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

The case involves Michelle Gilbank, who lost custody of her daughter, T.E.H., in state court proceedings in Wisconsin. Gilbank alleged that various officials involved in those proceedings violated her federal constitutional rights. The events began when Gilbank, who had a history of drug use, moved into her ex-partner Ian Hoyle's apartment. Following an anonymous tip, police and social workers investigated and found evidence of Gilbank's drug use. On August 21, 2018, Gilbank was arrested for drug possession, and her daughter was temporarily placed with Hoyle. Subsequent state court hearings resulted in the continued placement of T.E.H. with Hoyle until Gilbank regained custody in March 2020.In the United States District Court for the Western District of Wisconsin, the court granted summary judgment for the defendants. The court found that some of Gilbank’s claims were barred by the Rooker-Feldman doctrine, which prevents federal courts from reviewing state court judgments. The court also ruled that the remaining claims failed on the merits, including claims of unreasonable search, denial of due process, and unlawful eviction.The United States Court of Appeals for the Seventh Circuit reviewed the case en banc. The court affirmed the district court's judgment, agreeing that the Rooker-Feldman doctrine barred claims based on injuries caused by state court judgments. The court also affirmed summary judgment on the merits for claims not barred by Rooker-Feldman, including those related to the urinalysis, interrogation without an attorney, and the removal of T.E.H. The court found that Gilbank had consented to the urinalysis, that her Fifth Amendment rights were not violated as her statements were not used in a criminal proceeding, and that there was no seizure of T.E.H. by government actors. The court also rejected the existence of a "fraud exception" to the Rooker-Feldman doctrine. View "Gilbank v. Wood County Department of Human Services" on Justia Law

Christopher Truett operated a methamphetamine distribution network while incarcerated in the Marion County Jail. He coordinated drug purchases and sales through phone calls, directing his girlfriend to handle the transactions and collect proceeds. Truett and his co-conspirators faced various drug and firearm charges, but he was specifically charged with conspiracy to possess with intent to distribute methamphetamine. He pleaded guilty and disclosed his mental, cognitive, and memory impairments during the change-of-plea hearing.The United States District Court for the Southern District of Indiana did not hold a competency hearing despite Truett's impairments and behavior during the plea hearing. His counsel assured the court of his competence, and Truett actively participated in the proceedings. At sentencing, additional evidence of his impairments was presented, but the court again did not order a competency hearing. The court adopted the Presentence Investigation Report's findings, attributing the entire drug quantity to Truett and sentencing him to 240 months of imprisonment, five years of supervised release, and a $250 fine. The written judgment included a condition for fine payment not orally pronounced at sentencing.The United States Court of Appeals for the Seventh Circuit reviewed the case. It held that the district court did not abuse its discretion by not holding a competency hearing, as Truett's behavior and counsel's assurances indicated his understanding of the proceedings. The court also found no error in attributing the entire drug quantity to Truett, as he was personally involved in all transactions. Finally, the appellate court affirmed the inclusion of the fine payment condition in the written judgment, deeming it a mandatory condition of supervised release. The court affirmed the district court's decisions. View "USA v. Truett" on Justia Law

Paul Osterman was prosecuted for sex trafficking a child after a detective in Oneida County, Wisconsin, obtained a warrant to place a GPS tracker on his truck. The warrant was based on an affidavit that included incorrect information. Osterman argued that these inaccuracies meant the affidavit did not establish probable cause, and he sought to suppress the evidence obtained from the GPS tracking.The United States District Court for the Eastern District of Wisconsin held an evidentiary hearing and found that the affidavit did establish probable cause despite the inaccuracies. The court denied Osterman’s motion to suppress, leading to his appeal.The United States Court of Appeals for the Seventh Circuit reviewed the case and agreed that the detective acted recklessly by not correcting the affidavit. However, the court independently reviewed the affidavit and concluded that it still established probable cause even without the misstatements. Therefore, the court affirmed the district court’s decision to deny the motion to suppress. The main holding was that the inaccuracies in the affidavit were immaterial to the probable cause determination, and thus, the evidence obtained from the GPS tracking was admissible. View "USA v. Osterman" on Justia Law

In September 2020, Michael Karmo informed a friend that he was traveling to Kenosha, Wisconsin, with firearms during a period of civil unrest. The friend reported this to local police, who then notified the FBI. The FBI, believing Karmo intended to shoot people and loot, requested real-time cell site location information (CSLI) from AT&T under exigent circumstances. Law enforcement located Karmo in a hotel parking lot, where he consented to searches of his vehicle and hotel room, revealing multiple firearms. Later, it was clarified that Karmo did not explicitly state he intended to shoot people and loot.The United States District Court for the Eastern District of Wisconsin reviewed the case. Karmo moved to suppress the evidence obtained from the CSLI collection, arguing that the exigent circumstances form contained false information. He also requested a Franks hearing to challenge the veracity of the form. The district court denied his motion, and Karmo subsequently pleaded guilty while reserving his right to appeal the suppression issue.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court assumed, without deciding, that the CSLI collection constituted a Fourth Amendment search. It held that law enforcement reasonably believed probable cause and exigent circumstances existed, justifying the warrantless search. The court found that even without the misrepresentation in the exigency form, the totality of circumstances supported a reasonable belief of a public safety threat. The court also determined that a Franks hearing was inapplicable because no judge had made a probable cause determination based on the form. The Seventh Circuit affirmed the district court's decision. View "United States v. Karmo" on Justia Law

Thompson Corrugated Systems, Inc. (TCS) entered into an oral agreement in 2004 to act as the North American sales representative for Engico, S.r.l., an Italian manufacturer of corrugated box machinery. TCS was to receive an 8% commission on sales, later modified to a sliding scale in 2012. Despite low sales, TCS procured two significant sales for Engico in 2005 and 2017. In 2016, Engico attempted to terminate the agreement due to low sales, but TCS resisted, citing market conditions. The parties renegotiated in 2018, agreeing that TCS would remain the representative until 2021 and continue to receive commissions. However, disputes arose over commissions for sales made in 2019 and 2020, leading TCS to sue Engico for breach of contract and other state law claims.The United States District Court for the Southern District of Illinois granted partial summary judgment in favor of TCS, finding the 2004 oral agreement valid and enforceable. The court determined that the essential terms of the agreement, including the commission structure, territory, and services, were sufficiently definite. The court also found that the agreement was terminable at will under Illinois law. The remaining claims were left to the jury, which found Engico liable for breach of contract and awarded TCS damages.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s grant of partial summary judgment de novo. The appellate court affirmed the district court’s decision, agreeing that the 2004 oral agreement contained sufficiently definite terms and that the Statute of Frauds did not bar enforcement of the 2018 agreement. The court concluded that the essential terms of the agreement were clear and that the deposition testimony satisfied the Statute of Frauds’ writing requirement. Thus, the judgment of the district court was affirmed. View "Thompson Corrugated Systems, Inc. v. Engico S.r.l." on Justia Law

Darkel Martin, after serving a custodial sentence for possessing a firearm as a felon, began a three-year term of supervised release. The government petitioned to revoke his supervised release, alleging multiple violations, including committing another crime, possessing a controlled substance, and failing to participate in treatment programs. Martin admitted to several violations, and the district court revoked his supervised release, sentencing him to twenty months of imprisonment and one year of supervised release.The United States District Court for the Southern District of Illinois handled the initial proceedings. The court found Martin had committed several violations of his supervised release conditions. The U.S. Probation Office recommended an advisory Guidelines range of eighteen to twenty-four months of imprisonment. The district court sentenced Martin within this range, imposing twenty months of imprisonment and one year of supervised release.The United States Court of Appeals for the Seventh Circuit reviewed the case. Martin argued that the district court erred by not calculating his Guidelines range and improperly relying on certain facts in violation of 18 U.S.C. § 3583(e). The appellate court found that the district court had considered the Guidelines range and the relevant statutory factors. The court noted that the district court referenced the Guidelines and the Probation Office’s recommendations during the hearing. Additionally, the appellate court determined that the district court primarily relied on permissible factors under § 3583(e) when sentencing Martin, rather than the factors listed in § 3553(a)(2)(A). Consequently, the Seventh Circuit affirmed the district court’s judgment. View "USA v. Martin" on Justia Law

Jessica Gehner was implanted with a Cook Medical inferior vena cava (IVC) filter in Ohio. She later experienced abdominal pain, and a CT scan in March 2013 revealed that the filter had perforated her IVC. Her doctors recommended the filter's removal, which occurred in April 2013, but a fragment was left behind due to the filter fracturing. Gehner filed a lawsuit in May 2016 against Cook Incorporated, Cook Medical LLC, and William Cook Europe APS, alleging products liability and implied warranty claims. The defendants argued that her claims were time-barred under Ohio’s two-year statute of limitations.The United States District Court for the Southern District of Indiana granted the defendants' motion for judgment on the pleadings, which was converted to a summary judgment motion. The court concluded that Gehner's claims were time-barred, as she was informed by her doctors in March 2013 that the IVC filter caused her injury, starting the statute of limitations clock. Gehner contended that she was unaware of the defect until 2016 when her mother saw a television commercial about defective IVC filters.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court held that under Ohio law, the statute of limitations for product liability claims begins when the plaintiff is informed by competent medical authority of an injury related to the product or when the plaintiff should have known of the injury through reasonable diligence. The court found that Gehner was aware of her injury and its relation to the IVC filter by April 2013 at the latest. The court rejected Gehner's argument that the statute of limitations should start when she learned of the defect, noting that awareness of the injury itself was sufficient to start the clock. The court affirmed the district court's summary judgment in favor of the defendants, concluding that Gehner's claims were indeed time-barred. View "Gehner v. Cook Medical, LLC" on Justia Law

Robert Decker, a federal inmate, requested electronic access to the full, daily editions of the Federal Register from his prison law library. The Bureau of Prisons (BOP) denied his request, prompting Decker to file a pro se lawsuit under the Administrative Procedure Act. He claimed that the denial violated his First Amendment rights to receive information and petition the government. The BOP argued that its policy was justified by the need to conserve limited resources.The United States District Court for the Southern District of Illinois granted summary judgment in favor of the BOP. The court applied the framework from Turner v. Safley, concluding that the BOP’s policy was reasonably related to its legitimate penological interest in conserving resources. The district court also denied Decker’s motions for the recruitment of counsel, finding that he was competent to litigate his case despite the challenges of incarceration.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s decision, agreeing that the BOP’s policy was reasonably related to its legitimate interest in conserving resources. The court noted that the BOP provided access to documents pertaining to the Bureau and the U.S. Parole Commission and allowed inmates to receive print copies of the Federal Register through the mail. The court found that Decker had alternative means to exercise his First Amendment rights, although they were less convenient. The court also upheld the district court’s denial of Decker’s motions for the recruitment of counsel, concluding that the district court did not abuse its discretion.In summary, the Seventh Circuit held that the BOP’s policy of providing limited electronic access to the Federal Register was constitutionally valid under Turner v. Safley and that the district court did not err in denying Decker’s request for appointed counsel. View "Decker v. Sireveld" on Justia Law

Jason Beckner, employed by Commercial Air, Inc., was injured while working on a construction site in Zionsville, Indiana. Commercial Air had rented a crane and operator from Maxim Crane Works, L.P. for a day to lift roof trusses. Beckner claimed that the crane operator, Emmitt Pugh, caused his injury through negligent operation. Beckner and his wife sued Maxim Crane for negligence, asserting vicarious liability.The case was initially filed in Indiana state court but was removed to the United States District Court for the Southern District of Indiana based on diversity jurisdiction. Maxim Crane moved to dismiss the case, arguing that Indiana’s Worker’s Compensation Act barred the suit because Pugh was a co-employee of Beckner. The district court denied the motion to dismiss but later granted summary judgment in favor of Maxim Crane, ruling that Pugh was also employed by Commercial Air, making the Worker’s Compensation Act Beckner’s exclusive remedy.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that genuine issues of material fact existed regarding whether Pugh was an employee of Commercial Air. The court noted conflicting evidence about who controlled Pugh’s work and whether Commercial Air believed it employed Pugh. The court applied both the seven-factor test from Hale v. Kemp and the ten-factor test from Moberly v. Day, concluding that factual disputes precluded summary judgment.The Seventh Circuit vacated the district court’s judgment and remanded the case for further proceedings to resolve these factual issues. View "Beckner v. Maxim Crane Works, L.P." on Justia Law

Courtney Ealy, an inmate in the Illinois prison system, spent five consecutive months in segregation starting in 2019. During this period, he experienced cold temperatures, dirty cells, and faulty plumbing, which he claimed negatively affected his mental and physical health. Ealy sued several prison officials, alleging violations of his Fourteenth Amendment right to due process. He also filed multiple motions for recruitment of counsel during the litigation.The United States District Court for the Central District of Illinois granted summary judgment in favor of the defendants, Cameron Watson, David D. Frank, and Angela McKittrick, and denied Ealy's motions for recruitment of counsel. The court found that Ealy had received due process before being placed in disciplinary segregation and that the conditions of his confinement did not constitute an atypical and significant hardship. The court also determined that Ealy was competent to represent himself despite his claims to the contrary.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 Ealy received all the due process he was entitled to, including advance written notice of the charges, an opportunity to be heard, and a written statement of the evidence and reasons for the disciplinary action. The court also found that the district court did not abuse its discretion in denying Ealy's motions for recruitment of counsel, noting that Ealy's case was not complex and that he appeared competent to represent himself based on his filings. View "Ealy v. Watson" on Justia Law