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

Articles Posted in Criminal Law
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In an appeal from the United States District Court for the Northern District of Indiana, the United States Court of Appeals for the Seventh Circuit reviewed a case concerning Adam Tyrale Williams Jr.'s ongoing effort to reduce his sentences for crack-cocaine offenses. Williams was convicted in 2001 of various drug-related offenses, and over the years, he sought sentence reductions based on retroactive amendments to the guidelines and, most recently, the First Step Act of 2018. The district court denied Williams's most recent application for sentence reduction, but the appellate court vacated the decision because the district court failed to calculate the amended statutory sentencing ranges applicable to Williams's convictions. Upon remand, Williams further emphasized changes to his record and conditions of confinement that occurred after the order was vacated. However, the district court again denied Williams's request shortly after receiving the updated motion. The appellate court found that the district court's reliance on its previous reasoning and failure to adequately explain its decision was an abuse of discretion. Thus, the appellate court vacated the judgment and remanded for further proceedings, indicating that a more complete explanation from the district court was necessary given the changes in law and facts relevant to the case. View "USA v. Williams" on Justia Law

Posted in: Criminal Law
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Adrian L. Johnson was pulled over by a Deputy Sheriff for driving with a suspended license. The officer's trained dog indicated the presence of a controlled substance in Johnson's car, leading to a search of the vehicle. The officer found drugs, drug paraphernalia, and two handguns. Johnson was subsequently charged with possession of drugs with intent to distribute and possession of a firearm in furtherance of a drug trafficking crime. He moved to suppress all evidence, arguing that the search of his car violated his Fourth Amendment rights. The district court denied the motion, and Johnson pled guilty, reserving his right to appeal the suppression ruling. The United States Court of Appeals for the Seventh Circuit agreed with the district court, holding that the officer did not unconstitutionally prolong the stop to conduct the dog sniff, and that the subsequent search of Johnson's car did not violate the Fourth Amendment. The officer had probable cause to search the car because the dog's alerts indicated the presence of contraband. Therefore, the judgment of the district court was affirmed. View "USA v. Johnson" on Justia Law

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In this case before the United States Court of Appeals for the Seventh Circuit, the defendant, Christopher Christophel, was convicted of knowingly attempting to persuade, induce, or entice a minor to engage in sexual activity. He was convicted based on his online communications with an undercover federal agent who was posing as a 15-year-old girl. Christophel appealed his conviction, arguing that the trial court erred in giving a jury instruction that, in his view, misstated the elements of the offense.The specific issue on appeal was whether the language of a particular jury instruction, which stated that the government did not need to prove that the defendant intended to have sex with the minor, only that he intended to entice the minor to have sex with him, accurately summarized the law. Christophel contended that this instruction described a wider range of behavior than that proscribed by the statute.The appellate court held that, when viewed in its entirety, the jury instruction did not misstate the law. Although the term "causing ... assent" might suggest unintentional conduct when read out of context, when read in the context of the entire instruction, it was best understood as a shorthand reference to the specific conduct described in the first paragraph of the instruction: knowingly taking a substantial step with the intent to commit the offense of enticement of a minor.Even if the jury instruction could have been clearer, the court found that Christophel was not prejudiced by any potential error. Given the overwhelming evidence of Christophel's intent, any potential error would have been harmless. The court affirmed the judgment. View "USA v. Christophel" on Justia Law

Posted in: Criminal Law
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In this federal case before the United States Court of Appeals for the Seventh Circuit, Thomas Moorer, who had been arrested and indicted on charges including murder and attempted murder, challenged the constitutionality of his pretrial detention, claiming that there was no probable cause for his arrest. Moorer was ultimately acquitted by a jury of all charges. The defendants in the case were officers of the Chicago Police Department.The case arose from a fatal shooting that took place in an apartment shared by multiple people. Multiple witnesses, including Edwin Ramos, whose brother Edward was killed in the shooting, identified Moorer as the perpetrator. Edwin informed the police that the man who entered the apartment was nicknamed “Boom.” Moorer was subsequently arrested and charged with first-degree murder and other crimes, and a grand jury returned a 135-count indictment against him.Moorer claimed that the witness identifications were unreliable and that police failed to properly investigate his alibi. He argued that the prosecutors would have concluded there was no probable cause if they had been properly informed of all the facts known to the officers.However, the Court of Appeals found that the officers did have probable cause to arrest and detain Moorer, based on seven independent witness identifications. The court noted that the question for pretrial detention is not whether the officers have proof beyond a reasonable doubt that the accused committed the crime, but whether a reasonable person would have a sound reason to believe the suspect committed a crime. The court concluded that Moorer had not identified any facts known to the defendants that would eliminate probable cause.Therefore, the court affirmed the decision of the district court, which had granted summary judgment in favor of the defendants. View "Moorer v. City of Chicago" on Justia Law

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In the case before the United States Court of Appeals for the Seventh Circuit, the defendant, Demetrius Harvey, pled guilty to knowingly possessing a firearm after having previously been convicted of a crime punishable by a term of imprisonment exceeding one year. The court had to decide whether a 4-level enhancement was proper under USSG § 2K2.1(b)(6) because Harvey transferred a firearm to a confidential source (CS) who he had reason to believe was a felon. Harvey initially challenged the enhancement, arguing that the purchaser's statement that he was a convicted felon was an insufficient basis for Harvey to conclude that the purchaser was, in fact, a convicted felon. On appeal, Harvey changed his argument, claiming he was not told that the CS was a felon until the transaction was complete.The court concluded that even under the less onerous standard, Harvey's claim could not succeed. The enhancement was proper if the evidence before the district court supported the determination that the transfer of the firearm by the defendant occurred "with knowledge, intent, or reason to believe that it would be used or possessed in connection with" the felon-in-possession offense. Therefore, the court affirmed the decision of the district court and upheld the 4-level enhancement. View "USA v. Harvey" on Justia Law

Posted in: Criminal Law
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In the case at hand, the plaintiff, Benjamin Adams, an inmate at Indiana’s Plainfield Correctional Facility, sued the current and former commissioners of the Indiana Department of Corrections and various other officials pursuant to 42 U.S.C. § 1983, alleging that they violated his First and Eighth Amendment rights, as well as his Fourteenth Amendment rights to due process and equal protection. Adams was sentenced to a prison term of 30 years for attempted murder and a consecutive term of four years for involuntary manslaughter. He was assigned to work in the prison kitchen, but that assignment was rescinded due to concerns that he might use the assignment to smuggle drugs into the prison. He was later charged with offense A-100 for engaging in criminal gang activity related to an assault in the prison. Disciplinary Hearing Officer J. Peltier found Adams guilty of that offense on March 16. He was ordered to spend one year in disciplinary segregation, 365 days of his earned good time credits were revoked, and he was demoted from credit-earning class 1 to class 3.The United States Court of Appeals for the Seventh Circuit affirmed the district court's grant of summary judgment in favor of the defendants. The appellate court concluded that Adams' claim of First Amendment retaliation lacked sufficient evidence to suggest that the defendants were motivated by a retaliatory intent to pursue the assault charge against him. The court also held that Adams was not deprived of his Fourteenth Amendment due process rights, as prison disciplinary hearings require only informal due process, which leaves substantial flexibility in the hands of prison administrators. Regarding the Equal Protection claim, the court found no evidence that Adams was treated differently based on his race. Lastly, the court concluded that the defendants could not be held liable for violating Adams' Eighth Amendment rights as there was no evidence that they had control over the conditions of restrictive housing where Adams was placed. View "Adams v. Reagle" on Justia Law

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The defendant, Joseph Wilcher, was convicted of attempted enticement of a minor and travel with intent to engage in illicit sexual activity after he drove across state lines to meet someone he believed was a fifteen-year-old girl, who was actually a federal agent. The United States District Court for the Central District of Illinois sentenced Wilcher to a custodial prison term and a term of supervised release. In explaining the sentence, the district court only discussed the seriousness of the offense and did not address any of Wilcher's arguments for mitigation.On appeal, the United States Court of Appeals for the Seventh Circuit found that the district court erred in its sentencing. The appellate court held that the district court had relied on the seriousness of the offense as the sole justification for the sentence, including the term of supervised release. However, the seriousness of the offense is not a factor that courts can consider when imposing a term of supervised release. The appellate court also found that the district court had failed to consider Wilcher's principal mitigation arguments. The appellate court concluded that the district court's failure to adequately explain the sentence precluded meaningful appellate review.The Court of Appeals for the Seventh Circuit vacated Wilcher's sentence and remanded the case for a full resentencing hearing. The court clarified that on remand, the district court could not consider the seriousness of the offense when imposing a term of supervised release and must consider Wilcher's principal mitigation arguments. View "USA v. Wilcher" on Justia Law

Posted in: Criminal Law
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In 2015, DeShawn Harold Jewell was convicted of robbery by use of force and bail jumping, following a robbery outside a Milwaukee tavern. A DNA match from a hat left at the scene and a photo identification by the victim led to his arrest, but Jewell argued that the photo array procedure did not adhere to best practices. During deliberations, the jury asked the trial court if the numbering system of the photo array matched that of a photo "six-pack" shown at trial. The trial court, without consulting the parties, answered "No." The jury subsequently returned a guilty verdict. Jewell challenged this ex parte communication, arguing that it violated his Sixth Amendment rights. The Wisconsin Court of Appeals affirmed the conviction, concluding that the trial court's error was harmless. Jewell sought habeas relief under the Antiterrorism and Effective Death Penalty Act, but the U.S. Court of Appeals for the Seventh Circuit affirmed the lower court's decision. The court reasoned that the Wisconsin Court of Appeals had not unreasonably applied Supreme Court precedent in its harmlessness analysis, and that the ex parte communication did not have a substantial and injurious effect on the jury’s verdict. View "Jewell v. Boughton" on Justia Law

Posted in: Criminal Law
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In this case, the United States Court of Appeals for the Seventh Circuit reviewed an appeal related to a Fourth Amendment issue involving a warrantless search of a vehicle. The defendant, Charles Hays, was stopped by the police while driving, and his passenger was found in possession of methamphetamine. The police officers then searched the vehicle's interior but found no drugs. However, under the hood of the car, inside the air filter, they discovered more methamphetamine.Hays was indicted and later moved to suppress the evidence obtained during the traffic stop, arguing that the officers did not have probable cause to search under the hood and in the air filter. The district court denied his motion, and Hays subsequently pleaded guilty to possession with the intent to distribute 50 grams or more of methamphetamine, preserving his right to appeal the denial of his motion to suppress.The Seventh Circuit affirmed the district court's decision, holding that under the automobile exception to the Fourth Amendment's warrant requirement, officers may conduct a warrantless search of a vehicle, including all parts of the vehicle where there is a fair probability contraband could be concealed, as long as there is probable cause to believe it contains contraband or evidence of illegal activity. The court found that given the totality of the circumstances, including the passenger's possession of methamphetamine, Hays's previous drug-related arrest, and the presence of a screwdriver in the car - a tool known to be used for hiding drugs in vehicles - officers had a fair probability to believe that methamphetamine could be concealed in the car, including under its hood. View "United States v. Hays" on Justia Law

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The case arose from a tipster's information that led to an investigation and subsequent search of David Hueston's apartment in Marion, Indiana. The search, which was conducted under a warrant, produced drugs, cash, a gun, and ammunition. Hueston was charged with various drug-related offenses. He sought to suppress the evidence, arguing that the detectives deliberately or recklessly made misleading omissions and misrepresentations to obtain the search warrant. The district court denied Hueston's motion after conducting a Franks hearing, and Hueston appealed.The United States Court of Appeals for the Seventh Circuit found that though the affidavit supporting the search warrant contained omissions and inaccuracies, it was not clear that the detectives acted with deliberate intent or recklessness to mislead the judge who issued the warrant. The court noted that the detectives' consultation with a prosecutor both before and after drafting the affidavit argued against a finding of intent to mislead. The court also found that the good-faith exception applied, meaning that the police officers acted in good faith reliance upon a facially valid warrant. As such, the court affirmed the district court's denial of Hueston's motion to suppress the evidence. View "United States v. Hueston" on Justia Law

Posted in: Criminal Law