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

Michael Davis was arrested after a 911 call from a 15-year-old girl in Gary, Indiana, reported that he had threatened to kill her mother and had an assault rifle in his car. Police located Davis following the family's minivan and arrested him. A search of his vehicle revealed a loaded, semi-automatic shotgun with an obliterated serial number. Davis was charged with illegal firearm possession under 18 U.S.C. § 922(g). He moved to suppress the shotgun, arguing the search violated the Fourth Amendment, but the district court denied his motion.The United States District Court for the Northern District of Indiana held a two-day evidentiary hearing and found that the warrantless search of Davis's vehicle was justified under both the search incident to arrest and automobile exceptions to the warrant requirement. Davis entered a conditional guilty plea, reserving his right to appeal the suppression ruling. He was sentenced to ninety-two months in prison and two years of supervised release.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's denial of Davis's motion to suppress, holding that the search of Davis's vehicle was lawful under both the search incident to arrest and automobile exceptions. The court found that the officers had probable cause to arrest Davis based on the credible 911 report and corroborating evidence. Additionally, the court determined that it was reasonable to believe Davis's vehicle contained evidence of the crime, thus justifying the search. The judgment of the district court was affirmed. View "United States v. Davis" on Justia Law

James Harris, with a significant criminal history, was on federal supervised release following a 2013 federal drug conviction. After his release in 2016, he was arrested and convicted in a state drug case, leading to the revocation of his federal supervised release. He was sentenced to one year in prison, followed by three years of supervised release. In 2020, Harris was arrested again on state gun charges, which led to further alleged violations of his federal supervised release conditions.The United States District Court for the Northern District of Illinois held a two-day evidentiary hearing in July 2023. The court found that Harris had violated the conditions of his supervised release by using controlled substances and failing to comply with the rules of a community corrections program. Additionally, the court found by a preponderance of the evidence that Harris had unlawfully possessed a firearm, despite his acquittal in the state gun case. The court sentenced Harris to 36 months in prison for the firearm violation and 24 months for the community corrections program violation, to be served concurrently, with no additional supervised release.The United States Court of Appeals for the Seventh Circuit reviewed the case. Harris argued that the district court lacked jurisdiction to rule on the supervised release violations and that procedural errors were made during the revocation hearing. The Seventh Circuit held that the district court had jurisdiction, as Harris's federal supervised release term was tolled during his five-month imprisonment for violating state supervised release. The court also found no procedural errors, concluding that Harris had admitted to the Salvation Army violations and that the district court did not rely on inaccurate information. The Seventh Circuit affirmed the district court's ruling. View "United States v. Harris" on Justia Law

Lafiamma Orona was indicted for mail theft, identity theft, and related crimes after a scheme involving the theft of mail, including credit cards and checks, from mailboxes in Elkhart County, Indiana. He pleaded guilty to all charges about six weeks before trial. Under the Sentencing Guidelines, a defendant who pleads guilty and admits their conduct can receive a two-point reduction in their offense level, with an additional one-point reduction possible if the government files a motion affirming that the defendant's acceptance of responsibility saved prosecutorial and court resources.The district judge awarded Orona the two-level reduction, but the prosecutor declined to move for the extra one-level reduction, citing Orona's baseless challenge to the loss amount, which required the government to prepare for a contested sentencing hearing. Orona objected, asking the judge to order the prosecutor to file the motion. The judge overruled the objection, holding that the government had permissibly withheld the motion based on Orona's frivolous challenge. This decision was consistent with circuit precedent, specifically United States v. Nurek and United States v. Sainz-Preciado.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's judgment. The court held that the Sentencing Commission's Amendment 775 did not abrogate the precedent set by Nurek and Sainz-Preciado. Therefore, the government was within its rights to withhold the motion for the additional one-level reduction under § 3E1.1(b) based on Orona's objections to the loss amount, which necessitated additional prosecutorial resources. The court concluded that the district judge correctly overruled Orona's objection and affirmed the judgment. View "United States v. Orona" on Justia Law

Andre Bowyer, a Jamaican national, pleaded guilty to re-entering the United States without permission after being previously removed. During his sentencing, Bowyer attempted to highlight his ties to a family he had formed in the U.S. The district judge interrupted him frequently, characterizing Bowyer's account as lacking insight and unconvincing. Bowyer received a below-guidelines sentence.Bowyer appealed, arguing that his right to make his own statement at sentencing was violated. He conceded that he did not object during the district court proceedings, so the review was limited to the plain-error standard. Bowyer did not specify what additional arguments he would have made if given more time. The district court had read a letter from Bowyer detailing his background and his relationship with the family, but the judge found this information irrelevant to the sentencing factors.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court noted that while the district judge's interruptions were frequent, they did not completely prevent Bowyer from speaking. The judge also solicited further comments from Bowyer at the end of the allocution. The court found that even if there was an error, it was not plain because there was no unambiguous case law against such interruptions. Additionally, Bowyer's arguments were already considered by the judge, and there was no indication that further allocution would have led to a different sentence.The Seventh Circuit concluded that Bowyer did not meet the plain-error test for reversal and affirmed the district court's decision. View "USA v. Bowyer" on Justia Law

José Mireles was involved in a drug distribution conspiracy that transported large quantities of cocaine and heroin from Los Angeles to Chicago. Mireles's role included retrieving drug shipments, delivering them to customers, and laundering the proceeds back to Los Angeles. The Drug Enforcement Agency eventually dismantled the network, arresting Mireles and other conspirators. Mireles escaped custody while being transported to court but was re-arrested 18 months later. He was convicted and sentenced to 342 months in prison.The United States District Court for the Northern District of Illinois handled the initial trial. Mireles challenged the admission of certain evidence and the calculation of his sentence. The district court admitted evidence of Mireles's failure to file tax returns, his escape from custody, and a conversation about procuring a firearm. The court also calculated the drug quantity attributable to Mireles and applied sentencing enhancements for obstruction of justice and reckless endangerment.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed Mireles's conviction, finding no abuse of discretion in the admission of the challenged evidence. However, the court ordered a limited remand for resentencing. The appellate court could not discern the factual basis for one of the sentencing enhancements related to obstruction of justice. The court upheld the enhancement for reckless endangerment but required further proceedings to clarify the obstruction enhancement. The court vacated Mireles's sentence and remanded the case for further proceedings consistent with its opinion. View "United States v. Mireles" on Justia Law

Michael Porter was investigated and indicted on ten counts related to child pornography, including receipt, possession, and production. He pleaded guilty to three counts, with a conditional plea on the production charge, reserving the right to appeal whether his conduct fell under 18 U.S.C. § 2251(a). Porter argued that he did not "use" minors or record them in "sexually explicit conduct" as defined by the statute and contested the district court's calculation of his offense level at sentencing.The United States District Court for the Northern District of Illinois denied Porter's motion to dismiss the production charges. Porter then entered a plea agreement, admitting to placing a hidden camera in a gym locker room and recording prepubescent boys in various states of undress and sexual activity. The district court calculated his total offense level at 43, including several enhancements, and sentenced him to 22 years in prison, followed by 15 years of supervised release.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The court held that Porter's conduct fell within the scope of 18 U.S.C. § 2251(a), as he "used" minors by recording them in sexually explicit conduct, including lascivious exhibition of the genitals. The court also upheld the sentencing enhancements, finding that Porter's actions constituted a pattern of activity involving the sexual abuse or exploitation of minors. The court rejected Porter's arguments, noting that his conduct was clearly distinguishable from cases where mere nudity was involved, and reaffirmed the established legal standards for determining lasciviousness and "use" under the statute. View "USA v. Michael Porter" on Justia Law

Brian Jones, a Wisconsin prisoner, sued several correctional officers under 42 U.S.C. § 1983, alleging violations of his Eighth Amendment rights. The claims arose from an incident where Jones caused a disturbance in the prison dayroom, refused to return to his cell, and was subsequently placed in a restraint chair and transported to a restrictive-housing cell. Jones alleged that the officers used excessive force, conducted an unlawful strip search, and confined him in a dirty cell.The United States District Court for the Eastern District of Wisconsin granted summary judgment in favor of the officers on all claims. Jones, who represented himself during the lower court proceedings, argued on appeal that the magistrate judge should have granted his request for pro bono counsel under 28 U.S.C. § 1915(e)(1). The magistrate judge had denied this request, concluding that Jones was competent to litigate the straightforward case on his own.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that the magistrate judge applied the correct legal standard and reasonably concluded that Jones was capable of handling the case himself. The court also determined that the video evidence conclusively showed that Jones's claims lacked merit. The video demonstrated that the officers used only minimal force, conducted the strip search in a professional manner, and that Jones's cell conditions did not amount to a constitutional violation. Consequently, the Seventh Circuit affirmed the district court's judgment, holding that the denial of pro bono counsel was appropriate and that the officers did not violate Jones's Eighth Amendment rights. View "Jones v. Anderson" on Justia Law

Christopher Roalson was convicted of first-degree intentional homicide and burglary for the murder of a 93-year-old woman. At trial, a DNA analyst testified about evidence found on the murder weapons, although she did not perform the initial DNA testing. The original analyst was unavailable, and the testifying analyst based her conclusions on the initial analyst's notes. Roalson argued that this violated his right to confront the witness who performed the DNA testing.Roalson appealed his conviction, claiming a Confrontation Clause violation. The Wisconsin Court of Appeals affirmed the conviction, citing State v. Luther Williams, which allows one analyst to testify about their own conclusions based on another analyst's work if they can provide an independent evaluation. The Wisconsin and United States Supreme Courts denied certiorari. Roalson then filed a habeas corpus petition in the Eastern District of Wisconsin, which was dismissed. The district court found no clear federal law barring the testifying analyst from giving her own independent opinions.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court noted that the relevant federal law, as established by the Supreme Court, does not clearly prohibit an analyst from testifying to their own conclusions based on another analyst's data. The court found that the Wisconsin Court of Appeals reasonably applied existing law and that the testifying analyst did not merely act as a conduit for the original analyst's conclusions. Additionally, the court determined that any potential error was harmless given the substantial evidence supporting Roalson's conviction, including eyewitness testimony and his own confessions.The Seventh Circuit affirmed the district court's judgment, denying Roalson's habeas corpus petition. View "Roalson v. Noble" on Justia Law

A high-school administrator, Justin Schimandle, forcibly restrained a student, C.G., at school. Following an investigation, Detective Josh Duehning of the Dekalb County Sheriff’s Office submitted affidavits to support an arrest warrant for Schimandle on battery charges. An Illinois state magistrate judge issued the warrant, and Schimandle turned himself in. The criminal case proceeded to a bench trial, where Schimandle was found not guilty after the prosecution rested.Schimandle then sued the Dekalb County Sheriff’s Office and Duehning, alleging false arrest. The defendants moved for judgment on the pleadings, and the United States District Court for the Northern District of Illinois granted the motion, dismissing Schimandle’s claims. The court found that there was probable cause to arrest Schimandle and that Duehning was entitled to qualified immunity.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that arguable probable cause supported Schimandle’s arrest, meaning a reasonable officer could have believed probable cause existed based on the circumstances. The court also found that Duehning was entitled to qualified immunity, protecting him from liability for the false arrest claim. Additionally, the court noted that the magistrate judge’s issuance of the arrest warrant further supported the reasonableness of Duehning’s actions. Consequently, the court affirmed the dismissal of Schimandle’s complaint. View "Schimandle v. DeKalb County Sheriff's Office" on Justia Law

In 2004, Graham Stowe was charged with violent offenses against his former girlfriend and her family. He pleaded no contest, claiming insanity, which a state judge accepted, leading to his commitment for 39.5 years unless he recovered earlier. Released in 2007, Stowe was soon re-incarcerated for violating release conditions and later escaped in 2013, using drugs while free. After serving a sentence for escape, Stowe sought release in 2016 under Wisconsin law, which requires clear and convincing evidence of significant risk to deny release. Expert testimony indicated Stowe had a personality disorder and posed a risk of violence, leading the state circuit court to deny his release, a decision affirmed by the state court of appeals.Stowe then sought federal habeas corpus relief, arguing that the Wisconsin statute violated the Due Process Clause as interpreted in Foucha v. Louisiana, by allowing detention without a finding of mental illness. The district court found that Stowe had not preserved an as-applied challenge in state courts and limited the certificate of appealability to whether the statute was facially invalid. The district court upheld the statute, noting it allows consideration of mental history and condition, and thus often includes findings on mental illness.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court held that Stowe failed to show the Wisconsin statute was facially invalid under clearly established federal law, as the statute permits consideration of mental condition and does not inherently violate due process. The court also noted that Stowe's as-applied challenge was not preserved for federal review. Therefore, the court concluded that the Due Process Clause does not entitle Stowe to immediate release. View "Stowe v. Rybroek" on Justia Law