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

Mata fired shots, killing two men and injuring another. Chicago police arrested Mata that evening. The following day, after receiving his Miranda rights and saying that he understood them, Mata gave a videotaped statement: Mata explained that he heard Mares calling his name. He turned around and saw two men holding Mares while other men surrounded him. Mata took out his gun and fired. The men backed away, but one man reached for his pocket. Mata fired five more shots toward the group, then ran toward his car. The men were walking with their backs to him when he fired; he never saw any of them with a weapon. An officer read Mata his Miranda rights again on tape. Mata said he understood his rights and wanted to make the statement; the police had treated him “well and fairly,” and he gave the statement “freely and voluntarily” without threats or promises by the police.Defense counsel moved to suppress Mata’s statements, claiming that Mata was subjected to abuse by the police for two days before being given any Miranda warnings. No hearing was held on the motion. Convicted on two counts of first-degree murder and one count of aggravated battery with a firearm, Mata sought habeas relief, arguing counsel provided ineffective assistance by failing to pursue a hearing on the motion. The Seventh Circuit affirmed the denial of the petition. Mata procedurally defaulted his claim and did not show cause to excuse the default. View "Mata v. Baker" on Justia Law

Gilbert and his son Michael were charged with possession with intent to distribute methamphetamine. Gilbert pleaded guilty and sought “safety-valve relief” from the mandatory minimum 10-year sentence. While Gilbert was awaiting sentencing, Michael pleaded guilty and agreed to cooperate including by providing information about Gilbert’s criminal conduct. The plea agreement itself was not entered into the court’s docket. The government never disclosed the agreement to Gilbert or his lawyer. At Gilbert’s sentencing hearing, Michael testified against his father. The prosecutor elicited false testimony that Michael had pleaded “open”—without the benefit of a written plea agreement. The court subsequently located the written plea agreement and informed the parties. Gilbert’s lawyer did not move to recall Michael for further cross-examination nor did he probe Michael’s motivations for testifying. The court denied Gilbert’s request for safety-valve relief and sentenced Gilbert to 156 months.The Seventh Circuit “reluctantly” affirmed. To obtain relief for a “Brady” violation, a defendant must show that undisclosed information was “material either to guilt or to punishment.” While Gilbert was completely in the dark about evidence that would have been useful to impeach a witness who testified against him, that evidence would not have affected the outcome of his sentencing. The court described the prosecution’s conduct as “unsettling.” View "United States v. Bicknell" on Justia Law

Eight drug couriers, under indictment, identified Caraway as the supplier of the cocaine and leader of the operation. The government communicated to Caraway’s attorney that Caraway would soon be indicted. Caraway voluntarily traveled to Illinois for a proffer interview, then returned to Houston. In September 2017, the government learned that Caraway committed a violent robbery in Houston and notified Caraway’s attorney that he would be indicted and was required to surrender by December 15, 2017. Caraway never responded. In January 2018, the government charged Caraway with conspiracy to distribute cocaine.U.S. Marshals began searching for Caraway 11 months later. In July 2021, a Texas state trooper stopped Caraway for speeding. After initially supplying a fake name, Caraway provided his real name and was arrested. Caraway pleaded guilty. The PSR recommended sentencing enhancements for being the leader and organizer of the conspiracy and for obstruction of justice, based on evading arrest for approximately 42 months. Caraway argued that the fact that the government could not find him was not evidence that he was evading arrest. After overruling the enhancement objections, the court calculated Caraway’s sentence range as 292-365 months; without the obstruction enhancement, the range would have been 235-293 months. After discussing the 18 U.S.C. 3553 factors, the judge noted that she would have imposed the same 360-month sentence without the enhancements.The Seventh Circuit affirmed. The district court properly calculated the Guidelines range without the enhancement and tied the imposed sentence to the severity of the crime, Caraway’s role, relevant conduct, possible recidivism, and protecting the public. View "United States v. Caraway" on Justia Law

Hunter was housed in a general-population wing of “Unit H” at Redgranite Wisconsin state prison. Patterson, Hunter’s cellmate March-December 2017, was regarded as a “lifer” and a “violent individual.” On multiple occasions, Patterson told Hunter that he would beat him while he slept. Hunter communicated Patterson’s threats to Mueske, the Unit H supervisor with authority over housing assignments. Hunter told Officer Walker about Patterson’s threats. At Walker’s suggestion, Hunter filled out an Inmate Complaint form, dated August 9. Walker typically notifies his superiors and drafts an incident report when he learns of threats between inmates, but he did not do so. Wilcox decided to move Patterson out of Unit H on December 6, 2017, but not due to Hunter’s complaints.On the day of Patterson’s move, Hunter approached Patterson, purportedly to say goodbye. Hunter claims that Patterson flew into a rage, accusing Hunter of causing Patterson’s reassignment. Patterson testified that Hunter called him various derogatory terms, including the N-word. Patterson violently battered Hunter and stomped on his head, causing Hunter permanent injuries and triggering his PTSD from his time in the military. The altercation was captured on video. In Hunter’s suit under 42 U.S.C. 1983, the district court granted Mueske and Walker summary judgment. Hunter offered no facts from which a reasonable jury could find that Walker acted with deliberate indifference or that Mueske’s conduct caused his injury. View "Hunter v. Mueske" on Justia Law

A kitchen supervisor directed Balle, an Illinois state prisoner, to carry near-boiling water across a wet, damaged floor in a plastic five-gallon bucket. His foot caught in a hole, and he fell down. The water splashed on him and caused severe burns. Balle sued several prison officials, claiming they violated the Eighth Amendment by being deliberately indifferent to the dangerous kitchen conditions. The district court dismissed some of Balle’s claims at the pleading stage and granted summary judgment on the others.The Seventh Circuit affirmed in part. The record lacks sufficient evidence to create a genuine dispute as to the subjective knowledge of two defendants. Viewing the record in the light most favorable to Balle, a reasonable jury could conclude that the kitchen conditions represented an objectively serious danger to inmates, but gaps in the record prevent a jury from inferring that the two actually knew about the conditions that made the kitchen seriously dangerous–that inmates had to carry scalding water across the damaged floor. The court reversed in part, reinstating the claim against the kitchen supervisor, who required the inmates to carry the scalding water. The court affirmed the denial of a motion to recruit counsel. View "Balle v. Kennedy" on Justia Law

Hartleroad responded to an online post soliciting persons interested in participating in sexual conduct with minors. The author (McCarty, an FBI agent) claimed to be engaged in sexual relations with his 14-year-old stepdaughter. Hartleroad agreed to a Skype meeting, during which Hartleroad would view McCarty engaging in sexual conduct with the minor. McCarty suggested that Hartleroad direct the sexual conduct. Hartleroad sent McCarty a photograph of a child on which he had ejaculated, drafted a script of sexual conduct he expected, and sent it to McCarty. McCarty reminded Hartleroad that the fictitious minor was under age. Hartleroad responded, “It’s cool” and joined the Skype call. McCarty then claimed his wife had returned. McCarty later posted similar messages. Hartleroad reinitiated contact, admitting he knew she was a minor but “would still love to do Skype” and “direct.”Hartleroad was charged with attempting to sexually exploit a child, 18 U.S.C. 2251, for “attempting to employ, use, persuade, induce, entice, and coerce a minor to engage in sexually explicit conduct for the purpose of producing a visual depiction, or a live visual depiction.” The jury received a similar instruction but was told Hartleroad must have acted for the purpose of transmitting a live visual depiction of such conduct. The court of appeal affirmed Hartleroad’s conviction, rejecting challenges to the sufficiency of the evidence, that the jury instructions constructively amended the indictment, and that the indictment charged conduct not prohibited under section 2251(a). View "United States v. Hartleroad" on Justia Law

Marvin’s mother called the police to perform a wellness check; she thought Marvin, age 21, was suicidal. St. Joseph County Sheriff’s Deputies arrived at Marvin’s home and found his mother in the driveway with a bleeding lip. She stated that Marvin had hit her with a chair. The officers approached the house to speak with Marvin, who declined to exit the house. During the confrontation, the deputies saw Marvin’s father remove a box cutter from Marvin’s pocket. They pulled him from the doorway and wrestled him to the ground. While he resisted, they tased him twice and struck him several times. Marvin sued the deputies for unlawful entry and excessive force. Marvin admitted that he was uncooperative but claimed he was not threatening or violent and that he suffered a concussion and a broken toe.Marvin brought claims under 42 U.S.C. 1983 against the deputies for unlawful entry and excessive force, in violation of his Fourth Amendment rights. The Seventh Circuit affirmed the dismissal of the unlawful entry claims against Officer Corban, who had not helped pull Marvin from his house, and the excessive force claims against Officer Lawson-Rulli, who was not involved in tasing or hitting Marvin. Corban and Holcomb’s use of force was reasonable as a matter of law. The court also affirmed a defense verdict on Marvin’s unlawful entry claims against Holcomb and Lawson-Rulli. View "Marvin v. Holcomb" on Justia Law

Sorensen's friend Berg told Sorensen to drive a Suburu and follow him. Sorensen drove the Subaru but got lost and slept in the Subaru, waking up the next day. Sorensen then picked up Charles and subsequently noticed a handgun in the driver-side door. He and Charles both had felony records. He drove to a Goodwill parking lot, thinking that there was a drop box for disposing of illegal items without police involvement. He exited the car with the gun. In the meantime, police had received a report that the Subaru was stolen, containing a loaded revolver and ammunition. Officers discovered the Subaru and arrested Charles. Sorensen heard Charles talking to the officers, panicked, and hid the gun on a shelf in the Goodwill store. A Goodwill employee notified officers that a man (Sorensen) had been hiding in a maintenance closet and ran out of the store upon being discovered. Officers arrested Sorensen with the Subaru keys on his person. Sorensen showed them the location of the gun. Officers found the loaded firearm; there were many people, including children, in the store.Charged under 18 U.S.C. 922(g)(1), Sorenson sought to present an innocent possession defense. The Seventh Circuit affirmed his conviction, noting that circuit precedent does not recognize an innocent possession defense to section 922(g)(1) and that, even under a broad interpretation of that defense, Sorenson would not qualify. He did not take reasonable steps to turn over the firearm to law enforcement directly or through a third party. View "United States v. Sorensen" on Justia Law

Springfield Officer Weiss obtained a warrant to search Outland’s person and residence for heroin and drug paraphernalia. Another officer conducted a traffic stop and search, discovered drug paraphernalia, read Outland his Miranda rights, and began transporting him to a DEA facility. Outland collapsed; his face and coat were covered in a white substance (heroin). The officer drove Outland to the emergency room. He was unresponsive when triaged at 10:46 a.m. Hospital staff began administering medications. Around 11:30 a.m., Outland passed swallowing tests. Although he continued to appear drowsy and had apneic episodes, he was generally alert and oriented; his “mentation” was “improved significantly.” He was placed on a Narcan drip, awaiting an ICU bed. At regular intervals, staff described Outland as alert, awake, and oriented. Weiss arrived around 1:00 p.m. The officer assigned to Outland stated that Outland had asked to speak with Weiss. Outland stated his name and date of birth. Weiss read him his Miranda rights and confirmed that he understood his rights. Outland made several incriminating statements about trafficking in heroin.Outland was charged with distributing and conspiring to distribute 100 grams or more of heroin, 21 U.S.C. 841(a)(1), 841(b)(1)(B)–(C), 846. On remand, the district court rejected his arguments that he was so intoxicated as to render his statement involuntary and was unable to voluntarily and knowingly waive his Miranda rights because of the medications. The Seventh Circuit affirmed the denial of his motion to suppress. View "United States v. Outland" on Justia Law

An investigation of an Indianapolis drug trafficking organization led by Trice led to the indictments of Trice and many of his associates, including McClure and Payne. Officers intercepted a call between McClure and Trice during which they spoke in coded language suggestive of a drug deal. Officers later observed the two men meeting with Trice and pursued Payne in a high-speed chase during which he threw a sock containing 214.2 grams of methamphetamine out of his car window. Payne and McClure later discussed these events in detail on a recorded jail call.Both were convicted of purchasing 50 grams or more of methamphetamine from Trice for distribution, 21 U.S.C. 846, 841(a)(1), 841(b)(1)(A)(viii). The Seventh Circuit affirmed, rejecting "Batson" arguments that the government impermissibly struck a Black potential juror and that the government’s explanation, that the potential juror had a brother with a drug dealing conviction, was pretext because some white jurors who were not stricken also had relatives who had been involved with drugs. The court upheld the district court’s decision to permit Detective Hart to offer both expert and lay opinions at trial, rejecting an argument that the court failed to adequately instruct the jury as to his dual-role testimony. The evidence supporting their convictions was legally sufficient. View "United States v. McClure" on Justia Law