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

The case involves a property owned by Indiana Land Trust #3082, located in Hammond, Indiana, which houses a lucrative fireworks and tobacco business operated by Omar and Haitham Abuzir. The City of Hammond seeks to use its eminent domain power to take this property to build a road connecting Indianapolis Boulevard and the Water Gardens neighborhood. The Abuzirs allege that the City’s actions are part of a conspiracy involving political motives and favoritism towards competitors who support the mayor.The Hammond Redevelopment Commission initially offered to purchase the property in 2018, but the Abuzirs declined. Consequently, the Commission initiated a condemnation action in Indiana state court under the state’s eminent domain statute. The Abuzirs objected, arguing that the taking was for a private purpose and motivated by ill will. Unable to assert counterclaims in state court, they filed a federal lawsuit alleging constitutional and federal law violations, including claims under the Fourteenth Amendment and 42 U.S.C. § 1983.The United States District Court for the Northern District of Indiana dismissed the Abuzirs' third amended complaint with prejudice, finding that the City had a legitimate government interest in building a road and that the Abuzirs failed to state a claim for equal protection, substantive due process, or civil conspiracy. The court noted that the Abuzirs' complaint itself provided a rational basis for the City’s actions.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The appellate court held that the Abuzirs failed to state a class-of-one equal protection claim because the City’s actions had a rational basis. The court also found that the proposed substantive due process claim was futile as the Abuzirs did not allege a deprivation of a protected interest. Lastly, the court upheld the denial of leave to add a § 1983 conspiracy claim, as the Abuzirs failed to establish any underlying constitutional violation. View "Indiana Land Trust #3082 v. Hammond Redevelopment Commission" on Justia Law

Charles Vavra, an employee of Honeywell International, Inc., was required to complete an online unconscious bias training. Vavra refused to participate in the training and was subsequently terminated. He then filed a lawsuit claiming that his termination was in retaliation for his opposition to the training and for his complaints about an email from the head of his business unit, which he found offensive.The United States District Court for the Northern District of Illinois granted summary judgment in favor of Honeywell. The court found that Vavra's retaliation claims were without merit, leading to his appeal to the United States Court of Appeals for the Seventh Circuit.The Seventh Circuit reviewed the district court’s decision de novo. The court held that Vavra’s opposition to the training did not constitute protected activity under Title VII or the Illinois Human Rights Act because he did not have an objectively reasonable belief that the training violated the law. Vavra had not accessed the training or known its contents, making his belief speculative. Additionally, even if his complaints about the email were considered protected activity, Vavra failed to establish a causal connection between his complaints and his termination. The court noted that Honeywell had consistently sought Vavra’s compliance with the training requirement and only terminated him after his final refusal. The Seventh Circuit affirmed the district court’s grant of summary judgment in favor of Honeywell. View "Vavra v. Honeywell International, Inc." on Justia Law

Consolidated Grain and Barge Company (Consolidated) entered into multiple agreements with the Indiana Port Commission (Commission) to build new rail tracks at the Southwind Maritime Centre. In exchange, Consolidated received the right to perform rail switching services for other tenants, allowing it to recoup its investment through service fees. However, in 2021, the Commission hired a new rail service provider, Squaw Creek Southern Railroad, to maintain the tracks and perform rail services, prompting Consolidated to sue, alleging breach of contract.The United States District Court for the Southern District of Indiana dismissed the case, finding that the plain meaning of the agreements did not support Consolidated's claims. The court determined that the agreements did not grant Consolidated perpetual rights to perform its own switching services at no cost, especially after the Commission exercised its right to hire a new rail service provider.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 2008 New Storage Tracks Agreement unambiguously revoked Consolidated's lease rights over the storage tracks, and any right to perform switching services was tied to the now-expired 2006 Track Use Agreement. The court also found that the Commission had followed the proper procedure in hiring a new rail service provider, as stipulated in the agreements. Consequently, Consolidated's rights to perform its own switching services were extinguished in 2021, and the contracts were not ambiguous as a matter of law. The court also rejected Consolidated's promissory estoppel claim, as it was based on the interpretation of the existing contracts. View "Consolidated Grain and Barge Co. v. Indiana Port Commission" on Justia Law

The case involves Refugio Avila, who was found with a loaded handgun during a traffic stop. Avila, a known member of the Satan's Disciple gang, was in a vehicle with his girlfriend when they were stopped by Chicago police officers conducting proactive policing. The officers observed several traffic violations and initiated a stop. During the stop, the officers conducted three pat-downs on Avila, discovering a loaded handgun during the third pat-down. Avila was charged with being a felon in possession of a firearm.Avila filed a motion to suppress the firearm and a motion to dismiss the indictment, alleging violations of the Speedy Trial Act. The district court denied both motions. Avila entered a conditional plea to the felony charge, reserving his right to challenge the district court's denial of his motions.The United States Court of Appeals for the Seventh Circuit affirmed the district court's ruling on the motion to suppress, finding that the officers had reasonable suspicion to stop the vehicle and to frisk Avila, and the stop was not unlawfully prolonged. However, the court found that the district court erred in denying Avila's motion to dismiss the indictment. The court concluded that the district court had improperly excluded over 300 days from the Speedy Trial Act's seventy-day clock, violating the Act. The court reversed the district court's denial of Avila's motion to dismiss the indictment and remanded the case for further proceedings. View "United States v. Avila" on Justia Law

The case revolves around Terrell Esco, who alleged that he was unlawfully detained and maliciously prosecuted by the City of Chicago police officers. The officers arrested him for weapons and drug violations, but Esco claimed that the officers knew he was not the person they saw in possession of a gun. He further alleged that the officers' body-worn camera video evidence would support his claim. However, the district court judge viewed the video and held that the officers had probable cause to detain Esco, thereby dismissing his claims.The case was then brought to the United States Court of Appeals for the Seventh Circuit. The court agreed with the district court's assessment that Esco failed to allege any plausible claims. The court noted that the determination of probable cause is based on an objective assessment of what a reasonable officer could conclude based on information known to officers at the scene. The court found that the video provided definitive evidence that the officers had probable cause to believe that Esco was the person who possessed and then discarded the weapon.Furthermore, the court found that Esco failed to prove that the proceeding terminated in his favor, a necessary element for a malicious prosecution claim under Illinois law. The court noted that the mere fact that the state court entered a nolle prosequi order, without explanation of why the court entered the order, was insufficient evidence of a favorable termination of criminal proceedings. As a result, the court affirmed the judgment of the district court, dismissing Esco's claims. View "Esco v. City of Chicago" on Justia Law

This case revolves around a dispute over an insurance claim following a house fire. The plaintiff, William Werner, owned a home in Springfield, Illinois, which was in foreclosure when it burned down in 2017. Werner's home insurance policy was with Auto-Owners Insurance Company. After the fire, Werner filed a claim seeking to recover his policy limit on the home itself and two smaller coverages, totaling just over $190,000. Auto-Owners denied Werner’s claim for the full replacement value of the home, arguing that Werner had lost any insurable interest in the full value of the property after the judicial sale occurred and all of Werner’s rights of redemption had expired.The case was first heard in the United States District Court for the Central District of Illinois. The district court ruled in favor of Auto-Owners, holding that at the time of the fire, Werner’s only remaining insurable interest in the property was based on his narrow right under Illinois law to occupy the home until 30 days after the judicial sale was confirmed. The court awarded Werner the rental value of that temporary right, which amounted to just under $4,000.Werner appealed the decision to the United States Court of Appeals for the Seventh Circuit. The appellate court affirmed the district court's ruling. The court agreed with the lower court's interpretation of Illinois insurance law, stating that Werner's insurable interest at the time of the fire was limited to the value of his temporary right of possession. The court noted that Werner still held legal title to the property when the fire occurred, but he had no legal right to redeem it from foreclosure or otherwise retain it. The court concluded that Werner's insurable interest did not extend to the full value of the property. View "Werner v. Auto-Owners Insurance Company" on Justia Law

Anthony D. Lee, Sr. was convicted of aggravated kidnapping and aggravated sexual assault in 1996 and sentenced to 100 years in prison. Lee's defense was that the victim had voluntarily entered his car and that any sexual activity was consensual. He later sought postconviction relief, arguing that his attorney, Richard Friedman, had failed to interview several potential witnesses who could have corroborated his testimony. Lee supported his motion with six affidavits from these potential witnesses. The trial court denied Lee's ineffective-assistance claim, and the Illinois Appellate Court affirmed the decision.Lee then sought relief in federal court under 28 U.S.C. § 2254. The district court denied his petition, but the United States Court of Appeals for the Seventh Circuit disagreed with the lower courts' decisions. The appellate court found that the state court had based its prejudice analysis on the flawed assumption that each witness would have merely repeated their affidavits and refused to say another word if called to testify. The appellate court vacated and remanded the case to the district court to hold an evidentiary hearing on Lee's claim.After a three-day hearing, the district court again denied Lee's § 2254 petition. The court concluded that Lee failed to establish that Friedman's performance fell below an objective standard of professional competence. Alternatively, the court concluded that any errors Friedman might have committed did not meaningfully compromise Lee's defense given the strength of the state's case. Lee appealed this decision.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court found that Lee failed to demonstrate a "reasonable probability" that the result of his trial would have been different had Friedman not committed professional errors. The court noted that none of the affidavits provided an explanation for the severity of the victim's injuries, and that the additional testimony from the witnesses may have ultimately weakened Lee's defense by contradicting his testimony or their own affidavits. View "Lee v. Galloway" on Justia Law

The case involves Anthony Carr, who was convicted for being a felon in possession of a firearm. His offense level and sentencing range were increased due to his three prior convictions in Illinois for armed robbery, which the district court treated as a crime of violence. Carr argued that this was an error, contending that he could have been convicted as an aider and abettor to robbery rather than a principal, and thus his conviction was not for a crime of violence.The United States Court of Appeals for the Seventh Circuit rejected Carr's argument. The court held that each of Carr’s Illinois convictions was for armed robbery, and the pertinent elements of that offense matched those of generic robbery. The court found that the abstract possibility that Carr could have been convicted as an aider and abettor rather than a principal was irrelevant. The court also noted that although Illinois articulates its “common-design” iteration of accomplice liability in broad terms, it was not convinced that Illinois was an outlier in the way it applies common-design liability.Carr also requested a sentence reduction to account for the time he spent in custody prior to his federal sentencing. The district court declined to entertain this request, leading to Carr's appeal. The Court of Appeals vacated and remanded the sentence for the limited purpose of reconsidering Carr’s request for a sentencing reduction. View "United States v. Carr" on Justia Law

The case involves fourteen members of the Bomb Squad, a street gang, who were charged with violations of the Racketeer Influenced and Corrupt Organizations Act (RICO), among other crimes. One member pleaded guilty, while the remaining defendants were convicted by a jury. The defendants appealed their convictions, arguing that the district judge violated Batson v. Kentucky when selecting the jury. The court of appeals retained jurisdiction of the appeal and ordered a limited remand to allow the district court to make supplemental findings on this issue. The court of appeals found no reversible error in the remaining arguments raised by the defendants and affirmed their convictions.The Bomb Squad was a street gang that used violence to protect its reputation, territory, and drug sales. The gang members were charged with numerous crimes, including murder, attempted murder, drug trafficking, and multiple robberies. The defendants argued that the district judge violated Batson v. Kentucky when selecting the jury, which prohibits a prosecutor from using a peremptory challenge to strike a prospective juror because of their race.The court of appeals ordered a limited remand to allow the district court to make supplemental findings on the Batson issue. The court of appeals found no reversible error in the remaining arguments raised by the defendants and affirmed their convictions. The court of appeals also noted that if the district court orders a new trial, much of its opinion would become moot. However, it addressed the remaining issues raised by the defendants in the interest of judicial economy. View "USA v. Williams" on Justia Law

The case involves a consumer, Yoram Kahn, who alleges that Walmart Inc., the nation's largest retailer, engages in deceptive and unfair pricing practices. Kahn claims that there are small discrepancies between the prices advertised on Walmart's shelves and the prices actually charged at the cash register. These discrepancies, he alleges, add up to hundreds of millions of dollars each year. Kahn argues that these practices violate the Illinois Consumer Fraud and Deceptive Business Practices Act, the Illinois Uniform Deceptive Trade Practices Act, and other states' consumer protection statutes. He also brings a claim for unjust enrichment and seeks to sue on behalf of a class of similarly situated consumers.The district court dismissed the case on the pleadings and denied leave to amend the complaint. The court reasoned that providing a customer with a receipt after payment stating the actual price charged is sufficient to dispel any potential deception or unfairness caused by an inaccurate shelf price. The court also held that Kahn failed to allege that Walmart intended for him to rely on the inaccurate shelf pricing.The United States Court of Appeals for the Seventh Circuit reversed the district court's decision. The appellate court held that the complaint states some viable claims. The court rejected the theory that providing a receipt after payment is sufficient to dispel any potential deception or unfairness caused by an inaccurate shelf price. The court also found that Kahn had adequately alleged a deceptive or unfair practice and the required intent. The court remanded the case for further proceedings. View "Kahn v. Walmart Inc." on Justia Law