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

Kamala McCombs pleaded guilty to two counts of drug trafficking for her involvement in a conspiracy to transport methamphetamine from Arizona to Illinois. She was sentenced to concurrent terms of 121 months of imprisonment and 60 months of supervised release. McCombs appealed, arguing she deserved a mitigating role reduction under the U.S. Sentencing Guidelines because one of her co-conspirators received such a reduction.The government indicted McCombs and her co-conspirators for conspiracy to distribute methamphetamine and possession with intent to distribute. McCombs pleaded guilty and stipulated to the conduct. The probation office calculated her offense level and recommended a two-level downward variance, resulting in a guidelines range of 121 to 151 months. McCombs objected to the probation office's determination that she was not entitled to a mitigating role reduction. The district court overruled her objection, finding she was not substantially less culpable than her co-conspirators, and sentenced her to 121 months.The United States Court of Appeals for the Seventh Circuit reviewed the case. McCombs argued that the district court erred in not granting her a mitigating role reduction and that this resulted in an unwarranted sentencing disparity. The appellate court found that the district court correctly compared McCombs to her co-conspirators and concluded that her involvement was not substantially less than theirs. The court noted that McCombs's actions exceeded those of her co-conspirators, as she agreed to receive and transport drugs. The appellate court held that the district court's denial of the mitigating role reduction was not clearly erroneous and that the sentencing disparity was justified based on the record. The Seventh Circuit affirmed the sentence. View "USA v McCombs" on Justia Law

Jonathan Peoples pleaded guilty to felony possession of a controlled substance and was sentenced to one year of incarceration plus one year of mandatory supervised release. He received credit for time served, effectively completing his incarceration term. However, due to Illinois Department of Corrections (IDOC) policies, he was detained at Cook County Jail for four additional days until he could be transferred to IDOC for processing and release.Peoples filed a Section 1983 claim against Cook County and Sheriff Thomas J. Dart, alleging that his detention beyond his sentence violated his constitutional rights. The U.S. District Court for the Northern District of Illinois granted summary judgment in favor of the defendants, concluding that neither the Fourth nor the Fourteenth Amendments applied to Peoples's claim and that he failed to present a triable Eighth Amendment claim.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court determined that the Fourth Amendment did not apply to Peoples's post-conviction detention. Instead, the Eighth Amendment, which prohibits incarceration beyond the end of a sentence without penological justification, was applicable. The court found that the Cook County Sheriff's Office had a penological justification for detaining Peoples until IDOC could process him, as required by Illinois law and the court's commitment order.The Seventh Circuit affirmed the district court's decision, holding that Peoples failed to establish that the Sheriff acted with deliberate indifference, a necessary element for an Eighth Amendment violation. Consequently, without a constitutional injury, Peoples's Section 1983 claim could not succeed. View "Peoples v Cook County" on Justia Law

Police stopped Martin Devalois for a traffic violation. During the stop, a drug-sniffing dog alerted to narcotics in Devalois’s rental vehicle. Instead of complying with the police request to exit the car, Devalois initiated a high-speed chase that ended in a crash. Police searched the vehicle and found a small amount of marijuana and a gun. Devalois, a convicted felon, was charged with illegally possessing a firearm. He moved to suppress the gun, arguing that the police unconstitutionally prolonged the traffic stop to conduct the dog sniff. The district court denied his motion, and a jury found him guilty.The United States District Court for the Northern District of Indiana held a suppression hearing where the court found the police officer’s testimony credible and determined that the officer did not extend the length of the stop. The district court denied Devalois’s motion to suppress the gun, and the jury subsequently found him guilty of the firearm charge. Devalois was sentenced to 92 months’ imprisonment and appealed the denial of his motion to suppress.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that the district court’s factual finding that the officer did not prolong the traffic stop was not clearly erroneous. The court held that the officer’s actions during the stop were within the mission of the traffic stop and did not unlawfully extend its duration. The court also held that the dog sniff did not violate the Fourth Amendment as it was conducted while the officer was still diligently pursuing the stop’s mission. Consequently, the search of the vehicle and the seizure of the gun were lawful. The Seventh Circuit affirmed the district court’s decision denying Devalois’s motion to suppress the gun. View "United States v. Devalois" on Justia Law

The case involves Shamond Jenkins, who was convicted of robbing a Centier Bank branch in South Bend, Indiana, in December 2020. Jenkins was identified as a suspect in three robberies in northern Indiana between December 2020 and January 2021. During a traffic stop on January 8, 2021, Jenkins was found with cash, including a bait bill from the South Bend robbery, and was wearing red-and-white Air Jordan sneakers similar to those worn by the robber. Jenkins was charged with multiple counts, including the South Bend bank robbery, to which he pleaded not guilty.In the district court, Jenkins was found guilty of the South Bend bank robbery but not guilty of the Granger Centier Bank robbery. The jury could not reach a unanimous decision on the Check Into Cash robbery. Jenkins objected to the Presentence Investigation Report's recommendations, including an enhancement for obstructing justice by presenting false testimony and the inclusion of juvenile adjudications in his criminal history. The district court overruled these objections and sentenced Jenkins to 100 months in prison.The United States Court of Appeals for the Seventh Circuit reviewed Jenkins's appeal. Jenkins argued that the evidence was insufficient to convict him, that his Fifth and Sixth Amendment rights were violated due to the face mask he had to wear during the trial, and that the district court erred in applying a sentencing enhancement for perjury and in counting his juvenile convictions. The Seventh Circuit found no error in the district court's decisions. The court held that the face mask did not render the in-court identifications unduly suggestive or violate Jenkins's confrontation rights. The court also upheld the sufficiency of the evidence and the sentencing decisions, affirming Jenkins's conviction and sentence. View "USA v Jenkins" on Justia Law

Kein Eastman was abducted at gunpoint from his grandmother’s house by Kenwyn Frazier, taken to an apartment in East St. Louis, and subjected to threats, beatings, and a gunshot over a piece of jewelry. Eastman fled the scene with a bloodied face and has not been seen since. Kenwyn and his brother Kendrick Frazier were charged with kidnapping and found guilty by a jury. They appealed on several grounds, including a violation of Kendrick’s Sixth Amendment right to his choice of counsel, the constitutionality of the federal kidnapping statute, the sufficiency of the evidence, and aspects of their sentencing.The United States District Court for the Southern District of Illinois denied the Fraziers' motion to dismiss the indictment and their post-trial motions for acquittal or a new trial. The court also applied a four-level sentencing enhancement, finding that Eastman sustained permanent or life-threatening bodily injury. Kendrick’s request for joint representation by attorney Beau Brindley was denied due to potential conflicts of interest, and he retained separate counsel.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s decisions. The appellate court found no abuse of discretion in denying Kendrick’s choice of counsel, given the potential for conflicts of interest. The court upheld the constitutionality of the federal kidnapping statute, citing precedent that the use of instrumentalities of interstate commerce, such as cars and cellphones, suffices for federal jurisdiction. The court also found sufficient evidence to support Kendrick’s conviction for aiding and abetting the kidnapping. Lastly, the court affirmed the application of the sentencing enhancement, agreeing that the evidence supported the finding that Eastman sustained a permanent or life-threatening injury. View "United States v. Frazier" on Justia Law

William Hudson was convicted in Wisconsin state court of conspiracy to commit first-degree intentional homicide and conspiracy to commit arson. The convictions stemmed from an agreement Hudson made with another inmate, Scott Seal, to kill Seal’s ex-girlfriend and commit arson in exchange for payment. Seal, however, was an informant. After Hudson was released, he met with an undercover officer posing as Seal’s defense attorney, accepted an envelope with $6,000 and the targets' addresses, and was arrested. Hudson claimed he never intended to commit the crimes but was trying to scam Seal to support himself and his sister, Dana Hudson.Hudson filed a direct appeal alleging outrageous governmental conduct and ineffective assistance of trial counsel for not arguing the government’s conduct. The Wisconsin circuit court denied postconviction relief, and the Court of Appeals of Wisconsin affirmed. The Supreme Court of Wisconsin denied review. Hudson then filed a postconviction motion under Section 974.06, claiming ineffective assistance of trial counsel for not calling Dana as a witness and not investigating her testimony. The Wisconsin circuit court held evidentiary hearings and denied relief, finding counsel’s performance was not deficient. The Court of Appeals of Wisconsin affirmed, and the Supreme Court of Wisconsin denied review.Hudson filed a habeas petition in federal court, claiming ineffective assistance of trial counsel and postconviction counsel. The district court denied the petition, holding that the state court had not misapplied Strickland v. Washington and that trial counsel’s performance satisfied Strickland’s deferential standard. The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision, concluding that even if counsel’s performance was deficient, Hudson failed to demonstrate that the deficiencies prejudiced the outcome of the case. View "Hudson v DeHaan" on Justia Law

Rhonda Sutton was charged with conspiracy to commit health care fraud. At her arraignment in June 2018, the district court appointed counsel to represent her. Sutton pleaded not guilty in January 2020. After several delays due to the COVID-19 pandemic, the district court set her trial for November 2022. In September 2022, Sutton requested her attorneys to engage in plea negotiations, but she ultimately decided to proceed to trial. She then expressed dissatisfaction with her counsel and requested new representation. Her counsel filed a motion to withdraw, which the district court denied, citing no conflict or communication breakdown and suspecting a delay tactic.The United States District Court for the Northern District of Illinois denied Sutton's motion to substitute appointed counsel, finding no conflict or communication breakdown and suspecting her request was a delay tactic. The trial proceeded as scheduled, and the jury returned guilty verdicts on all counts. Post-trial, Sutton's counsel filed another motion to withdraw, which the district court granted, appointing new counsel for sentencing. At sentencing, Sutton raised objections to the proposed conditions of supervised release, but she waived her challenge to one condition by not objecting at the appropriate time.The United States Court of Appeals for the Seventh Circuit reviewed the case. Sutton raised two issues on appeal: the denial of her pretrial motion to withdraw and the constitutionality of a supervised release condition. The court held that the district court did not abuse its discretion in denying the motion to withdraw, as Sutton had no right to insist on counsel she could not afford, and her request appeared to be a delay tactic. The court also found that Sutton waived her challenge to the supervised release condition by not objecting at the appropriate time. The judgment of the district court was affirmed. View "USA v Sutton" on Justia Law

Jeffery Henson was convicted of federal fraud, including aggravated identity theft, money laundering, and wire fraud, for diverting nearly $330,000 from his employer to his personal account. He was ordered to pay $436,495.93 in restitution. Following his arrest, Illinois police found $17,390 in cash in his car. The government sought to apply this cash towards Henson's restitution, but Henson argued that the money was obtained through an illegal search and seizure, as the warrant was issued nine hours after the search.The United States District Court for the Central District of Illinois, through a magistrate judge, granted the government's motion to turn over the cash. Henson appealed, contending that the magistrate judge lacked the authority to issue a final decision on the matter.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court determined that the magistrate judge acted outside of his authority, as there was no final decision in the case. The Federal Magistrates Act and the local rules of the Central District of Illinois did not authorize the magistrate judge to issue a final decision on the turnover motion without the district court's explicit assignment. Consequently, the Seventh Circuit dismissed the appeal for lack of appellate jurisdiction, as the magistrate judge's order was not an appealable final decision. View "USA v Henson" on Justia Law

In March 2021, Jamal Shehadeh was involved in a controlled drug buy orchestrated by the Taylorville, Illinois Police Department. A confidential informant paid Shehadeh for methamphetamine, and the transaction was recorded on video. Shehadeh was arrested shortly after leaving the informant's house, waived his constitutional rights, and admitted to delivering the drugs. Shehadeh claimed he knew the buy was a setup and intended to embarrass the police by taking the buy money without delivering drugs. However, he ended up giving the informant methamphetamine, which he claimed he thought was road salt.A grand jury indicted Shehadeh for delivering methamphetamine. The government moved to preclude cross-examination of a witness, Chief Dwayne Wheeler, about past misconduct, which Shehadeh's counsel did not oppose. The district court granted the motion. Shehadeh later filed a pro se motion to cross-examine Wheeler on additional topics, which the court struck. At trial, Shehadeh testified about his plan, but the jury found him guilty. The district court applied a two-level obstruction of justice enhancement and a career offender enhancement, resulting in a Guidelines range of 262 to 327 months. Shehadeh was sentenced to 92 months in prison.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that Shehadeh waived his evidentiary arguments by not objecting to the district court's rulings and failing to renew objections during the trial. The court also concluded that any error in applying the obstruction of justice enhancement was harmless because the career offender enhancement controlled the length of Shehadeh's sentence. The Seventh Circuit affirmed the conviction and sentence. View "USA v Shehadeh" on Justia Law

Christopher Easterling attempted to rob a Walgreens store on September 15, 2019, by brandishing a firearm and demanding money from the cashier, who fled. Easterling did not take anything and was apprehended. He was charged with interference with commerce by robbery, carrying and using a firearm during a crime of violence, and possessing a firearm after a felony conviction. Easterling pleaded guilty to all charges.The United States District Court for the Southern District of Illinois sentenced Easterling to 239 months in prison, which was above the advisory guidelines range of 141 to 155 months. The sentence included 155 months for the robbery, 120 months for the firearm possession (to run concurrently), and a consecutive 84 months for using a firearm during a crime of violence. Easterling appealed, and the Seventh Circuit vacated the judgment and remanded for resentencing after the Supreme Court ruled that attempted Hobbs Act robbery is not a "crime of violence," invalidating one of his convictions.At the resentencing, the district court calculated a new advisory range of 84 to 105 months but imposed the same 239-month sentence. Easterling appealed again, and during the appeal, the Sentencing Commission amended the guidelines to remove two criminal history points for offenses committed while on parole, which would lower his advisory range to 70 to 87 months. The district court declined to reduce his sentence, citing lack of jurisdiction due to the pending appeal.The United States Court of Appeals for the Seventh Circuit remanded the case for resentencing, noting that the district court had not had the opportunity to consider the retroactive amendment to the Sentencing Guidelines. The court found that it was in the interest of justice to remand for resentencing in light of the updated guidelines, rejecting the government's argument that the district court would impose the same sentence regardless. View "United States v. Easterling" on Justia Law