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

The petitioner, who entered the United States without authorization in 2006, lived with his wife and three children, all of whom are U.S. citizens. He was the primary financial provider for the family, earning significantly more than his wife and providing health insurance for the household. The family faced removal proceedings after the petitioner was arrested for driving on a suspended license and leaving the scene of an accident. The petitioner argued that his removal would cause his children exceptional and extremely unusual hardship, citing their emotional distress and the family’s financial dependence on him.An immigration judge found that the petitioner met all statutory requirements for cancellation of removal except for the “exceptional and extremely unusual hardship” standard. The judge determined that, while the family would experience financial and emotional difficulties, these did not rise above what is typically expected in removal cases. The petitioner appealed to the Board of Immigration Appeals, which affirmed the immigration judge’s decision, assuming for the sake of argument that all three children were qualifying relatives.The United States Court of Appeals for the Seventh Circuit reviewed the case, holding that it had jurisdiction to consider legal questions related to the application of the hardship standard. The court applied a deferential standard of review, as suggested by recent Supreme Court precedent, and concluded that the immigration judge’s findings were supported by substantial evidence and were not clearly erroneous. The court held that the petitioner had not demonstrated that his removal would result in hardship substantially beyond what is ordinarily expected in such cases. Accordingly, the Seventh Circuit denied the petition for review. View "Santos Mendoza v. Bondi" on Justia Law

A registered nurse, who identified as a dark-skinned Salvadoran woman, was employed at an acute care hospital. After a night in which she took a prescribed opioid for shingles, she reported to work without notifying her supervisor of her medication use. On that day, two incidents occurred in which controlled opioids were improperly removed from the hospital’s secure medication dispensing system. Several coworkers observed that the nurse appeared disoriented, drowsy, and exhibited slurred speech. Following these observations and the missing medication, supervisors required her to undergo a fitness for duty exam and drug test, which was positive for opiates but later deemed explained by her prescription. The hospital conducted an internal investigation, reviewed security logs, and ultimately terminated her employment for suspected drug diversion, policy violations, and unsafe patient care.The United States District Court for the Northern District of Illinois, Eastern Division, granted summary judgment in favor of the hospital on all claims. The nurse had alleged discrimination and retaliation based on color and national origin under Title VII, disability discrimination and failure to accommodate under the ADA, interference and retaliation under the FMLA, and violations of the Illinois Human Rights Act. The district court found that no reasonable factfinder could conclude the hospital’s actions were unlawful.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court’s grant of summary judgment. The appellate court held that the nurse failed to establish a prima facie case of discrimination or retaliation under Title VII, as her conduct and observed behavior distinguished her from other employees. The court also found insufficient evidence to support her ADA, FMLA, and IHRA claims, concluding that the hospital’s actions were not shown to be motivated by unlawful animus or to have violated any statutory rights. The court affirmed the judgment in favor of the hospital on all claims. View "Lohmeier v Gottlieb Memorial Hospital" on Justia Law

Jorge Diaz was charged with conspiracy to possess and attempted possession of five kilograms or more of cocaine with intent to distribute, based on events in late 2016. The government’s case relied heavily on Maria Bonilla, a cooperating witness who had previously identified Diaz as a drug-trafficking associate and provided audio recordings of their meetings. At trial, however, Bonilla claimed to have no memory of her involvement, her cooperation, or her prior testimony. The government introduced her grand jury testimony as a prior inconsistent statement and played the audio recordings for the jury, with a DEA agent identifying Diaz’s voice on the tapes. Diaz was convicted by a jury on both counts.The United States District Court for the Northern District of Illinois, Eastern Division, overruled Diaz’s objections to the admission of Bonilla’s grand jury testimony and the audio recordings. Diaz argued that the admission of the grand jury testimony violated his rights under the Confrontation Clause, that the recordings lacked proper foundation, and, for the first time on appeal, that the voice identification was unduly suggestive in violation of due process. The district court found that the requirements for admitting prior inconsistent statements and authenticating the recordings were met, and that Diaz had the opportunity to cross-examine Bonilla.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s judgment. The court held that admitting Bonilla’s grand jury testimony did not violate the Confrontation Clause because Diaz had the opportunity for effective cross-examination. The court also held that the foundation for the audio recordings was sufficient under Federal Rule of Evidence 901, and that the voice identification was not unduly suggestive or unreliable under due process standards. The convictions were affirmed. View "United States v. Diaz" on Justia Law

In the early morning hours of August 25, 2012, two individuals robbed Stephin Williams and Breonna Clausell while they sat in a parked car in Chicago. One of the assailants, later identified as Michael Tucker, shot Williams as he tried to flee. The identity of the second assailant was disputed: police believed it was Kiontae Mack, while Mack claimed he was merely a bystander. Mack was detained near the scene, subjected to a show-up identification by Clausell (who was uncertain but did not rule him out), and later confessed to involvement in the robbery during police questioning. Mack was indicted and, after nearly five years in detention, was acquitted at trial.Following his acquittal, Mack filed a civil rights lawsuit in the United States District Court for the Northern District of Illinois, Eastern Division, against several Chicago police officers and the City of Chicago. He alleged violations of his constitutional rights, including unlawful pretrial detention, fabrication of evidence, coerced confession, and malicious prosecution. The district court granted summary judgment in favor of the defendants on all claims, finding that the officers had at least arguable probable cause for Mack’s detention, that his acquittal precluded a fabricated evidence claim, and that his confession was not used against him in any court proceeding.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court’s judgment. The court held that the officers were entitled to qualified immunity because they had arguable probable cause to detain Mack. It further held that Mack’s acquittal barred his Fourteenth Amendment fabricated evidence claim, and that his coerced confession claim failed because the confession was never used against him in a criminal case. The court also found no basis for malicious prosecution, as probable cause existed throughout the proceedings. View "Mack v. City of Chicago" on Justia Law

A man living with his partner and her two young children in Indiana was convicted of murdering the children and setting fire to their home. Prior to the incident, he exhibited suspicious behavior, including quitting his job, withdrawing his savings, and making threatening statements. On the night of the crime, he bound one child, gathered belongings, and fled the state. The children’s bodies were found after the house fire, and he was apprehended in Kentucky following a police chase. After being read his rights in the hospital, he gave a brief, largely uninformative statement to police.He was charged with two counts of murder and arson. At trial, the jury found him guilty and recommended the death penalty, which the judge imposed. During the trial, a juror brought a note and cookies from his wife, referencing the victims, but the court found this did not prejudice the jury after questioning them and dismissed the juror. The Indiana Supreme Court affirmed the convictions and sentence. The defendant then sought postconviction relief in Indiana state court, arguing ineffective assistance of counsel, but the trial court denied relief, and the Indiana Supreme Court affirmed, with some justices partially dissenting on the prejudice issue.The defendant filed a federal habeas petition in the United States District Court for the Southern District of Indiana, raising over 30 claims, including ineffective assistance of counsel, juror bias, and evidentiary issues. The district court denied most claims as procedurally defaulted and found the rest without merit, also denying requests for stays and additional funding. On appeal, the United States Court of Appeals for the Seventh Circuit held that most claims were procedurally defaulted, the district court did not abuse its discretion in denying stays or funding, and the Indiana Supreme Court’s decisions were neither unreasonable applications of federal law nor based on unreasonable factual determinations. The Seventh Circuit affirmed the district court’s denial of habeas relief and related motions. View "Weisheit v Neal" on Justia Law

Shawn Baldwin operated a fraudulent investment scheme over several years, soliciting more than $10 million from over a dozen victims. He convinced individuals—including friends, business contacts, and a European businessman named Luca Tenuta—to invest in what he claimed were legitimate ventures, such as a purported social media platform for traders called Currency Clicks. In reality, Baldwin used the funds for personal expenses and to repay earlier investors, characteristic of a Ponzi scheme. He consistently misrepresented his professional credentials, concealed regulatory actions against him, and fabricated business opportunities to further his scheme.The United States District Court for the Northern District of Illinois, Eastern Division, presided over Baldwin’s trial. A jury convicted him on seven counts of wire fraud, and the court sentenced him to 204 months in prison. During the proceedings, the court allowed the government to present Tenuta’s testimony via a recorded deposition from London, after finding Tenuta was unavailable to testify in person. Baldwin objected to the deposition and its admission, arguing violations of procedural rules and his constitutional rights. He also challenged the joinder of charges, the admission of evidence regarding uncharged victims, and several sentencing enhancements.The United States Court of Appeals for the Seventh Circuit reviewed Baldwin’s conviction and sentence. The court held that the district court did not abuse its discretion in permitting Tenuta’s deposition under Federal Rule of Criminal Procedure 15, nor did it violate Baldwin’s Confrontation Clause rights, as Baldwin had waived his right to be present. The appellate court also found no error in the joinder of offenses, the admission of evidence about uncharged victims, or the application of sentencing enhancements. Accordingly, the Seventh Circuit affirmed Baldwin’s conviction and sentence. View "USA v Baldwin" on Justia Law

Deon Pugh was charged with multiple offenses, including conspiracy to possess with intent to distribute and distribute controlled substances, distribution of controlled substances, and possession of a firearm as a felon. The government alleged that Pugh, along with several co-defendants, participated in a drug distribution conspiracy centered at the home of Jonathan Mason, who was recognized as a leader of the operation. Evidence at trial showed that Pugh regularly visited Mason’s home, brought drugs for preparation and sale, and directed other participants in the conspiracy.After Pugh waived his right to a jury trial, the United States District Court for the Northern District of Illinois, Eastern Division, conducted a bench trial and found him guilty on all counts. The court determined that Pugh conspired with at least six others and that it was reasonably foreseeable to him that the conspiracy involved more than 1,000 grams of heroin. The court denied Pugh’s motions for acquittal and a new trial. At sentencing, the court calculated a base offense level based on a drug quantity of approximately 2,236 grams of heroin, applied a four-level leadership enhancement, and designated Pugh as a career offender, resulting in an advisory guidelines range of 360 months to life. The court ultimately sentenced Pugh to 216 months’ imprisonment and five years of supervised release.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed Pugh’s challenges to his career offender designation, the drug quantity attributed to him, and the leadership enhancement. The court held that the career offender designation was proper under both the current and prior versions of the Sentencing Guidelines, found that Pugh had waived any challenge to the drug quantity calculation, and concluded that the leadership enhancement was supported by the evidence. The Seventh Circuit affirmed the district court’s judgment. View "USA v Pugh" on Justia Law

Stella Paterakos, a white woman, worked as an Assistant Community Living Specialist for the City of Chicago. In 2020, after Crystal Warren, a black woman, became her supervisor, Paterakos was disciplined three times, resulting in suspensions of one, three, and five days. The cited reasons for discipline included violations of office policies, work assignments, and issues related to her use of Family and Medical Leave Act (FMLA) leave. Paterakos admitted to much of the conduct underlying the suspensions but alleged she was singled out for harsh treatment due to her race. She also claimed that her third suspension interfered with or retaliated against her for taking FMLA leave. Additionally, she was temporarily assigned to a different office, which she argued was racially motivated.After her third suspension, Paterakos filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, alleging violations of Title VII of the Civil Rights Act, the Equal Protection Clause, the FMLA, and the Age Discrimination in Employment Act. The defendants moved for summary judgment. The district court granted summary judgment on all claims, finding no reasonable jury could conclude that the suspensions or the temporary assignment were motivated by race, age, or constituted unlawful FMLA interference or retaliation. Paterakos appealed, dropping her age discrimination claim but challenging the summary judgment on her Title VII, Equal Protection, and FMLA claims.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision de novo. The Seventh Circuit affirmed the district court’s judgment, holding that no reasonable jury could find that the suspensions or assignment were based on race rather than documented performance issues. For the FMLA claims, the court held that the defendants’ honest belief that Paterakos was abusing her FMLA leave defeated her interference and retaliation claims. View "Paterakos v City of Chicago" on Justia Law

Alex Kedas worked for the Illinois Department of Transportation (IDOT) for over thirty years, primarily as a senior resident engineer. In 2016, Kedas complained to management and legal counsel that a female colleague was receiving better job assignments due to gender favoritism. After his complaint, Kedas received a counseling memorandum, a negative performance evaluation, and was denied a merit-based bonus. In subsequent years, he was assigned less significant projects and faced additional disciplinary actions. Kedas believed these actions were retaliatory and ultimately resigned in 2021, claiming constructive discharge due to an intolerable work environment.Kedas filed a lawsuit in the United States District Court for the Central District of Illinois, alleging retaliation under Title VII of the Civil Rights Act of 1964. The district court granted partial summary judgment for IDOT, finding that only certain actions—specifically, the counseling memorandum, the negative performance review, the denial of a bonus, and the 2018 job assignments—could be considered materially adverse employment actions. However, the court then found no sufficient evidence of a causal link between Kedas’s protected activity and his 2018 job assignments or constructive discharge. The remaining claims proceeded to trial, where the jury found IDOT had retaliated by issuing the counseling memorandum but awarded no damages.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s summary judgment rulings de novo. The appellate court held that Kedas failed to present sufficient evidence to support claims of constructive discharge or a causal connection between his protected activity and the 2018 job assignments. The Seventh Circuit affirmed the district court’s judgment, concluding that no reasonable jury could find in Kedas’s favor on these issues. View "Kedas v Illinois Department of Transportation" on Justia Law

Two children, E.R. and G.S., have severe, complex medical conditions that require constant, skilled care. Their mothers, who are their primary caregivers and sole financial supporters, have been trained by medical professionals to provide the necessary care at home. For years, Indiana’s Medicaid program reimbursed these mothers for providing “attendant care services” under a waiver program designed to keep individuals out of institutions. In July 2024, the Indiana Family and Social Services Administration (FSSA) implemented a policy change that would make parents ineligible to be paid providers of attendant care for their children, threatening to force E.R. and G.S. into institutional care due to the lack of available in-home nurses.The Indiana Protection and Advocacy Services Commission, along with E.R. and G.S., sued to block the policy change and require FSSA to secure in-home nursing. The United States District Court for the Southern District of Indiana initially granted a preliminary injunction requiring FSSA to take steps to obtain in-home nurses and to pay the mothers for a different, lower-paid service. After further proceedings, the court modified its order, ultimately requiring FSSA to pay the mothers for attendant care at the previous rate until in-home nursing could be secured.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s October 1 injunction. The court held that the plaintiffs are likely to succeed on their claims under the Americans with Disabilities Act’s integration mandate, which requires states to provide services in the most integrated setting appropriate. The court found that prohibiting the mothers from providing paid attendant care placed the children at serious risk of institutionalization and that FSSA had not shown that allowing such care would fundamentally alter the Medicaid program or violate federal law. The case was remanded for further proceedings. View "Indiana Protection and Advocacy Services Comm'n v Indiana Family and Social Services Administration" on Justia Law