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

Eric Kyereme was indicted on five counts of wire fraud for misleading investors in his company, Sika Capital Management, LLC. He solicited $200,000 for the "Alpha Fund," which he lost through poor trading. Instead of informing investors, he created fake account statements to show positive returns. Kyereme pleaded guilty to one count but disputed his dealings with Da Zhou, a business associate who invested $133,000, allegedly for shares in RestoreFlow Allografts (RFA). The government claimed Kyereme used Zhou's money to cover Alpha Fund losses, while Kyereme argued it was a legitimate transaction.The United States District Court for the Northern District of Illinois held an evidentiary hearing and found that Kyereme defrauded Zhou. The court determined that Zhou's $133,000 investment was part of the wire fraud scheme, increasing the total loss amount to $335,500. This led to a higher offense level and a sentencing range of 41 to 51 months. The court sentenced Kyereme to 36 months in prison, three years of supervised release, and ordered $185,500 in restitution, including $135,500 to Zhou.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found no clear error in the district court's determination that the Zhou transaction was part of the wire fraud scheme. The court noted that the evidence, including the membership agreement and the Primrose operating agreement, supported the finding that Kyereme defrauded Zhou. The appellate court also held that Kyereme had sufficient notice that the district court would rule on the Zhou transaction at the final sentencing hearing. Consequently, the Seventh Circuit affirmed Kyereme's sentence. View "United States v. Kyereme" on Justia Law

Ronald Williams, a driver for hire, was convicted of sex trafficking and conspiracy to commit sex trafficking. In April 2018, Williams transported two teenage girls, Hannah Brown and Cyan Smith, for commercial sex work at the behest of his co-defendant, Kennedy Spencer. Both girls were minors and vulnerable, with histories of mental health challenges. Spencer arranged for the girls to engage in commercial sex acts, and Williams facilitated their transportation and received a portion of the earnings.The United States District Court for the Northern District of Illinois, Eastern Division, tried Williams and Spencer jointly. On November 1, 2022, a jury found both men guilty of conspiracy to commit sex trafficking and sex trafficking of both Hannah and Cyan. Williams appealed his conviction, arguing insufficient evidence to support the jury's verdict.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court noted that Williams bore a heavy burden to overturn the jury's verdict, requiring the record to be devoid of evidence supporting guilt beyond a reasonable doubt. The court found sufficient evidence that Williams knew Spencer intended to use the girls for commercial sex acts, facilitated their transportation, and profited from their exploitation. Additionally, the court determined that Williams had a reasonable opportunity to observe that both girls were minors, satisfying the statutory requirements under 18 U.S.C. § 1591 and § 1594.The Seventh Circuit affirmed Williams's conviction, concluding that the jury had sufficient evidence to find him guilty of sex trafficking and conspiracy to commit sex trafficking. View "USA v Williams" on Justia Law

Wesley K. White, Jr. pleaded guilty to two counts of unlawful possession of a firearm under 18 U.S.C. § 922(g)(1). The government agreed to recommend a sentence at the low end of the guidelines range as part of a plea agreement. However, while awaiting sentencing, White violated federal law again, leading the government to seek release from its sentencing recommendation. The district court granted this motion and sentenced White to a prison term exceeding the guidelines range.The United States District Court for the Southern District of Illinois initially handled the case. White had previously pleaded guilty to a felony firearms offense in Illinois state court and was on probation when further violations occurred. During a compliance check in 2018, authorities found a semiautomatic rifle and other firearm accessories in his residence. In 2020, White was seen in a Facebook Live video handling firearms at a shooting range. He admitted to firing the guns but claimed they were not at his residence. Subsequent searches revealed ammunition and a gun case. White was indicted for his 2018 and 2020 conduct and pleaded guilty.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's decision, finding that White breached the plea agreement by violating federal law through marijuana use and firearm possession. The district court did not err in its factual findings or in allowing the government to withdraw from its sentencing recommendation. The court also found that the district court did not abuse its discretion in imposing an above-guidelines sentence, considering White's history and the § 3553(a) factors. The Seventh Circuit affirmed the district court's judgment in full. View "United States v. White" on Justia Law

In February 2018, two men invaded a home in Rockford, Illinois, resulting in the death of Julian Young, Jr. and the escape of Jasmine Meneweather. Meneweather initially provided general descriptions of the assailants but no specific identities. Later, she sent a photo of one perpetrator to Detective Eric Harris, but the person was not identified. Over a year later, Harris received another photo from Young’s aunt, identifying the assailants as brothers Cortez and Shawnqiz Lee. Meneweather later identified Shawnqiz Lee in a photo array. Despite Lee’s alibi of being at work during the crime, he was arrested in November 2019 based on a criminal complaint and a judge-issued arrest warrant. A grand jury indicted Lee, but subsequent DNA evidence did not match him. Lee was released in December 2020 after the charges were dismissed.The United States District Court for the Northern District of Illinois granted summary judgment to the police officers, reasoning that probable cause existed based on Meneweather’s identification, which is an absolute defense to Lee’s claims. Lee appealed, arguing that the officers lacked probable cause and that they recklessly withheld material facts.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court’s decision. The court held that probable cause existed based on Meneweather’s identification, which was sufficient to support the arrest warrant. The court also found that the officers did not recklessly withhold material facts that would have negated probable cause. Additionally, the grand jury indictment provided prima facie evidence of probable cause, which Lee failed to rebut. Consequently, the court affirmed the summary judgment in favor of the police officers, concluding that probable cause was an absolute defense to Lee’s Fourth Amendment and state-law claims. View "Lee v Harris" on Justia Law

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