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

Law enforcement suspected the defendant of supplying drugs to a gang in Illinois and, after conducting several controlled purchases, arrested him. During his arrest, officers found multiple small bags of drugs in his possession. A search of an apartment he shared with family members revealed additional drugs, items associated with drug trafficking, and four firearms. While in custody, the defendant made a recorded call to his parents referencing the firearms found in the apartment. He was indicted on seven counts, including distribution of controlled substances and possession of a firearm in furtherance of a drug trafficking crime. He pleaded guilty to the distribution counts and went to trial on the remaining counts.The United States District Court for the Northern District of Illinois, Eastern Division, presided over the trial. The government called a fingerprint analyst who testified that two of the firearms bore fingerprints matching the defendant’s. The defense challenged the analyst’s methodology but was permitted to present its own expert, despite late disclosure. The jury found the defendant guilty on both remaining counts, concluding he possessed all four firearms. The district court denied the defendant’s post-trial motions for acquittal and a new trial, and sentenced him to 123 months in prison.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether there was sufficient evidence to support the firearm conviction and whether the district court erred in admitting the expert fingerprint testimony. The appellate court held that the evidence—including the recorded phone call and fingerprint analysis—was sufficient for a rational jury to find constructive possession of the firearms. The court also concluded the district court properly applied Rule 702 and Daubert in admitting the expert testimony. The judgment of the district court was affirmed. View "United States v Andrews" on Justia Law

The case concerns a defendant who was indicted for sex trafficking minors and faced serious federal charges. Over the course of three years between his indictment and trial, the defendant was represented by five different court-appointed attorneys. He repeatedly refused to cooperate with his lawyers, frequently submitted pro se motions, and violated court orders prohibiting him from contacting victims and witnesses. Twice, after comprehensive hearings in line with Faretta v. California, the defendant knowingly and voluntarily waived his Sixth Amendment right to counsel and elected to represent himself, despite being warned by the judge that no further attorneys would be appointed if he changed his mind again.Throughout the pretrial proceedings, the United States District Court for the Northern District of Illinois patiently allowed several changes in representation, including the appointment of standby counsel. However, when the defendant again requested an attorney during trial, after previously waiving counsel and being warned that further appointments would not be made, the district judge denied the request. After a jury trial, the defendant was found guilty on all counts, and his posttrial motions—including a challenge to the denial of his midtrial request for counsel—were denied.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether the district judge abused his discretion in denying the midtrial request for a sixth appointed lawyer. The Seventh Circuit held that, after a valid Faretta waiver, district judges may require a defendant to abide by his choice to proceed pro se, especially if the request for counsel is made after trial has begun. The court further held that there is no constitutional requirement to reassess the defendant’s motives or the likely delay caused by such a request under these circumstances. The judgment of the district court was affirmed. View "USA v Perry" on Justia Law

William Walls was found by an Illinois state court to be a sexually violent person in 2015, leading to his civil commitment under Illinois law. The commitment was based, in part, on statements he made or that were made by his treatment providers while he was incarcerated for a prior sexual assault conviction. Walls has argued that these statements were obtained in violation of his constitutional rights. After his commitment, his case involved extensive delays, including a twelve-year period before the initial commitment decision and seven years before the state appellate court resolved the appeal filed by his counsel.After the 2015 commitment order, Walls—sometimes proceeding pro se despite being represented—filed a series of appeals and petitions. The Illinois Appellate Court eventually affirmed both the 2015 and a subsequent 2018 recommitment decision in a consolidated opinion. Walls’s first federal habeas petition under 28 U.S.C. §2254 was dismissed by the United States District Court for the Central District of Illinois on procedural default grounds. He did not appeal that dismissal. After the 2018 recommitment proceeding, Walls filed a second federal habeas petition, which was dismissed as an unauthorized successive petition under 28 U.S.C. §2244(b) because it challenged the same 2015 order or did not raise new claims as required.The United States Court of Appeals for the Seventh Circuit reviewed Walls’s appeal of the district court’s dismissal. The court held that, to the extent Walls was once again contesting the 2015 commitment order, his petition was barred as a successive habeas application. Alternatively, if he was challenging later decisions, he had failed to raise or exhaust federal claims relating to those decisions. The Seventh Circuit affirmed the district court’s dismissal of Walls’s petition. View "Walls v Posey" on Justia Law

The defendant was indicted under a federal statute that prohibits individuals convicted of crimes punishable by more than one year of imprisonment from possessing firearms. The defendant’s criminal history included prior convictions for armed robbery and aggravated battery, and the conduct leading to the present prosecution involved using a firearm to threaten passengers on public transportation and possessing a loaded semi-automatic weapon in a location where firearms were explicitly prohibited.The United States District Court for the Northern District of Illinois, Eastern Division, dismissed the indictment. The district court concluded that the statute in question, 18 U.S.C. §922(g)(1), was invalid on its face under the Second Amendment, meaning that it was unconstitutional in every possible application. The government appealed this decision.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court considered Supreme Court precedents regarding the Second Amendment, including District of Columbia v. Heller, McDonald v. Chicago, New York State Rifle & Pistol Association, Inc. v. Bruen, and United States v. Rahimi. The appellate court noted that, while there is disagreement among courts about the statute’s application in some circumstances, all courts of appeals have agreed that §922(g)(1) is valid in many applications and cannot be declared unconstitutional in all cases. The Seventh Circuit held that the statute cannot be found facially invalid and reserved judgment on whether it might be unconstitutional as applied to individuals whose prior convictions do not suggest they are dangerous. In this case, because the defendant’s convictions and conduct indicated a risk of dangerousness, the court reversed the district court’s dismissal and remanded the case for further proceedings. View "USA v Prince" on Justia Law

Kenneth Karwacki was convicted by a special court martial of delivering peyote to fellow soldiers and received a bad-conduct discharge from military service. Later, he applied for a permit to carry a concealed firearm in Wisconsin. The state denied his application under Wis. Stat. §941.29(1m)(b), which bars firearm possession by anyone convicted of a crime elsewhere that would be a felony if committed in Wisconsin. Although the military court labeled his offense a misdemeanor, Wisconsin classified his conduct as a felony under its own laws.Karwacki brought a federal lawsuit, arguing that Wisconsin’s decision to treat his military misdemeanor conviction as a state-law felony violated the Full Faith and Credit Clause of the U.S. Constitution and his Second Amendment rights. The United States District Court for the Eastern District of Wisconsin entered judgment in favor of the state, rejecting Karwacki’s claims.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The Seventh Circuit held that the Full Faith and Credit Clause does not apply to federal court martial convictions because such proceedings are not “judicial Proceedings of any other State,” nor has Congress prescribed any effect for court martial judgments in the states. The court also concluded that Wisconsin did not fail to give effect to the court martial’s judgment, as it imposed only collateral consequences under state law. Addressing the Second Amendment, the Seventh Circuit reasoned that neither the federal nor Wisconsin’s statutory scheme is facially invalid, and that individuals convicted of distributing illegal drugs are not entitled to as-applied relief from firearms disabilities. Therefore, the judgment was affirmed. View "Karwacki v Kaul" on Justia Law

In this case, the defendant was indicted under federal law for possessing firearms after having been previously convicted of felony offenses, including possession of cocaine with intent to distribute and being a firearm user while using controlled substances. The case arose when police, investigating a shooting, traced evidence to the defendant through witness statements, storage unit searches, and DNA samples. The defendant challenged both the admissibility of DNA evidence and the constitutionality of the federal statute prohibiting felons from possessing firearms as applied to him.The United States District Court for the Eastern District of Wisconsin denied the defendant’s motions to dismiss the indictment and to suppress the DNA evidence. The court found that the DNA collected by federal authorities was obtained independently of any potentially unlawful prior collection by state authorities, and that there was a sufficient evidentiary basis for the federal warrant. The defendant subsequently pleaded guilty but preserved his right to appeal the denial of his motions.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the legal conclusions de novo and factual findings for clear error. The Seventh Circuit affirmed the district court’s rulings. It held that the DNA evidence was admissible under the independent-source doctrine, as the federal warrant was based on evidence untainted by any prior illegality. The court also held that 18 U.S.C. § 922(g)(1), as applied to the defendant’s conviction for a dangerous felony (possession of cocaine with intent to distribute), did not violate the Second Amendment. The court reasoned that disarmament of individuals convicted of dangerous felonies is consistent with the nation’s historical tradition and supported by both categorical disarmament of dangerous groups and the historical imposition of severe penalties for such offenses. The judgment was affirmed. View "USA v Watson" on Justia Law

The petitioner was convicted of two separate murders in Indiana and sentenced to death for each. He unsuccessfully challenged his convictions and sentences in Indiana’s courts, including direct appeals and post-conviction proceedings, with the Indiana Supreme Court affirming the outcomes. After the Supreme Court of the United States denied review, the petitioner’s deadline to seek federal habeas corpus relief under 28 U.S.C. § 2254 expired in February 2021. Despite being represented by counsel appointed during the COVID-19 pandemic, communication difficulties and alleged mental health issues were cited as reasons for the late filing of his federal petition, which was submitted two years past the deadline.Following the late filing, the State moved to dismiss the petition as untimely. The petitioner argued for equitable tolling, claiming extraordinary circumstances prevented timely filing and requested discovery and an evidentiary hearing to support this claim. As part of the process, he also sought an order under the All Writs Act to be transported to a hospital for brain scans to support his argument regarding his mental health limitations.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s order granting the transportation request. The appellate court held that, under Shoop v. Twyford, a transportation order for evidence-gathering is warranted only if there is a demonstrated nexus between the sought evidence and its admissibility or relevance to a particular claim for relief. The court found that the petitioner failed to establish how the requested brain scans would be relevant or admissible in support of equitable tolling. Therefore, the Seventh Circuit reversed the district court’s transportation order and remanded the case for further proceedings. View "Gibson v. Neal" on Justia Law

Three individuals entered an apartment in Plover, Wisconsin, and committed an armed robbery, physically assaulting the two residents and stealing electronics and guitars. Two of the robbers, Lyndell Dale and Archie Biddell, were apprehended shortly after and implicated Maurice Holt as the third participant. Initially, the victims identified Gosha, Holt’s nephew, as the third assailant, but later expressed uncertainty. Two days after the robbery, Holt sold some of the stolen guitars, using his real name. A search of Holt’s residence, which Gosha frequented, yielded additional stolen property. Holt denied involvement and claimed he was elsewhere during the crime.Holt was tried in Wisconsin state court on charges including armed robbery. The prosecution relied on the sale of stolen items, pretrial identifications by Dale and Biddell, and circumstantial evidence. Neither victim could positively identify Holt at trial. Holt’s defense was twofold: that Gosha was the third robber, and that Holt had an alibi. Holt’s counsel attempted to introduce photographs to support the defense theory, but the trial court excluded them as irrelevant and cumulative. Holt was convicted on all counts and sentenced to twelve years. He pursued post-conviction relief, arguing the exclusion of evidence and ineffective assistance of counsel. The state post-conviction court and the Wisconsin Court of Appeals denied his claims, and the Wisconsin Supreme Court declined review.Holt sought habeas relief in the United States District Court for the Western District of Wisconsin, which granted his petition. On appeal, the United States Court of Appeals for the Seventh Circuit reversed. The Seventh Circuit held that the Wisconsin Court of Appeals reasonably applied Supreme Court precedent in rejecting Holt’s constitutional claims regarding exclusion of evidence and ineffective assistance of counsel. The court concluded that any errors did not have a substantial and injurious effect on the verdict and did not warrant habeas relief. View "Holt v. Boughton" on Justia Law

Paul Daugerdas was convicted in federal court for orchestrating a fraudulent tax shelter scheme that defrauded the U.S. Treasury of significant tax revenue. A jury found him guilty of conspiracy to defraud the IRS, mail fraud, client tax evasion, and obstructing the internal revenue laws. The federal district court sentenced him to 15 years in prison, ordered forfeiture of $164.7 million, and imposed $371 million in restitution, to be paid jointly and severally with co-conspirators. The criminal restitution order set a payment schedule of 10% of Daugerdas’s gross monthly income following his release from prison.After the United States Court of Appeals for the Second Circuit affirmed the convictions and sentence, the Internal Revenue Service, relying on 26 U.S.C. § 6201(a)(4)(A), assessed the same $371 million restitution as a civil tax liability, making the entire amount immediately due. The IRS also filed a notice of federal tax lien against Daugerdas’s property in Illinois. Daugerdas challenged the IRS’s authority to impose and collect restitution in this manner, particularly objecting to the acceleration of the payment schedule. The United States Tax Court upheld the IRS’s actions, ruling that the statutory provision authorized the IRS to assess and collect restitution for tax-related offenses, even when the underlying criminal conviction was under Title 18 rather than Title 26.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the Tax Court’s judgment de novo. The court held that 26 U.S.C. § 6201(a)(4)(A) empowers the IRS to assess and collect restitution ordered under 18 U.S.C. § 3556 for tax-related crimes, including those prosecuted under Title 18, and that the IRS is not bound by the payment schedule set by the criminal court. The Seventh Circuit affirmed the Tax Court’s judgment for the Commissioner. View "Daugerdas v CIR" on Justia Law

The petitioner was convicted of first-degree intentional homicide and related charges after a shooting at the Luna Lounge in Appleton, Wisconsin. Video evidence showed several people fleeing the scene, including the petitioner’s brother. Police interviewed three eyewitnesses—Watou Lee, Mikey Thao, and Ryan Thao—shortly after the incident. These witnesses described the shooter but did not explicitly identify the petitioner. However, police later received statements from other witnesses implicating the petitioner. The State did not disclose the initial interviews with Watou, Mikey, and Ryan to the defense and eventually destroyed the recordings, citing the witnesses’ fears for their safety. The defense only learned of the destroyed interviews after the witnesses were reinterviewed and those statements were provided. The petitioner moved to dismiss the charges or, alternatively, to bar the witnesses’ testimony, arguing violations of his due process rights under Brady v. Maryland and the principles set forth in California v. Trombetta and Arizona v. Youngblood.The Wisconsin Circuit Court denied the Brady claim but agreed the destruction of evidence violated due process, barring the State from calling the three witnesses at trial, though permitting the defense to do so. The petitioner did not object to this remedy and ultimately did not call the witnesses. He was convicted by a jury, and his conviction and denial of post-conviction relief were affirmed by the Court of Appeals of Wisconsin, with the Wisconsin Supreme Court declining review.On federal habeas review, the United States District Court for the Eastern District of Wisconsin denied relief, holding that the state appellate court did not act contrary to or unreasonably apply clearly established federal law. The United States Court of Appeals for the Seventh Circuit affirmed, holding that the state court’s application of Brady, Trombetta, and Youngblood was not objectively unreasonable and that the selected remedy did not violate clearly established federal law. View "Lee v Mlodzik" on Justia Law