground was authorized by the Guidelines and that the court sentenced him based on inaccurate information. The Seventh Circuit found that the district court did not limit its discretion to depart from the Guidelines and did not base its decision on inaccurate information. The appellate court conducted a de novo review of the sentencing hearing and affirmed Martin's life sentence. The court also reiterated that defendants do not need to object at sentencing to preserve issues for de novo review on appeal. View "USA v. Martin" on Justia Law

In late 2020, the FBI began investigating Tyron Offutt for narcotics trafficking in Centralia, Illinois. A confidential informant conducted three controlled purchases of methamphetamine from Offutt, which were recorded. Based on these buys, a search warrant was obtained and executed on February 3, 2021. Offutt attempted to flee during a traffic stop but was eventually apprehended. The search of his residence revealed methamphetamine, firearms, marijuana, cash, and drug paraphernalia.The United States District Court for the Southern District of Illinois appointed Dan Cronin as Offutt’s attorney, but he was later replaced by Rebecca J. Grosser due to a conflict of interest. Offutt was indicted on multiple counts related to drug distribution and firearm possession. Offutt requested new counsel multiple times, citing communication issues, and eventually, Bobby Edward Bailey was appointed as his third attorney. Offutt’s trial commenced on December 6, 2022, and he was found guilty on three counts but the jury could not reach a verdict on one count.On appeal to the United States Court of Appeals for the Seventh Circuit, Offutt challenged his conviction and sentence, arguing that the district court erred in instructing the jury that his flight could be considered evidence of guilt and that his Sixth Amendment right to counsel was violated when his request for counsel at sentencing was denied. The Seventh Circuit held that the flight instruction did not affect the trial's outcome and that Offutt had constructively waived his right to counsel by refusing to work with appointed attorneys and failing to retain private counsel. The court affirmed Offutt’s conviction and sentence. View "USA v. Offutt" on Justia Law

Clarence Bonds, serving a 71-month sentence for transporting a firearm in interstate commerce as a felon, sought a reduced sentence based on Amendment 821 to the U.S. Sentencing Guidelines. This amendment, which applies retroactively, reduced Bonds's criminal history category from IV to III, thereby lowering his advisory Guidelines range from 57–71 months to 46–57 months. Bonds requested the district court to reduce his sentence accordingly. The district court acknowledged the amendment's impact but declined to reduce his sentence, citing the need for deterrence, incapacitation, public protection, and Bonds's extensive criminal history, which included numerous violent crimes with firearms.The United States District Court for the Northern District of Indiana denied Bonds's motion for a sentence reduction. The court recognized the amendment's effect on Bonds's criminal history category and advisory range but exercised its discretion to maintain the original sentence. The court emphasized Bonds's long criminal history and the serious nature of his offenses as reasons for not reducing the sentence.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's decision, finding no abuse of discretion in denying Bonds's motion for a sentence reduction. The appellate court agreed that the district court had adequately considered the relevant factors under 28 U.S.C. § 3553(a) and provided a sufficient explanation for its decision. Additionally, the appellate court addressed whether the Criminal Justice Act authorized the appointment of appellate counsel for Bonds in his effort to challenge the district court's ruling. The panel was divided on this issue, with each judge providing a separate opinion. Ultimately, the court affirmed the district court's denial of Bonds's motion on the merits. View "United States v. Bonds" on Justia Law

Sherman Fields, a federal prisoner, filed a petition for a writ of habeas corpus under 28 U.S.C. § 2241, which was dismissed by the district court. Fields was previously convicted of multiple crimes, including murder and carjacking, after escaping from federal custody. He was sentenced to death on one count and to imprisonment on others. Fields sought relief through various motions under 28 U.S.C. § 2255, which were denied, and his convictions and sentence were affirmed on direct appeal by the Fifth Circuit.Fields later filed a habeas petition under § 2241 in the Southern District of Indiana, where he was imprisoned. The district court stayed the proceedings pending Supreme Court decisions in related cases. Following these decisions, Fields filed another § 2255 motion, which led to the vacating of his death sentence and resentencing to life imprisonment. The district court then dismissed his § 2241 petition, holding that Fields failed to demonstrate that § 2255 was inadequate or ineffective to test the legality of his detention, as required by § 2255(e).On appeal, Fields argued that § 2255 was inadequate to address his claim of judicial bias. The United States Court of Appeals for the Seventh Circuit reviewed the case and referenced the Supreme Court's decision in Jones v. Hendrix, which clarified the relationship between § 2241 and § 2255. The court held that § 2255 is not inadequate or ineffective simply because a prisoner cannot meet the standards for a successive motion under § 2255(h). The court found that Fields had already presented his claims of judicial bias in his § 2255 motions, which were denied on the merits.The Seventh Circuit affirmed the district court's decision, concluding that Fields could not pursue his claims under § 2241 because he failed to meet the requirements of the saving clause in § 2255(e). The court emphasized that the inability to meet the standards for a successive § 2255 motion does not render § 2241 available for such claims. View "Fields v. Gilley" on Justia Law