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

Larry Dennis pleaded guilty to possession with intent to distribute cocaine base and marijuana. The government presented photos of Dennis pointing a firearm at a man, describing the incident as an "armed robbery." Based on these photos and Dennis's post-arrest statements, the district court enhanced his sentence. Dennis contested the enhancement and argued that two of his supervised release conditions were inconsistent with the district court's pronouncements.The United States District Court for the Northern District of Illinois initially handled the case. Dennis was arrested after a search warrant at his home revealed drugs, drug paraphernalia, cash, and a loaded handgun. Despite being released, he continued similar activities, leading to a federal search warrant and further charges. Dennis pleaded guilty, and the plea agreement set a base offense level of 24. The district court applied a two-level enhancement for making a credible threat of violence based on the photos and Dennis's statements. The court imposed a 78-month sentence and included several discretionary conditions for supervised release.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's decision to enhance Dennis's sentence, finding that the government met its burden of proof with the photos and Dennis's statements. The court also found no procedural error in the district court's reliance on the government's characterization of the incident as an "armed robbery." However, the appellate court agreed with Dennis that the written judgment's discretionary conditions on supervised release conflicted with the district court's oral pronouncements. The court ordered the modification of the condition related to substance abuse treatment to reflect that Dennis only needed a mental health assessment at the probation officer's direction. The court affirmed the district court's judgment in all other respects. View "United States v. Dennis" on Justia Law

Jerry Peoples and three associates planned to rob a marijuana dealer, unaware that the police were monitoring their conversations via a wiretap. The police intervened and arrested the group before the robbery could take place. Peoples was subsequently charged with conspiring and attempting to interfere with commerce by robbing a drug dealer, in violation of the Hobbs Act.The United States District Court for the Northern District of Illinois, Eastern Division, presided over Peoples' trial. The jury found him guilty on both counts. Peoples then filed post-trial motions under Federal Rule of Criminal Procedure 29 for a judgment of acquittal and Rule 33 for a new trial, arguing that the government’s evidence was insufficient. The district court denied both motions, stating that the evidence against Peoples was overwhelming. Peoples was sentenced to concurrent terms of 110 months’ imprisonment.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court upheld the district court’s decision, finding that the evidence presented at trial, including wiretap recordings and testimony, was sufficient to support the jury’s verdict. The court noted that the wiretap revealed detailed plans for the robbery, and the actions taken by Peoples and his associates demonstrated a substantial step toward committing the crime. The court also found that the evidence satisfied the Hobbs Act’s interstate commerce element, as the robbery targeted drugs and drug proceeds. Consequently, the Seventh Circuit affirmed the district court’s denial of Peoples' motions and upheld the jury’s guilty verdicts. View "USA v. Peoples" on Justia Law

In January 2015, Sarah Schoper, a tenure-track assistant professor at Western Illinois University, suffered a traumatic brain injury resulting in high-functioning mild aphasia and other physical disabilities. Despite her condition, she returned to teaching in May 2015, with accommodations from the University. Schoper applied for tenure in 2017 but was denied based on her teaching evaluations, which had declined post-injury. She then filed a lawsuit alleging disability discrimination and failure to accommodate under the Americans with Disabilities Act.The United States District Court for the Central District of Illinois granted summary judgment in favor of the University. The court found that Schoper could not prove that her disability was the but-for cause of her negative tenure recommendation. Additionally, the court ruled that Schoper failed to show how her requested accommodation—additional time to meet tenure criteria—would enable her to perform the essential functions of her job.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that Schoper was not a qualified individual under the ADA because her teaching evaluations did not meet the University's tenure requirements. The court also found that her request for more time to achieve tenure was not a reasonable accommodation, as it essentially sought a second chance rather than a modification to enable her to perform her job. Furthermore, the court concluded that no reasonable jury could find that Schoper's disability was the but-for cause of the University's decision to deny her tenure, given the multiple layers of review and the lack of evidence showing discriminatory intent by the reviewers. View "Schoper v. Board of Trustees of Western Illinois University" on Justia Law

In 2005, Full Circle Villagebrook GP, LLC formed a partnership with Protech 2004-D, LLC and AMTAX Holdings 436, LLC to develop and operate an affordable housing project in Illinois. Full Circle, as the General Partner, held a minor ownership stake but had an option to buy out the Limited Partners after 15 years, based on the property's fair market value. The partnership agreement specified that the appraiser for this valuation must be selected from the approved lists of LaSalle Bank or Deutsche Bank Berkshire Mortgage (DBBM). When Full Circle attempted to exercise this option in 2020, it selected an appraiser from the approved lists of the successor banks to LaSalle and DBBM, as the original banks no longer existed.The United States District Court for the Northern District of Illinois granted summary judgment in favor of the Limited Partners and Alden Torch Financial, LLC. The court held that Full Circle did not comply with the partnership agreement's terms, as it did not select an appraiser from the lists of the named banks, nor did it seek the Investor Limited Partner's approval for an alternative appraiser. Consequently, the court denied Full Circle's claims for breach of contract and tortious interference.The United States Court of Appeals for the Seventh Circuit affirmed the district court's judgment. The appellate court agreed that the contract's language was unambiguous and required strict compliance with the specified method for selecting an appraiser. Since Full Circle did not adhere to these terms, it failed to validly exercise its option, and no binding contract was formed. Therefore, the Limited Partners were not in breach, and Full Circle's claims were properly dismissed. View "Full Circle Villagebrook GP, LLC v. Protech 2004-D, LLC" on Justia Law

In February 2020, a police officer in Wauwatosa, Wisconsin, shot and killed a Black teenager, Alvin Cole. Following the incident, community members organized protests against police violence and racism. Anticipating unrest after the district attorney decided not to charge the officer, the mayor imposed a curfew. Plaintiffs, affected by the curfew and police conduct, filed constitutional and state law claims against the City of Wauwatosa and individual defendants.The United States District Court for the Eastern District of Wisconsin dismissed most claims, allowing only First Amendment and Driver’s Privacy Protection Act (DPPA) claims to proceed. The court later granted summary judgment for the defendants on the First Amendment claims, leaving only the DPPA claims for trial. The jury ultimately ruled in favor of the defendants on the DPPA claims.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s rulings, holding that the curfew was a permissible time, place, and manner restriction under the First Amendment. The court found that the curfew was content-neutral, served a significant government interest in public safety, was narrowly tailored, and left open ample alternative channels for communication. The court also upheld the dismissal of the plaintiffs' § 1983 claims against individual defendants, agreeing that the claims were inadequately pleaded and that the district court did not abuse its discretion in denying further amendments. Lastly, the court found no abuse of discretion in the district court’s response to a jury question regarding the definition of “personal information” under the DPPA. The judgment of the district court was affirmed. View "Knowlton v. City of Wauwatosa" on Justia Law

In February 2018, Joseph Fuchs, a special agent with the U.S. Postal Service’s Office of the Inspector General, traveled to the Philippines to engage in sexual activity with a 14-year-old girl, referred to as MV-1. Homeland Security Investigations (HSI) was alerted by the Illinois Attorney General’s office in March 2019, following a tip from Facebook about Fuchs’s explicit messages to MV-1. HSI confirmed Fuchs’s trip and examined his Facebook messages, which revealed his belief that MV-1 was 14 or 15 years old and detailed their sexual encounters. A photograph and MV-1’s birth certificate confirmed her age.The United States District Court for the Southern District of Illinois tried the case without a jury. Fuchs contested the admissibility of MV-1’s birth certificate, arguing insufficient proof of its authenticity. The court admitted the birth certificate, along with other evidence, including Fuchs’s Facebook messages, a recorded interview, and financial records of payments to MV-1. The court found Fuchs guilty of using a facility of foreign commerce to coerce a minor, traveling with intent to engage in illicit sexual conduct, and engaging in illicit conduct in a foreign country. He was sentenced to 126 months in prison.The United States Court of Appeals for the Seventh Circuit reviewed the case. Fuchs challenged the admissibility of the birth certificate and the recorded interview, and argued insufficient evidence for his conviction. The court upheld the district court’s decision, finding the birth certificate properly admitted and the evidence sufficient to establish MV-1’s age and Fuchs’s guilt. The court affirmed Fuchs’s conviction. View "U.S. v. Fuchs" on Justia Law

Michael Davis was arrested after a 911 call from a 15-year-old girl in Gary, Indiana, reported that he had threatened to kill her mother and had an assault rifle in his car. Police located Davis following the family's minivan and arrested him. A search of his vehicle revealed a loaded, semi-automatic shotgun with an obliterated serial number. Davis was charged with illegal firearm possession under 18 U.S.C. § 922(g). He moved to suppress the shotgun, arguing the search violated the Fourth Amendment, but the district court denied his motion.The United States District Court for the Northern District of Indiana held a two-day evidentiary hearing and found that the warrantless search of Davis's vehicle was justified under both the search incident to arrest and automobile exceptions to the warrant requirement. Davis entered a conditional guilty plea, reserving his right to appeal the suppression ruling. He was sentenced to ninety-two months in prison and two years of supervised release.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's denial of Davis's motion to suppress, holding that the search of Davis's vehicle was lawful under both the search incident to arrest and automobile exceptions. The court found that the officers had probable cause to arrest Davis based on the credible 911 report and corroborating evidence. Additionally, the court determined that it was reasonable to believe Davis's vehicle contained evidence of the crime, thus justifying the search. The judgment of the district court was affirmed. View "United States v. Davis" on Justia Law

Santanu Das, a sales associate at Tata Consultancy Services, participated in a compensation incentive plan that promised a bonus exceeding $400,000 for achieving certain sales targets. Das met the target but was paid less than $100,000. He sued Tata under Illinois law, which requires employers to pay all agreed-upon compensation. Tata argued that disclaimers in the incentive plan negated any agreement to pay the bonus. The district court dismissed Das’s complaint, leading to this appeal.The United States District Court for the Northern District of Illinois initially dismissed Das’s claims without prejudice. Das amended his complaint, adding breach of contract and fraudulent misrepresentation claims. The district court dismissed the repleaded claims with prejudice but allowed Das to replead the new claims. Das chose to appeal only the Wage Act and fraudulent misrepresentation claims. The district court found that the disclaimers in the incentive plan prevented the formation of an agreement to pay wages and that Das’s fraudulent misrepresentation claim lacked the necessary particularity.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court found that Illinois law does not treat disclaimers as necessarily preventing the formation of mutual assent to terms. The court noted that past practices between Das and Tata could establish mutual assent. The court concluded that Das had plausibly alleged that Tata agreed to pay him the full bonus, reversing the district court’s dismissal of the Wage Act claim. However, the court affirmed the dismissal of the fraudulent misrepresentation claim, as Das failed to allege a scheme to defraud.The Seventh Circuit reversed the district court’s decision on the Wage Act claim and remanded the case for further proceedings. The dismissal of the fraudulent misrepresentation claim was affirmed. View "Das v. Tata Consultancy Services Limited" on Justia Law

Heide Montoya, a former Superintendent of On-Board Services at Amtrak, was discharged in 2020 and later rehired to a different position. Montoya filed a lawsuit alleging sex discrimination and other state-law claims. The litigation became complicated due to a dispute over arbitration. Amtrak argued that Montoya had agreed to arbitration by continuing to work after receiving an email notice. Montoya denied receiving the arbitration agreement, and the district judge could not resolve the issue due to a lack of definitive evidence.The United States District Court for the Northern District of Illinois, Eastern Division, held a status hearing where the judge indicated that the evidence was insufficient to determine if an arbitration agreement existed. The judge suggested that the parties confer and possibly provide a joint statement on how to proceed. Instead of following these steps, Amtrak filed a notice of appeal, relying on §16(a)(1) of the Federal Arbitration Act (FAA), which allows interlocutory appeals from orders bypassing arbitration.The United States Court of Appeals for the Seventh Circuit reviewed the case and found that §16 of the FAA only applies when the Act as a whole is applicable. Section 1 of the FAA excludes contracts of employment for railroad employees, among others, from its scope. Since Montoya was an Amtrak employee, the case falls outside the FAA. The court referenced similar cases and legal precedents, including Southwest Airlines Co. v. Saxon and Bissonnette v. LePage Bakeries Park St., LLC, to support its conclusion. Consequently, the Seventh Circuit dismissed Amtrak's appeal for lack of jurisdiction, noting that the district court still needs to resolve whether Montoya agreed to arbitrate disputes under state law. View "Montoya v. National Railroad Passenger Corp." on Justia Law

Three former satellite service technicians filed a class action lawsuit against their employer, DirectSat USA, LLC, alleging violations of the Illinois Minimum Wage Law (IMWL) and the Fair Labor Standards Act (FLSA). They claimed that DirectSat failed to compensate them for work-related tasks performed beyond forty hours per week. The district court initially certified a class of full-time Illinois DirectSat technicians but later vacated this certification and certified a Rule 23(c)(4) issue class to resolve fifteen questions related to DirectSat’s liability.The case was reassigned to another district judge in 2019. Before the trial, the district court decertified the Rule 23(c)(4) class. The plaintiffs settled their individual claims but reserved the right to appeal the decertification decision. The district court found that the class action was not a superior method for adjudicating the plaintiffs' controversy due to the variance in the amount of time technicians spent on work-related tasks and the individualized nature of their piece-rate compensation system.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that a party seeking certification of an issue class under Rule 23(c)(4) must show that common questions predominate in the resolution of the specific issues to be certified, not the entire cause of action. However, the court affirmed the district court’s decision to decertify the class, concluding that a class action was not a superior method for resolving the controversy due to the individualized nature of the claims and the necessity for numerous separate trials to determine liability and damages. View "Jacks v. DirectSat USA, LLC" on Justia Law