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

In 2015, Giulio Palma and his friend Graham Kos developed a plan to pool investor funds to purchase and develop luxury properties in Italy, with the aim of reselling them or operating short-term rentals. Palma claimed to have exclusive connections enabling access to discounted properties. Over several years, they raised about $6 million from multiple investors, all of whom believed their funds would be used exclusively for acquiring and developing Italian properties. Contrary to his repeated assurances and the terms of their arrangements, Palma withdrew approximately $2 million for personal use, concealing these actions from investors. These unauthorized transactions were discovered in 2019.The United States District Court for the Northern District of Illinois, Eastern Division, indicted Palma on seven counts of wire fraud under 18 U.S.C. § 1343. Following a jury trial in 2023, Palma was convicted on six counts. He moved for a judgment of acquittal and a new trial, but the district court denied both motions, finding that the evidence overwhelmingly supported the jury’s verdict. The district court then sentenced Palma to 36 months in prison.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the denial of the motion for judgment of acquittal de novo, applying the standard for sufficiency of the evidence. The court held that the evidence was more than sufficient for a rational jury to find that Palma engaged in a scheme to defraud and acted with intent to defraud. The Seventh Circuit affirmed the judgment of the district court, upholding both the conviction and the sentence. View "USA v. Palma" on Justia Law

Andrew Boltz, age 25, met A.S., a 16-year-old, through the website Omegle in early 2020. Their communication continued across various platforms, including Snapchat, and involved frequent daily contact. Boltz repeatedly requested sexually explicit images and videos from A.S., fully aware of her minor status. A.S. testified that she was uncomfortable with these requests but ultimately sent nude photos. Law enforcement was alerted after A.S.’s mother discovered the relationship, leading to Boltz’s arrest.The United States District Court for the Northern District of Illinois, Eastern Division, presided over Boltz’s jury trial on charges including sexual exploitation of a minor. The court made several key evidentiary rulings: it excluded evidence that A.S. had sent explicit photos to other men under Federal Rule of Evidence 412 (the rape shield rule), allowed the government to introduce Rule 404(b) evidence that Boltz had groomed another minor, and permitted A.S.’s mother to testify about A.S.’s vulnerability. After his conviction, Boltz moved for a new trial, arguing the government failed to preserve exculpatory Snapchat messages. The district court denied the motion, finding no bad faith by the government.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed these rulings. The court held that the district court properly excluded evidence of A.S.’s sexual conduct with others under Rule 412, as it was either sexual behavior or predisposition and not central to Boltz’s defense. The court also found that the Rule 404(b) evidence was properly admitted for the non-propensity purpose of establishing Boltz’s identity, due to the distinctive similarities between the incidents. The court further ruled that A.S.’s mother’s testimony was relevant and that the government did not act in bad faith regarding evidence preservation. The Seventh Circuit affirmed the district court’s decision. View "USA v. Boltz" on Justia Law

A man was convicted of first-degree child sexual assault in Wisconsin after a two-day jury trial. The victim, a minor, had a prior relationship with the defendant, who was not his biological father but remained involved in his life. In late 2014, after the defendant cared for the child during the father’s hospitalization, the child’s behavior changed and troubling statements were made, leading to a report to Child Protective Services (CPS). A police investigation followed, and after a forensic interview in August 2015, the child disclosed inappropriate contact by the defendant, who was then charged with sexual assault.The State made various pre-trial disclosures, including a police report summarizing the CPS report, but did not provide the actual CPS report. At trial, the prosecution relied on testimony from the forensic interviewer, the child, the child’s grandmother, and the investigating officer. The defense had access to the police report but did not use it to impeach the officer’s testimony. The defendant testified and denied the allegations. The jury found him guilty, and he was sentenced to twenty-five years. He moved for postconviction relief, arguing suppression of material evidence and ineffective assistance of counsel. The postconviction court denied relief, but the Wisconsin Court of Appeals reversed. The Wisconsin Supreme Court unanimously reinstated the conviction.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s grant of habeas relief de novo, applying the deferential standard required by the Antiterrorism and Effective Death Penalty Act. The Seventh Circuit held that the Wisconsin Supreme Court reasonably applied federal law in finding that the suppressed CPS report was cumulative of evidence already available to the defense and not material, and that trial counsel’s performance did not prejudice the outcome. The Seventh Circuit reversed the district court’s judgment and denied habeas relief. View "Hineman v. Chase" on Justia Law

Robert Carter, convicted of wire fraud, sought compassionate release from his sentence under 18 U.S.C. § 3582(c)(1)(A), citing family caregiving obligations. The United States District Court for the Western District of Wisconsin denied his motion on February 6, 2026. Carter was required to file a notice of appeal within 14 days, but his notice was postmarked February 27 and received March 2, missing the deadline even under the prison-mailbox rule.Following the denial, Carter did not file a motion for extension of time, which would ordinarily be fatal in civil cases under Federal Rule of Appellate Procedure 4(a)(5). However, Rule 4(b)(4), governing criminal cases, allows the district court to extend the time to appeal “with or without motion” for up to 30 days after the deadline. Carter argued that the district judge implicitly granted an extension by docketing his late notice of appeal, but the court found this reasoning unpersuasive, emphasizing that docketing is a ministerial act and does not imply a judicial finding of excusable neglect or good cause.The United States Court of Appeals for the Seventh Circuit reviewed the matter. Adopting the consensus of other circuits, the court held that if a notice of appeal in a criminal case is filed within the 30-day extension window, the appeal should not be dismissed until the district judge has made a finding regarding excusable neglect or good cause, even without a formal motion for extension. Accordingly, the Seventh Circuit suspended further proceedings and remanded the issue to the district court for a determination on whether Carter’s delay was justified. View "USA v Carter" on Justia Law

The defendant was convicted of possessing methamphetamine with intent to distribute and, after serving his sentence, was released on supervised release in September 2024. Within two months, he failed to attend required drug tests and tested positive for fentanyl and methamphetamine. His probation officer filed a petition to revoke his supervised release, and a warrant was issued. He was later arrested in Minnesota on state charges, convicted of providing false information to an officer, and then transferred to federal custody. The district court initially revoked his supervised release but, at his request, deferred sentencing to allow him to enter a residential drug treatment program. He failed to report to treatment and was again arrested for similar offenses. At a subsequent hearing, the court considered his repeated violations and imposed a 24-month prison sentence followed by four years of supervised release.The United States District Court for the Western District of Wisconsin handled the revocation and sentencing proceedings. The court explained that the sentence aimed to hold the defendant accountable for his violations, protect the community, and promote specific and general deterrence. The court did not refer to punishment for the seriousness of the underlying offense or the need to promote respect for the law.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s actions. The main issue was whether the district court improperly considered retributive factors when imposing the sentence for the supervised release violation. The Seventh Circuit held that the district court did not err, as its reasoning focused on permissible objectives such as deterrence, protection, and rehabilitation, rather than retribution for the underlying offense. The appellate court affirmed the district court’s judgment. View "USA v. Stapleton" on Justia Law

Corrie Singleton, along with his brother and a minor, committed an armed robbery at a Chase Bank in Lansing, Illinois, using a stolen vehicle. Singleton held a loaded firearm to a Brink’s employee’s head during the robbery, while his accomplices emptied cash from the ATM and the armored truck. After fleeing the scene and crashing the getaway car, Singleton and the minor were apprehended by law enforcement, who recovered over $1 million in cash and firearms. Singleton’s brother escaped arrest. A federal grand jury charged Singleton with conspiracy to commit armed robbery, Hobbs Act robbery, and brandishing a firearm during and in relation to a crime of violence. Singleton pled guilty to the latter two charges.The United States District Court for the Northern District of Illinois, Eastern Division, sentenced Singleton in June 2025. The court reviewed the Presentence Investigation Report, which calculated an advisory guidelines range of 219 to 252 months’ imprisonment. Singleton requested a downward departure in light of his youth, lack of criminal history, and potential for rehabilitation, referencing a recent amendment to the Sentencing Guidelines. The government sought a sentence of 204 months. Ultimately, the district court imposed a below-guidelines sentence of 96 months for robbery, followed by the mandatory consecutive 84 months for the firearm charge, totaling 180 months’ imprisonment and four years of supervised release. The court explained its reasoning, referencing Singleton’s mitigating circumstances.On appeal, before the United States Court of Appeals for the Seventh Circuit, Singleton argued that his sentence was procedurally unreasonable because the district court failed to adequately consider his mitigation arguments and explain its reasoning. The Seventh Circuit held that the district court sufficiently addressed Singleton’s principal mitigation arguments and explained its rationale for the below-guidelines sentence. The court affirmed the district court’s judgment. View "USA v. Singleton" on Justia Law

In this case, federal drug enforcement agents received information suggesting that the defendant was involved in the distribution of large quantities of narcotics in Indiana. Following surveillance and a traffic stop that yielded evidence of drug activity, officers became concerned that the defendant was aware of their investigation. They installed a camera on a utility pole across the street from the defendant’s leased auto-repair shop without first obtaining a warrant. The property was surrounded by a six-foot fence, but it had significant gaps, including a thirty-foot-wide opening allowing vehicle and pedestrian access. The pole camera recorded activities on the property for approximately two weeks, capturing movements consistent with drug trafficking. Subsequent searches, supported by warrants, resulted in significant seizures of narcotics, firearms, and cash.The United States District Court for the Southern District of Indiana denied the defendant’s motion to suppress evidence obtained from the pole camera. The court held that the fence did not create a reasonable expectation of privacy in the observed activities because the gaps allowed visibility from the street. The court also found that the pole camera’s use was not a search requiring a warrant under prevailing precedent, and concluded that even without the camera footage, there was probable cause to support the search warrants. The court determined that, if necessary, the good-faith exception to the exclusionary rule would apply.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The Seventh Circuit held that the use of the pole camera did not violate the Fourth Amendment. The court reasoned that the camera captured activities observable to passersby through the substantial gap in the fence, the technology was in common public use, and the officers were lawfully present. The court also emphasized that commercial properties receive less Fourth Amendment protection than residences. View "USA v Kendrick" on Justia Law

A semi-truck driver was stopped in Illinois after state police received a tip from another law enforcement agency that the truck was carrying a large amount of narcotics. Two K9 troopers, not on routine patrol, waited on the side of the highway in the early morning hours to intercept the vehicle. The stated purpose for the stop was to conduct an administrative Level 3 inspection under Illinois’s commercial trucking regulatory scheme, involving checks of driver and vehicle documents. During the stop, the trooper noticed several signs he considered suspicious, including an odor of air freshener and irregularities with the driver’s route and cargo. A dog sniff of the truck led to the discovery of narcotics, and the driver was arrested.The United States District Court for the Central District of Illinois heard the defendant’s suppression motion, in which he argued the stop was a pretextual administrative inspection aimed solely at investigating criminal activity, thus violating the Fourth Amendment. The district court denied the motion, reasoning that the officer’s subjective intent was irrelevant so long as the stop was authorized under Illinois’s regulatory scheme.On appeal, the United States Court of Appeals for the Seventh Circuit held that, in the context of administrative inspections, an officer’s actual motivation for conducting the stop is relevant. The court found that the evidence showed the stop was undertaken solely to further a criminal investigation, not to enforce administrative regulations. It further held that the government had failed to demonstrate the stop was justified in its inception under the administrative inspection exception to the warrant requirement. The court concluded that the evidence obtained as a result of the stop must be suppressed and that the good faith exception to the exclusionary rule did not apply. The Seventh Circuit reversed the district court’s denial of the suppression motion and remanded for further proceedings. View "USA v. Martinez" on Justia Law

Federal authorities were investigating an individual suspected of orchestrating transnational cyber fraud and money laundering schemes originating in Nigeria and targeting U.S. nationals. Information from two sources, including a co-conspirator, implicated him as a leader of fraudulent operations. Investigators gathered corroborating evidence, such as suspicious messages, unusually high activity on messaging apps, and bank records showing millions in transactions with no apparent legitimate source. When authorities learned he would return to the U.S. from Nigeria, they requested a manual search of his electronic devices upon arrival at Atlanta’s international airport. Customs officers searched his phones, found evidence of criminal activity, and subsequently seized the devices for forensic imaging. Two days later, law enforcement obtained search warrants for the phones and their extracted data.The United States District Court for the Northern District of Illinois, Eastern Division, reviewed the defendant’s motion to suppress evidence from the warrantless border search of his cell phones, which he argued violated his Fourth Amendment rights. After an evidentiary hearing, the district court found law enforcement witnesses credible and denied the motion, concluding that the manual search at the border was justified under the border search doctrine. The defendant then entered a conditional guilty plea to wire fraud, preserving his right to appeal the suppression ruling.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s denial de novo. The court reaffirmed that routine, manual searches of electronic devices at the border do not require a warrant or individualized suspicion under circuit precedent, specifically United States v. Mendez, and Supreme Court precedent. The court held that the search was routine, reasonable, and justified by the border search exception. Even if a Fourth Amendment violation occurred, the good-faith exception would preclude suppression. The judgment of the district court was affirmed. View "USA v Eta" on Justia Law

In 2009, Jonathan Rose was involuntarily committed to a mental institution in Indiana due to a psychiatric disorder, though the specific diagnosis and its severity were not detailed in the record. He was released in early 2010 and has not been recommitted since. In 2022, Rose successfully purchased multiple firearms, though he was denied others after background checks revealed his prior commitment. In 2023, he was indicted under federal law for possessing firearms as a person previously committed to a mental institution and for making false statements to firearms dealers by denying his commitment history.The United States District Court for the Northern District of Indiana reviewed Rose’s case and dismissed the counts related to possession of firearms by a previously committed person under 18 U.S.C. §922(g)(4). The district court reasoned that this statute, as applied to someone no longer suffering from mental illness, was inconsistent with the Second Amendment, particularly in light of recent Supreme Court decisions emphasizing individualized assessments of current danger rather than permanent disabilities based on past conditions.The United States Court of Appeals for the Seventh Circuit considered the government’s appeal. The court determined that the district court should not have dismissed the indictment without an evidentiary hearing to assess Rose’s current mental health and dangerousness. The Seventh Circuit held that, after recent Supreme Court decisions, the constitutionality of §922(g)(4) as applied depends on whether the defendant currently poses a credible threat to the safety of others. Because the record lacked evidence concerning Rose’s present mental condition, the appellate court vacated the district court’s order and remanded for further proceedings to develop the necessary facts. View "USA v Rose" on Justia Law