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

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

Marion Thomas was stopped by Chicago police officers after failing to signal a turn. During the stop, officers reported smelling marijuana coming from his vehicle. After Thomas partially rolled down his window and refused to comply with several commands, officers opened his door and removed him from the car. Thomas was handcuffed and his car was searched, revealing a marijuana cigarette and a tray. Thomas claimed the items did not belong to him and experienced a medical issue, after which he was taken to the hospital. He was cited for the traffic violation and marijuana possession.Following his arrest, Thomas filed suit in the United States District Court for the Northern District of Illinois against the officers and the City of Chicago, alleging illegal search, illegal seizure, false arrest under 42 U.S.C. § 1983, and malicious prosecution under state law. Some claims and defendants were dismissed at summary judgment. At trial, the jury found for the defendants. Thomas moved for a new trial, arguing that the jury instructions were erroneous, that an officer gave misleading testimony, and that a question about his criminal record was prejudicial. The district court denied his motion.The United States Court of Appeals for the Seventh Circuit reviewed the case. It held that the challenged jury instructions accurately stated the law, including the principle that probable cause to arrest for any crime defeats a false arrest claim. The court found no abuse of discretion regarding the officer’s testimony about a marijuana “grinder,” as there was no evidence of fraud or prejudice. The court also determined that the question about Thomas’s criminal record did not prejudice the jury, since the objection was sustained and no answer was given. The Seventh Circuit affirmed the district court’s judgment. View "Thomas v McAuliffe" on Justia Law

Law enforcement in southern Illinois identified multiple Snapchat accounts linked to the same person, who used these accounts to impersonate a female and solicit nude images from minor boys. The investigation revealed that the defendant, Adam Power, knew some victims through his work as a choir director, substitute teacher, and day camp employee. He was arrested after police searched his devices and social media accounts, uncovering evidence of extensive child exploitation.A federal grand jury indicted Power on thirty-four counts related to child pornography and sexual exploitation of minors. He pleaded guilty to all counts without a plea agreement. The United States District Court for the Central District of Illinois ensured that Power’s pleas were knowing and voluntary, and asked him to confirm the factual basis for each count. At sentencing, the court considered the presentence report and the applicable Sentencing Guidelines, ultimately imposing a 60-year prison sentence, significantly less than the calculated Guidelines range of 740 years. The court highlighted the seriousness of the offenses and the lack of meaningful mitigating circumstances.On appeal to the United States Court of Appeals for the Seventh Circuit, Power sought to vacate his guilty pleas to eight counts, arguing the district court lacked an adequate factual basis for those pleas. Alternatively, he challenged his sentence as substantively unreasonable. The Seventh Circuit reviewed the guilty plea issue for plain error and found that Power failed to show a reasonable probability that, but for any alleged errors, he would not have pleaded guilty. The court also upheld the substantive reasonableness of the sentence, rejecting Power’s arguments regarding de facto life imprisonment and sentencing disparities. The Seventh Circuit affirmed the judgment of the district court. View "USA v Power" on Justia Law

Steven Bradford was initially convicted in federal court for his involvement in a heroin-trafficking conspiracy that resulted in a teenager’s death. After serving a lengthy prison sentence, he began a five-year term of supervised release. Within a year and a half, Bradford was arrested twice: first for possessing a firearm as a felon and having an open alcohol container, and later for drag racing while intoxicated, which led to a fatal multi-vehicle crash. These incidents constituted serious violations of the terms of his supervised release, including prohibitions against criminal activity, firearm possession, alcohol use, and frequenting bars.Following these events, Bradford’s federal probation officer sought revocation of his supervised release in the United States District Court for the Northern District of Illinois. The court initially paused revocation proceedings to allow state charges to proceed but later held a hearing after the second arrest. Bradford admitted to some violations, and the district judge found that he committed others based on testimony and evidence. The probation officer recommended a reimprisonment term at the upper end of the advisory Sentencing Guidelines range (14 months), while the government sought the statutory maximum (36 months). The judge imposed the maximum, emphasizing the severity of Bradford’s violations and his criminal history.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed Bradford’s challenge to the length of his reimprisonment. The court held that district judges have broad discretion in supervised release revocation proceedings and are not bound by the Guidelines or probation officer recommendations. The Seventh Circuit found that the district judge adequately explained the sentence and properly weighed permissible factors, including the seriousness of the violations. The court concluded that the 36-month sentence was not plainly unreasonable and affirmed the judgment. View "United States v. Bradford" on Justia Law

Federal law enforcement began investigating a Chicago address linked to the defendant after intercepting suspicious parcels sent from Arizona, one of which contained fentanyl. Agents arranged a controlled delivery of lookalike pills to the address, obtained an anticipatory search warrant, and described the property as a single-family home, when it was actually a two-unit building. The description error arose because all the agents’ pre-search checks—postal records, databases, resident information, and visual inspection—suggested the property was a single-family residence. During the delivery, agents noticed two doorbells but did not immediately conclude the building contained multiple units.After the parcel was opened inside the property, officers entered the building, swept the first-floor unit, and quickly encountered the defendant in a common stairwell with purple-stained hands, evidence he had handled the booby-trapped parcel. The defendant fled into the second-floor unit, where agents found further incriminating evidence. The United States District Court for the Northern District of Illinois denied the defendant’s motion to suppress the evidence, finding the warrant valid and the execution reasonable, even if the initial investigation was not exhaustive.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s ruling. The appellate court held that the warrant, though technically overbroad, was valid because the agent neither knew nor should have known the building had multiple units based on information available at the time. The court further found the warrant was executed reasonably, as agents, upon realizing there were multiple units, limited their search to the correct premises. Finally, the court determined that, even if the warrant had been invalid, the exigent circumstances and plain view exceptions to the warrant requirement justified the search and seizure. The judgment was affirmed. View "USA v Suggs" on Justia Law

An Indiana prisoner, while serving a 65-year sentence for murder, attacked a correctional officer at the Miami Correctional Facility in 2022. The attack caused serious injuries requiring outside medical treatment. Following an administrative hearing, the prisoner was found guilty of battering staff and was sanctioned by losing nearly 19 years of accumulated good time credits. The hearing officer based the sanction on the severity of the attack and the resulting injury and checked factors including the seriousness of the offense and the disruption to facility security.The prisoner filed a pro se habeas petition under 28 U.S.C. § 2254 in the United States District Court for the Southern District of Indiana, raising due process and Eighth Amendment claims. He alleged procedural errors, hearing officer bias, and that there was no evidence of serious injury. He also argued that the sanction was grossly disproportionate. After counsel was appointed, he submitted a brief that referenced, but did not fully restate, these claims. The district court denied relief, holding that the due process claims lacked merit and that the Eighth Amendment claim was waived due to insufficient argument in the brief.On appeal, the United States Court of Appeals for the Seventh Circuit held that the relevant constitutional claims were not waived, as the amended filing preserved the original petition’s arguments. The Seventh Circuit affirmed the district court’s judgment, holding that the hearing officer’s finding of serious bodily injury was supported by sufficient evidence under the “some evidence” standard. The court also concluded that the loss of good time credits was not grossly disproportionate in violation of the Eighth Amendment, given the circumstances of the offense, the petitioner’s disciplinary record, and the nature of his underlying conviction. The district court’s judgment was affirmed. View "Hawkins v. Sevier" on Justia Law