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

Two healthcare workers, Megan Passarella and Sandra Dottenwhy, employed by Aspirus Health in Wisconsin, sought religious exemptions from the company's COVID-19 vaccination mandate. Passarella cited her Christian belief that her body is a temple of the Holy Spirit and expressed concerns about the vaccine's safety. Dottenwhy also referenced her Christian faith, stating that her body is a temple and expressing distrust in the vaccine's development and long-term effects. Both were denied exemptions and subsequently terminated.The United States District Court for the Western District of Wisconsin dismissed their Title VII claims, ruling that their objections were based on medical judgment rather than religious conviction. The court found that the plaintiffs did not articulate any religious belief that would prevent them from taking the vaccine if they believed it was safe.The United States Court of Appeals for the Seventh Circuit reversed the district court's decision. The appellate court held that an employee's request for accommodation is based on religion if it is plausibly connected to their religious beliefs or practices, even if it also includes non-religious reasons. The court emphasized that Title VII's definition of religion is broad and includes all aspects of religious observance and practice. The court found that both Passarella's and Dottenwhy's exemption requests were at least partially based on their religious beliefs, making them sufficient to survive a motion to dismiss. The case was remanded for further proceedings to determine the sincerity of the plaintiffs' beliefs and whether Aspirus could reasonably accommodate them without undue hardship. View "Dottenwhy v. Aspirus, Inc." on Justia Law

RCBA Nutraceuticals, LLC, a Florida-based nutritional supplements company, contracted with Western Packaging, Inc. for the manufacture of plastic zipper pouches to hold its protein powder. These pouches were produced by PolyFirst Packaging, Inc. in Wisconsin, which was later acquired by ProAmpac Holdings, Inc. The pouches were shipped to companies in New York and Texas for filling. RCBA discovered that the pouches were defective, with seams splitting and spilling the protein powder, leading to a lawsuit against ProAmpac in federal court in Wisconsin. RCBA's claims included breach of contract, breach of implied warranties, negligence, civil conspiracy, and fraudulent misrepresentation.The United States District Court for the Eastern District of Wisconsin dismissed RCBA’s complaint. The court found that the claims were "foreign" under Wisconsin’s borrowing statute, WIS. STAT. § 893.07, and applied the statutes of limitations from New York and Texas for the contract claims, and Florida for the negligence claim. The court concluded that the contract claims were time-barred under the four-year statutes of limitations of New York and Texas, and the negligence claim was time-barred under Florida’s statute of limitations. The remaining tort claims were precluded by the economic loss doctrine. RCBA’s motion to reconsider was denied, with the court ruling that RCBA had waived its equitable arguments by not raising them earlier.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The appellate court agreed that the final significant event for the contract claims occurred where the defective pouches were delivered, in New York and Texas, making the claims foreign and subject to those states' statutes of limitations. The court also upheld the district court’s decision to deny the motion to reconsider, noting that RCBA had waived its equitable arguments by not presenting them in response to the motion to dismiss. The court concluded that RCBA’s claims were either time-barred or precluded. View "RCBA Nutraceuticals, LLC v. ProAmpac Holdings, Inc." on Justia Law

Shannon Cotton violated the terms of his supervised release by using cocaine and losing contact with his probation officer. The district court revoked his supervised release and sentenced him to two years in prison, disagreeing with the government's assertion that the maximum revocation sentence should be five years. The dispute centered on the interpretation of 18 U.S.C. § 3583(e)(3) regarding the maximum period of imprisonment for such violations.Cotton was originally convicted in 2007 for distributing and possessing with intent to distribute cocaine, which carried a mandatory minimum of 10 years and a maximum of life imprisonment due to prior felony convictions. In 2018, under the First Step Act, his sentence was reduced from 262 months to 188 months. After completing his reduced sentence, Cotton began supervised release in 2020 but subsequently violated its terms, leading to the revocation and the current legal dispute over the maximum revocation sentence.The United States Court of Appeals for the Seventh Circuit reviewed the case and determined that the district court erred in its interpretation. The appellate court concluded that the maximum revocation sentence Cotton faced was five years, based on the original classification of his offense as a class A felony under 18 U.S.C. § 3583(e)(3). The court emphasized that the classification of the offense should be based on the original conviction and not on current law or subsequent legal changes. Consequently, the appellate court vacated Cotton's two-year revocation sentence and remanded the case for resentencing, allowing the district court to consider the 18 U.S.C. § 3553(a) factors and any intervening legal changes. View "United States v. Cotton" on Justia Law

Paula Emerson, a former Cook County Corrections Officer, was terminated in 2019 after being on disability leave since 2012 due to anxiety, depression, and PTSD. Emerson claimed her termination was in retaliation for filing a workers' compensation claim in 2014 and a Title VII lawsuit against Cook County and its employees, which she lost. She alleged that the same attorneys represented the County in both her workers' compensation proceedings and the Title VII case, and discussed her cases with those responsible for her termination.The United States District Court for the Northern District of Illinois dismissed Emerson's initial complaint for failure to state a claim, allowing her to amend it. Emerson's amended complaint was also dismissed with prejudice for failing to cure deficiencies. The court found that filing a workers' compensation claim was not a protected activity under the ADA and that Emerson did not adequately allege that her workers' compensation claim caused her termination. Emerson's request for limited discovery was denied due to lack of specific allegations.The United States Court of Appeals for the Seventh Circuit affirmed the district court's dismissal. The appellate court held that Emerson's complaint did not plausibly allege that her workers' compensation claim caused her termination, noting the five-year gap between the claim and her firing. The court also upheld the denial of Emerson's discovery request, deeming it speculative, and found no abuse of discretion in denying her Rule 59(e) motion for reconsideration, as she presented no new evidence or manifest error of law or fact. The judgment of the district court was affirmed. View "Emerson v. Dart" on Justia Law

Aurelio Cervantes pleaded guilty in 2016 to possession with intent to distribute and distribution of cocaine. The district court sentenced him to 168 months, the bottom of his calculated guidelines range. This calculation included a base offense level of 34, a four-level increase for his role as a leader in a criminal activity involving five or more participants, and a three-level decrease for acceptance of responsibility. Cervantes had no criminal history points, resulting in a guidelines range of 168-210 months. He did not appeal the judgment.In 2023, Cervantes sought to reduce his sentence under 18 U.S.C. § 3582(c)(2), citing a recent amendment to the Sentencing Guidelines (Amendment 821) that allows a two-level reduction for certain offenders with no criminal history. The district court denied the motion, determining that Cervantes did not qualify for the reduction because he had received an aggravating-role adjustment under § 3B1.1. The court relied on the Seventh Circuit's decision in United States v. Draheim, which interpreted similar language to require that each negative phrase in a conjunctive list be a separate requirement.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s interpretation of § 4C1.1 de novo. The court agreed with the district court, holding that Cervantes’s role adjustment under § 3B1.1 disqualified him from eligibility for the two-level reduction under § 4C1.1. The court found that the conjunctive "and" in § 4C1.1(a)(10) should be interpreted similarly to the language in Draheim, meaning that each condition listed is a separate requirement. The court also noted that a pending amendment to § 4C1.1 would clarify this interpretation. The Seventh Circuit affirmed the district court’s decision, concluding that any error in the alternative ground for denial was harmless. View "USA v. Cervantes" on Justia Law

F.C. Bloxom Company, a Seattle-based distributor of fresh produce, entered into an agreement with Seven Seas Fruit to deliver three loads of onions to Honduras. The onions required phytosanitary certificates from the U.S. Department of Agriculture to clear Honduran customs, but the parties did not explicitly discuss who would procure these certificates. Bloxom believed Seven Seas would handle it, based on past practices and vague assurances. However, the onions were shipped without the necessary certificates, leading to their rejection in Honduras and eventual spoilage upon return to the U.S.Seven Seas initiated administrative proceedings under the Perishable Agricultural Commodities Act (PACA) when Bloxom refused to pay for the onions. The Secretary of Agriculture ruled in favor of Seven Seas, finding no evidence that Seven Seas had agreed to procure the certificates. Bloxom appealed to the U.S. District Court for the Central District of Illinois, which granted summary judgment for Seven Seas. The court found that Bloxom had accepted the onions at the Port of Long Beach and did not revoke that acceptance, thus obligating Bloxom to pay for the onions.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that Bloxom had accepted the onions by shipping them to Honduras and did not revoke this acceptance even after learning the certificates were missing. The court also found no abuse of discretion in the district court's denial of Bloxom's request for additional discovery time, as further discovery would not have changed the outcome. The court concluded that Bloxom was liable for the payment under PACA. View "F.C. Bloxom Company v. Tom Lange Company International, Inc." on Justia Law

On March 17, 2022, Anycco Rivers and Ladonta Tucker carjacked a BMW in Bourbonnais, Illinois. Rivers pointed two guns at the car’s owner, while Tucker searched the owner and then drove the car away. During a high-speed chase, Rivers fired a gun into the air. The chase ended when the BMW crashed into a guardrail. Tucker and Rivers fled on foot but were eventually captured. Police found firearms and spent cartridges at the scene.The United States District Court for the Central District of Illinois indicted both Rivers and Tucker on charges of carjacking and firearms violations. At trial, both were found guilty. Tucker was sentenced to 100 months for carjacking and an additional 60 months for the firearms charge, plus 24 months for violating supervised release, totaling 184 months. Rivers received 87 months for carjacking and 120 months for the firearms charge. Rivers objected to a two-level enhancement for reckless endangerment during flight, which the district court applied.The United States Court of Appeals for the Seventh Circuit reviewed the case. Tucker challenged his conviction, arguing insufficient evidence that his firearm facilitated the carjacking. The court upheld his conviction, stating that the jury could reasonably conclude that carrying a firearm during a carjacking had the potential to facilitate the crime. Rivers challenged his sentence enhancement and requested resentencing due to recent amendments to the Sentencing Guidelines. The court affirmed the enhancement but vacated and remanded Rivers’s carjacking sentence for reconsideration in light of the new Guidelines amendments. View "USA v. Tucker" on Justia Law

Stanford Clacks, an African American truck driver, was employed by Kwik Trip, Inc. and experienced racial harassment from fellow employees. During his training, Clacks was harassed by two trainers, Tom Roerkohl and Brett Nechkash, who used racial epithets and made derogatory remarks. Clacks reported these incidents to his supervisor, Sean Clements, but did not initially specify the racial nature of the harassment. After completing his training, Clacks continued to face sporadic racial harassment, including receiving a racially charged note from Nechkash. Clacks went on voluntary pandemic leave in March 2020 and later reported the harassment to Kwik Trip’s Human Resources department, prompting an investigation that led to the termination of the offending employees. Kwik Trip offered Clacks his job back or a severance package, both of which he declined.The United States District Court for the Western District of Wisconsin granted summary judgment in favor of Kwik Trip on all claims. The court applied the sham-affidavit rule to exclude parts of an affidavit Clacks submitted in opposition to summary judgment, finding it contradicted his earlier deposition testimony. The court found that Clacks did not present sufficient evidence to support his claims of a hostile work environment and retaliation.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 the district court properly applied the sham-affidavit rule and that Clacks did not provide sufficient evidence to support his claims. Specifically, the court found that Kwik Trip took reasonable steps to address the harassment once it was reported and that Clacks did not suffer an adverse employment action as he was offered his job back. The court concluded that no reasonable jury could find Kwik Trip liable for a hostile work environment or retaliation. View "Clacks v. Kwik Trip, Incorporated" on Justia Law

A former immigration attorney was convicted of conspiring with clients, interpreters, and employees to defraud the U.S. by submitting fabricated asylum applications. The attorney would create false stories for clients, often including fabricated details of persecution, and submit these to the United States Citizenship and Immigration Services (USCIS). Interpreters assisted by coaching clients to memorize false information and providing fraudulent translations during asylum interviews. Nine former clients testified against the attorney, and the jury found him guilty of conspiracy to defraud the U.S.The attorney's conviction was affirmed on direct appeal. He then moved to vacate his sentence under 28 U.S.C. § 2255, claiming undisclosed benefits were provided to witnesses. The district court authorized broad discovery, held a weeklong hearing, and denied the motion. The court found that undisclosed pre-trial benefits were immaterial and that post-trial benefits did not violate the attorney's rights as they were not promised to witnesses and would not have affected the trial's outcome.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's decision, holding that the undisclosed pre-trial benefits were immaterial and that the post-trial assistance provided to witnesses did not constitute a Brady violation. The court found no evidence of pre-trial promises regarding immigration status and concluded that the undisclosed availability of an "insider" for post-trial assistance was not material to the trial's outcome. The attorney's § 2255 motion was denied. View "Dekelaita v. USA" on Justia Law

A sixteen-year-old, Donnell Wilson, was convicted of two murders, armed robbery, and criminal gang activity in Gary, Indiana. Wilson and his accomplice, Jonte Crawford, harassed and robbed a teenager before encountering and fatally shooting two brothers affiliated with a rival gang. Wilson was sentenced to 183 years in prison, which was later reduced to 181 years on appeal due to a vacated gang activity conviction.Wilson sought post-conviction relief, arguing ineffective assistance of counsel and that his sentence violated the Eighth Amendment under Miller v. Alabama, which prohibits mandatory life without parole for juveniles. The Indiana Supreme Court found his trial counsel effective but agreed his appellate counsel was ineffective for not challenging the sentence under Indiana Appellate Rule 7(B). The court then reduced Wilson’s sentence to 100 years, considering his youth as a mitigating factor.Wilson filed a federal habeas corpus petition, arguing his 100-year sentence was a de facto life sentence violating the Eighth Amendment. The United States District Court for the Northern District of Indiana found the petition timely but denied relief, stating no clearly established law extended Miller to de facto life sentences. The United States Court of Appeals for the Seventh Circuit affirmed, agreeing the petition was timely but holding that the Indiana Supreme Court’s decision was not contrary to or an unreasonable application of clearly established federal law. The Seventh Circuit concluded that Miller’s protections did not extend to Wilson’s 100-year sentence, thus affirming the denial of his habeas petition. View "Wilson v. Neal" on Justia Law