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

A former student at the University of Southern Indiana was accused of sexual assault during the 2020–21 academic year. After a hearing, a university panel found the alleged victim’s account more credible than the student’s, noting her consistency over time, and concluded that the student committed rape and forcible fondling. The student was suspended for three semesters and did not return to the university. He subsequently filed a lawsuit against the university and other defendants, alleging sex discrimination in violation of Title IX, deprivation of due process, and intentional infliction of emotional distress. During discovery, the student learned of undisclosed records that suggested his account may have been consistent over time, contrary to the panel’s finding.The United States District Court for the Southern District of Indiana granted summary judgment to the defendants on all claims. In the course of the litigation, a magistrate judge ordered the student to proceed using his real name, not a pseudonym. The student objected, but the district judge overruled the objection, though the district court stayed its order pending this appeal. The student filed multiple appeals, which were consolidated for argument.The United States Court of Appeals for the Seventh Circuit reviewed whether the district court abused its discretion by denying the student’s use of a pseudonym. The court reaffirmed the strong presumption that adult parties litigate under their real names in federal court and found that the student did not present sufficient evidence of a substantial risk of physical harm or retaliation to justify use of a pseudonym. The court declined to broaden the standard to include mental health risks or to consider the merits of the underlying claims in deciding the pseudonym issue. The Seventh Circuit affirmed the district court’s order. View "Doe v University of Southern Indiana" on Justia Law

In this case, the plaintiff alleged that his constitutional rights were violated during his state criminal trial when two deputies, assigned as bailiffs, interacted with the jury during deliberations. According to the complaint, one deputy responded to a juror’s question by telling the jury that they must reach a unanimous verdict and that a hung jury was not an option. The second deputy was present but did not intervene or report the communication to the trial judge. The episode was later found to have influenced the jury, leading to the plaintiff’s conviction. After an evidentiary hearing in state court, the convictions were vacated and charges dismissed.The plaintiff then brought a civil suit in the United States District Court for the Eastern District of Wisconsin against the deputies and others, asserting violations of his constitutional rights and various state law claims. The deputies asserted qualified immunity as a defense and moved for judgment on the pleadings. The district court denied qualified immunity to the deputy who spoke to the jury, finding the law clearly established. However, as to the other deputy—who had not spoken but allegedly failed to intervene—the district court denied qualified immunity “without prejudice,” explaining that neither party had properly briefed the issue regarding his specific actions and invited a renewed argument at summary judgment.The United States Court of Appeals for the Seventh Circuit reviewed the interlocutory appeal filed by the deputy who had not spoken to the jury. The court held that because the district court had not made a final or substantive ruling on the qualified immunity issue as it pertained to this deputy, there was no appealable decision under the collateral order doctrine. As a result, the Seventh Circuit dismissed the appeal for lack of jurisdiction. View "Mahajni v Do" on Justia Law

The case concerns a defendant who was indicted for sex trafficking minors and faced serious federal charges. Over the course of three years between his indictment and trial, the defendant was represented by five different court-appointed attorneys. He repeatedly refused to cooperate with his lawyers, frequently submitted pro se motions, and violated court orders prohibiting him from contacting victims and witnesses. Twice, after comprehensive hearings in line with Faretta v. California, the defendant knowingly and voluntarily waived his Sixth Amendment right to counsel and elected to represent himself, despite being warned by the judge that no further attorneys would be appointed if he changed his mind again.Throughout the pretrial proceedings, the United States District Court for the Northern District of Illinois patiently allowed several changes in representation, including the appointment of standby counsel. However, when the defendant again requested an attorney during trial, after previously waiving counsel and being warned that further appointments would not be made, the district judge denied the request. After a jury trial, the defendant was found guilty on all counts, and his posttrial motions—including a challenge to the denial of his midtrial request for counsel—were denied.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether the district judge abused his discretion in denying the midtrial request for a sixth appointed lawyer. The Seventh Circuit held that, after a valid Faretta waiver, district judges may require a defendant to abide by his choice to proceed pro se, especially if the request for counsel is made after trial has begun. The court further held that there is no constitutional requirement to reassess the defendant’s motives or the likely delay caused by such a request under these circumstances. The judgment of the district court was affirmed. View "USA v Perry" on Justia Law

The plaintiffs held individual retirement accounts (IRAs) for which Capital One acted as custodian. Capital One chose to resign as custodian and notified the plaintiffs that, unless they directed otherwise, their IRA funds would be transferred to Inspira Financial Trust (formerly Millennium Trust Company). Plaintiffs did not act to select a different custodian or investment option. After the funds were transferred, Inspira placed them in a “sweeps” account that paid a low annual interest rate—less than Inspira’s management fees. Plaintiffs complained that both Capital One and Inspira breached their contractual duties by causing their funds to earn little or no net return, though they acknowledged Inspira is a reputable institution.In the United States District Court for the Northern District of Illinois, Eastern Division, the judge compelled arbitration of the claims against Inspira due to an arbitration agreement. The court then dismissed the claims against Capital One on the merits under Federal Rule of Civil Procedure 12(b)(6), relying in part on an exculpatory clause in the contract. Plaintiffs appealed the portion of the judgment relating to Capital One, under Rule 54(b).The United States Court of Appeals for the Seventh Circuit reviewed the case. The appellate court held that Capital One did not breach its contractual obligations, even when interpreting the contract as plaintiffs urged. The court found that Capital One’s actions—providing ample notice and allowing plaintiffs to choose their own custodian or investment vehicle—complied with its duties, including any obligations of good faith and fair dealing under applicable state law. The court further noted that plaintiffs were not prevented from learning about or choosing better investment options. The Seventh Circuit affirmed the district court’s dismissal of the claims against Capital One. View "Hewitt v Capital One Bank, N.A." on Justia Law

William Walls was found by an Illinois state court to be a sexually violent person in 2015, leading to his civil commitment under Illinois law. The commitment was based, in part, on statements he made or that were made by his treatment providers while he was incarcerated for a prior sexual assault conviction. Walls has argued that these statements were obtained in violation of his constitutional rights. After his commitment, his case involved extensive delays, including a twelve-year period before the initial commitment decision and seven years before the state appellate court resolved the appeal filed by his counsel.After the 2015 commitment order, Walls—sometimes proceeding pro se despite being represented—filed a series of appeals and petitions. The Illinois Appellate Court eventually affirmed both the 2015 and a subsequent 2018 recommitment decision in a consolidated opinion. Walls’s first federal habeas petition under 28 U.S.C. §2254 was dismissed by the United States District Court for the Central District of Illinois on procedural default grounds. He did not appeal that dismissal. After the 2018 recommitment proceeding, Walls filed a second federal habeas petition, which was dismissed as an unauthorized successive petition under 28 U.S.C. §2244(b) because it challenged the same 2015 order or did not raise new claims as required.The United States Court of Appeals for the Seventh Circuit reviewed Walls’s appeal of the district court’s dismissal. The court held that, to the extent Walls was once again contesting the 2015 commitment order, his petition was barred as a successive habeas application. Alternatively, if he was challenging later decisions, he had failed to raise or exhaust federal claims relating to those decisions. The Seventh Circuit affirmed the district court’s dismissal of Walls’s petition. View "Walls v Posey" on Justia Law

An individual entered the United States without authorization prior to 2018. After she was convicted in Illinois state court for possessing cocaine with intent to deliver, federal immigration authorities issued a Final Administrative Removal Order (FARO) against her under expedited procedures, and she was removed to Mexico in August 2018. Subsequently, she reentered the United States without authorization. She later obtained an amendment of her state conviction to simple possession, arguing the original charge overstated her conduct. Relying on this development, she requested that the Department of Homeland Security (DHS) reopen and cancel her prior removal order. A Deportation Officer in the Chicago Field Office responded by email, stating the office would not revisit the 2018 order.After the Deportation Officer declined to act, the individual petitioned the United States Court of Appeals for the Seventh Circuit to review the decision under 8 U.S.C. §1252(a). She characterized the email as a reviewable final order of removal. Meanwhile, DHS had not reinstated the 2018 removal order but had instead initiated new removal proceedings by issuing a Notice to Appear, beginning a new immigration process.The United States Court of Appeals for the Seventh Circuit held that it lacked jurisdiction to review the petition because the email from the field office was not a “final order of removal” as defined by statute or relevant precedent. The court explained that the 2018 removal order was already executed and had not been reinstated, and that the petitioner was now subject to new removal proceedings. Because there was no reviewable order before it, the court dismissed the petition for review. View "Velazquez-Olais v Blanche" on Justia Law

Thomas T.D. Polk and his wife, Katarzyna Kurek-Polk, were struck by a vehicle while assisting another motorist, resulting in serious injury to Thomas and Katarzyna’s death. They recovered $100,000 from the at-fault driver’s insurance and sought additional compensation under three separate underinsured motorist (UIM) policies: $1,000,000 from AMCO Insurance Company, $500,000 from Progressive Northern Insurance Company, and $500,000 from Secura Supreme Insurance Company. Each policy included a proportionate liability clause and an “Other Insurance” anti-stacking provision, which limited the total UIM recovery to the highest coverage available under a single policy.After receiving $800,000 from the AMCO policy and rejecting a $220,000 offer from Secura, Polk filed a breach of contract suit against Secura and Progressive in the United States District Court for the Northern District of Illinois. The district court granted summary judgment in favor of the insurers. It held that the anti-stacking provisions were unambiguous and limited Polk’s maximum recovery to $1,000,000—the highest limit among the policies—regardless of the number of insureds or policies. Since Polk had already received $900,000 from the tortfeasor and AMCO, the court ordered Secura to pay $100,000 to bring the total to $1,000,000, and ruled that Progressive owed nothing.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. It held that the anti-stacking provisions in both the Progressive and Secura policies were clear and enforceable under Illinois law, and that the insurers’ liabilities were properly offset by the amounts already received, thus capping total recovery at $1,000,000. The court also rejected Polk’s arguments regarding policy ambiguity and statutory interpretation. View "Polk v Progressive Northern Insurance Company" on Justia Law

A group of current and former shuttle truck drivers who work exclusively within Illinois, transporting auto parts and custom storage racks between storage lots and a Ford assembly plant in Chicago, alleged that their employers failed to pay them overtime wages as required by the Fair Labor Standards Act (FLSA), as well as relevant state and municipal wage laws. The essential facts, which were stipulated by the parties, establish that the auto parts are manufactured out of state, delivered by interstate carriers to storage lots near the assembly plant, and then moved by the plaintiffs from these lots to the plant as needed. After unloading, the drivers return the empty trailers to the storage lots, where interstate carriers retrieve them for return to the manufacturing sites.The United States District Court for the Northern District of Illinois, Eastern Division, granted summary judgment for the defendants. The district court determined that the plaintiffs’ work moving goods from the storage lots to the assembly plant was part of a continuous interstate journey, thereby qualifying for the Motor Carrier Act (MCA) exemption to the FLSA’s overtime requirement. This exemption applies when employees are subject to the Secretary of Transportation’s authority over qualifications and maximum hours.Reviewing the appeal, the United States Court of Appeals for the Seventh Circuit held that the transportation performed by the shuttle drivers was indeed a continuation of the interstate shipment, as the storage lots were not the final destination for the goods. Applying the legal standard articulated in Collins v. Heritage Wine Cellars, Ltd., the court found the relevant criteria for interstate commerce satisfied. The court rejected the plaintiffs’ argument that the storage lots and assembly plant should be considered a single destination. The Seventh Circuit affirmed the district court’s grant of summary judgment in favor of the defendants, holding that the MCA exemption applies and overtime pay was not required. View "Stingley v Laci Transport Inc." on Justia Law

The defendant was indicted under a federal statute that prohibits individuals convicted of crimes punishable by more than one year of imprisonment from possessing firearms. The defendant’s criminal history included prior convictions for armed robbery and aggravated battery, and the conduct leading to the present prosecution involved using a firearm to threaten passengers on public transportation and possessing a loaded semi-automatic weapon in a location where firearms were explicitly prohibited.The United States District Court for the Northern District of Illinois, Eastern Division, dismissed the indictment. The district court concluded that the statute in question, 18 U.S.C. §922(g)(1), was invalid on its face under the Second Amendment, meaning that it was unconstitutional in every possible application. The government appealed this decision.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court considered Supreme Court precedents regarding the Second Amendment, including District of Columbia v. Heller, McDonald v. Chicago, New York State Rifle & Pistol Association, Inc. v. Bruen, and United States v. Rahimi. The appellate court noted that, while there is disagreement among courts about the statute’s application in some circumstances, all courts of appeals have agreed that §922(g)(1) is valid in many applications and cannot be declared unconstitutional in all cases. The Seventh Circuit held that the statute cannot be found facially invalid and reserved judgment on whether it might be unconstitutional as applied to individuals whose prior convictions do not suggest they are dangerous. In this case, because the defendant’s convictions and conduct indicated a risk of dangerousness, the court reversed the district court’s dismissal and remanded the case for further proceedings. View "USA v Prince" on Justia Law

A group of prisoners in Illinois sued the state’s Department of Corrections, alleging that they were provided with inadequate medical and dental care, which they claimed violated the Eighth Amendment. The class was certified, and the parties reached a settlement that led to the entry of a consent decree. This decree required the Department to prepare an implementation plan, with oversight and recommendations from an independent monitor, to address the systemic deficiencies identified. Over time, disagreements arose regarding the adequacy and specificity of the Department’s proposals, and the monitor’s recommendations were largely adopted by the court after finding the Department in contempt for noncompliance.The United States District Court for the Northern District of Illinois, Eastern Division, approved and amended the consent decree, eventually adopting the implementation plan as part of it. The Department then filed several motions under Rule 60(b) to modify the consent decree, including requests to remove stipulations about compliance with the Prison Litigation Reform Act (PLRA) and to excise or terminate the implementation plan. The court denied these requests, but did acknowledge changed circumstances and amended the decree to clarify that the implementation plan would only be enforceable if the court made findings required by the PLRA. The court also extended the term of the consent decree due to the Department’s lack of substantial compliance.On appeal, the United States Court of Appeals for the Seventh Circuit found it lacked jurisdiction to review some orders, such as the denial of the motion to strike the stipulation and the extension of the decree, as these did not substantially alter the parties’ legal relationship. The court affirmed the lower court’s decisions regarding the implementation plan, holding that its terms are not enforceable unless and until the district court makes the factual findings required by 18 U.S.C. § 3626(a)(1)(A) of the PLRA. The case was remanded for further proceedings. View "Lippert v Hughes" on Justia Law