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

Federal agents arrested a defendant after he engaged in explicit online communications with an undercover agent posing as the father of an eight-year-old girl. Over several months, the defendant requested sexually explicit images of the fictitious child, instructed the agent on how to sedate her to facilitate the abuse, and provided detailed suggestions about the nature of the photographs. The defendant attempted to access links purported to contain the requested images, which were in fact fake and used to record his attempts.A grand jury indicted the defendant on three counts: attempted enticement of a minor to engage in criminal sexual activity, attempted sexual exploitation of a child for the purpose of producing a visual depiction, and attempted receipt of child pornography. At trial in the United States District Court for the Central District of Illinois, the government presented evidence through two FBI agents. After the government rested, the court granted the defendant’s motion for acquittal on the enticement charge but denied it on the other two; the defendant was convicted by a jury on attempted sexual exploitation and attempted receipt of child pornography and was sentenced to 180 months, the statutory minimum for the exploitation charge.The United States Court of Appeals for the Seventh Circuit reviewed the conviction for attempted sexual exploitation. The court held that the defendant’s sufficiency-of-the-evidence challenge was preserved and, viewing the evidence in the light most favorable to the government, found sufficient evidence to support the conviction beyond a reasonable doubt. The court further held that the jury was properly instructed that conviction under 18 U.S.C. § 2251(a) does not require direct communication with a minor, and that the statute covers conduct involving an intermediary. The court affirmed the judgment of the district court. View "USA v Carpenter" on Justia Law

Julius Robinson was convicted of murders committed during drug offenses and sentenced to death in the Northern District of Texas. His convictions and sentences were affirmed on direct appeal by the United States Court of Appeals for the Fifth Circuit. Robinson then filed a petition under 28 U.S.C. §2255, which was denied by the United States District Court for the Northern District of Texas, and the Fifth Circuit denied him a certificate of appealability. Subsequent efforts to reopen his case were treated as requests to file second or successive §2255 petitions, which were also denied.After these unsuccessful attempts, Robinson sought habeas relief under 28 U.S.C. §2241 in the United States District Court for the Southern District of Indiana, where he was incarcerated. He raised five issues, including claims about the jurisdiction of the trial court, alleged prosecutorial misconduct, ineffective assistance of trial counsel, and violations of his rights under the American Declaration of the Rights and Duties of Man. The district court dismissed Robinson’s §2241 petition, holding that §2255(e) barred review because Robinson had not shown that the remedy under §2255 was inadequate or ineffective, referencing the Supreme Court’s decision in Jones v. Hendrix.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that, under Jones and its own recent decision in Agofsky v. Baysore, §2255(e) does not permit a federal prisoner to seek relief under §2241 merely because he cannot satisfy the requirements for filing a second or successive §2255 motion, unless the sentencing court is unavailable. The Seventh Circuit further clarified that prior circuit decisions allowing such claims under §2241 are no longer authoritative. The court also rejected Robinson’s Suspension Clause argument and affirmed the district court’s dismissal of the petition. View "Robinson v. Lammer" on Justia Law

Alfredo Juarez-Perez, a citizen of Mexico, was arrested in Sun Prairie, Wisconsin, after illegally reentering the United States for the third time. His criminal history spans decades, including multiple state convictions for sexual assault, failure to register as a sex offender, operating while intoxicated, and federal convictions for distributing cocaine and illegal reentry. He has repeatedly used aliases to elude law enforcement and violated conditions of release by failing to appear for legal proceedings. Upon his most recent arrest, U.S. Immigration and Customs Enforcement (ICE) lodged a detainer against him, and he was indicted for illegal reentry in October 2025.A magistrate judge in the United States District Court for the Western District of Wisconsin initially ordered Juarez-Perez released pending trial, reasoning that the ICE detainer eliminated the risk of flight because he would remain in government custody. The magistrate judge indicated that, absent the detainer, Juarez-Perez would pose a serious risk of flight under the Bail Reform Act. The government appealed this decision, and the district court revoked the release order, finding that Juarez-Perez’s criminal history, likely incentive to consent to deportation, repeated illegal reentries, and use of fraudulent documents presented a serious risk of flight. The district court concluded that no conditions could reasonably assure his appearance in court.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision and affirmed the denial of Juarez-Perez’s motion for release pending trial. The Seventh Circuit held that the presence of an ICE detainer does not preclude pretrial detention under the Bail Reform Act, and that Juarez-Perez’s history demonstrated a serious risk of flight and non-appearance. The court found that no conditions of release would reasonably assure his appearance, and accordingly denied his motion for release. View "USA v Juarez-Perez" on Justia Law

Alvin Beasley was charged with being a felon in possession of a firearm after police responded to gunshots at his ex-girlfriend’s house in Danville, Illinois. Officers saw a car fleeing the scene, found Beasley inside, and recovered a discarded firearm. As Beasley was on parole for a felony conviction, he could not lawfully possess a firearm. After a jury found him guilty, a presentence investigation identified three prior felony convictions: armed robbery in 2004, aggravated battery in 2005, and second-degree murder in 2011. The probation office concluded that Beasley qualified for enhanced sentencing under the Armed Career Criminal Act (ACCA).The United States District Court for the Central District of Illinois overruled Beasley’s objection that a jury should decide whether his prior convictions occurred on “different occasions,” and sentenced him to 300 months’ imprisonment. The court relied on then-controlling Seventh Circuit precedent, which permitted judges to make this finding. Beasley appealed, arguing that recent Supreme Court decisions (Wooden v. United States and Alleyne v. United States) required that this factual question be determined by a jury.While the appeal was pending, the Supreme Court decided Erlinger v. United States, holding that the Fifth and Sixth Amendments require a jury to decide whether prior offenses occurred on different occasions under ACCA. The United States Court of Appeals for the Seventh Circuit agreed that the district court erred under Erlinger, but concluded the error was harmless. The appellate court found, beyond a reasonable doubt, that a properly instructed jury would have reached the same result, given the substantial gaps in time and the distinct nature of the offenses. The Seventh Circuit affirmed the district court’s judgment. View "United States v. Beasley" on Justia Law

De’Andre Owens was the subject of a controlled drug buy operation in Centralia, Illinois, on March 15, 2022. Law enforcement provided a confidential informant, Charlie Anderson, with money and recording equipment to purchase methamphetamine from Owens. The exchange occurred under police surveillance, but the recording device did not capture the transaction clearly. After the sale, Anderson was followed by Owens, prompting coordinated surveillance by detectives until Anderson safely rejoined them and turned over methamphetamine. While awaiting trial in jail for this offense, Owens attempted to bribe Anderson not to testify, orchestrating a series of calls offering Anderson $10,000 for his silence.In July 2023, Owens was indicted in the United States District Court for the Southern District of Illinois on counts of distributing methamphetamine and witness tampering. At trial, several law enforcement officers and experts testified regarding the procedures used in the controlled buy and the subsequent investigation. The jury found Owens guilty on both counts. The district court sentenced him to 360 months’ imprisonment, classifying him as a career offender based in part on a prior state drug conviction. Owens had initially objected to the career offender enhancement but withdrew that objection at sentencing.Owens appealed to the United States Court of Appeals for the Seventh Circuit, arguing errors related to expert testimony, jury instructions, handling of dual-role witnesses, and the career offender enhancement. The Seventh Circuit held that Owens forfeited or waived each argument. The court found no plain error in the admission of expert testimony, the inclusion of a witness in a jury instruction, or the handling of dual-role testimony, and concluded Owens had waived his objection to the career offender enhancement. The Seventh Circuit affirmed the judgment of the district court. View "USA v Owens" on Justia Law

After serving more than a decade in the Illinois state legislature, the defendant established a lobbying and consulting firm and also sold life insurance for a private company. For several years, she correctly filed her tax returns and reported her income. However, beginning in 2014, she significantly underreported her income on her personal tax returns or failed to file altogether, despite substantial earnings from her business and insurance work. She was later terminated from her insurance position for fraudulent activity. The IRS discovered unreported income and issued a notice of tax liability, prompting her to amend one return and enter a payment plan, which she later abandoned.A grand jury indicted her on six counts, including making false statements on tax returns and willfully failing to file returns for herself and her company. The United States District Court for the Northern District of Illinois, Eastern Division, made several evidentiary rulings before and during trial, including excluding evidence of her amended tax return and payment plan, and limiting her expert’s testimony. The jury convicted her on four counts. The court denied her motion for judgment of acquittal and later sentenced her to one year of imprisonment and supervised release. She subsequently filed a motion to modify her sentence to make her eligible for good-time credits, which the district court denied.The United States Court of Appeals for the Seventh Circuit reviewed her convictions and the district court’s evidentiary rulings de novo and for abuse of discretion, respectively. The appellate court held that there was sufficient evidence for a rational jury to find willfulness, affirmed the exclusion of post-offense remedial evidence as within the district court’s discretion, found her challenge to the impeachment ruling waived since she did not testify, upheld the limitation on her expert’s testimony, and agreed that her motion to correct the sentence was untimely and properly denied. The Seventh Circuit affirmed the judgment. View "United States v. Collins" on Justia Law

Federal law enforcement began investigating the defendant after a wiretap of an associate’s phone implicated him in drug trafficking outside Chicago. The investigation revealed that the defendant, a convicted felon, was likely involved in significant drug transactions and was concerned about being targeted for a robbery. He was overheard discussing that he possessed a firearm for protection. Surveillance observed him using countersurveillance driving maneuvers, prompting agents to initiate a stop. During the stop, the defendant failed to comply with commands, resisted a frisk, and was ultimately found to have a handgun in his pocket.The United States District Court for the Northern District of Illinois, Eastern Division, considered and denied the defendant’s motion to suppress the firearm, finding that the officers had reasonable suspicion for the stop and that their use of force did not convert the encounter into an arrest without probable cause. The case proceeded to trial, where the jury found the defendant guilty of being a felon in possession of a firearm. The district court also denied the defendant’s posttrial motions for acquittal and a new trial. At sentencing, the court declined to enhance the sentence under the Armed Career Criminal Act (ACCA), concluding that the defendant’s prior Illinois conviction for voluntary manslaughter was not a qualifying predicate offense.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the conviction, holding that the officers had reasonable suspicion and their conduct was justified under the circumstances. The court also found the evidence at trial was sufficient to support the verdict and that the district judge’s evidentiary rulings did not merit a new trial. However, the Seventh Circuit vacated the sentence, holding that the defendant’s 1982 Illinois voluntary manslaughter conviction qualifies as a violent felony under the ACCA, and remanded for resentencing. View "USA v Edwards" on Justia Law

A defendant was indicted on multiple federal charges, including sex trafficking by force, transporting a victim across state lines with the intent of prostitution, and coercing or enticing a victim to travel interstate for prostitution-related activities. During jury selection, a prospective juror with experience in local law enforcement expressed doubts about her ability to remain impartial, suggesting that cases typically proceed only when there is sufficient evidence. Her comments were made in the presence of other prospective jurors.After this exchange, the defendant moved to strike the entire venire, arguing that the comments had irreparably tainted the panel. The United States District Court for the Northern District of Illinois denied the motion but excused the individual juror for cause. The court reasoned that her experience was limited to a police department unrelated to the case and emphasized that it had already instructed the panel multiple times that an indictment is not evidence of guilt. The defendant was ultimately convicted on all counts, and his motion for a new trial—reiterating his concerns about jury prejudice—was denied by the district court, which found no prejudice resulted from the juror’s comments.On appeal, the United States Court of Appeals for the Seventh Circuit considered whether the district court abused its discretion in refusing to question or strike the rest of the venire and in providing the jury with a redacted copy of the indictment during deliberations. The Seventh Circuit held that the district court acted within its discretion in both respects, noting the low probability of prejudice, the adequacy of curative instructions, and the routine nature of providing indictments with proper safeguards. The court also rejected the argument of cumulative error and affirmed the judgment of the district court. View "USA v Thomas" on Justia Law

Two individuals who held leadership positions at a local public housing authority in South Bend, Indiana, orchestrated a scheme in which they collaborated with several contractors to submit false invoices for maintenance work that was never performed. The contractors cashed checks issued by the housing authority for these fictitious services and shared the proceeds with the two employees. This fraudulent activity came to light after a casino employee observed the pair gambling large amounts of cash and reported the suspicious behavior to law enforcement. Following an investigation, both individuals were indicted on multiple counts, including conspiracy to commit wire and bank fraud, several counts of bank fraud, wire fraud, and federal program theft.The United States District Court for the Northern District of Indiana presided over their trial. After the government presented its case, both defendants moved for judgments of acquittal on the wire fraud charges; the court reserved ruling, and the jury ultimately convicted both individuals on the majority of counts, although one was acquitted on a wire fraud count. The district court denied the motions for acquittal, imposed prison sentences, and ordered substantial restitution. The defendants appealed their convictions and sentences.The United States Court of Appeals for the Seventh Circuit reviewed the appeals. It held that the evidence was insufficient to sustain the bank fraud convictions because the government failed to prove that any false statement was made to a bank, as required by 18 U.S.C. § 1344(2), and therefore reversed those convictions. However, the Seventh Circuit affirmed the wire fraud convictions, finding that a rational jury could conclude the fraudulent scheme furthered the transmission of funds via interstate wire. The court also affirmed one defendant’s sentence enhancement for abuse of a position of trust, finding no clear error or harmless error. The case was remanded solely to correct a clerical error in the restitution order. View "United States v. Smith" on Justia Law

A special agent with Homeland Security Investigations was discovered to have stolen money from criminal targets, embezzled agency funds, and entered into a cash-for-protection arrangement with a confidential source. The agent’s conduct came to light after the confidential source was arrested by the DEA, and text messages between the two were uncovered. Investigators found that the agent deleted incriminating messages, misappropriated cash from drug dealers and agency sources, manipulated controlled buys for personal gain, and protected his source from law enforcement scrutiny. The agent was also shown to have structured cash deposits to evade bank reporting requirements and failed to report significant taxable income.The United States District Court for the Northern District of Illinois, Eastern Division, conducted a thirteen-day jury trial in 2023. The jury found the agent guilty on all counts, including filing false tax returns, structuring cash transactions, and concealing material facts from the government. The district court denied the agent’s post-trial motions for acquittal and a new trial, then imposed sentence. The agent appealed, contesting the sufficiency of the evidence supporting his conviction.The United States Court of Appeals for the Seventh Circuit reviewed the case. Applying the appropriate standards of review, the court held that there was sufficient evidence for a rational jury to convict on all counts. The evidence included direct and indirect proof of unreported income, clear indications of structuring to evade reporting requirements, and material omissions on government forms. The court found no grounds to disturb the jury’s credibility determinations or the district court’s denial of post-trial motions. Accordingly, the Seventh Circuit affirmed the judgment of the district court. View "USA v Sabaini" on Justia Law