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

The case involves Harold McGhee, who was convicted and sentenced for drug trafficking. In August 2021, law enforcement received information from a confidential source about a drug dealer distributing large amounts of cocaine in Peoria, Illinois. The dealer was said to drive a Chevy Malibu and supplied cocaine to a house on West Millman Street. With this information, along with details from other informants and a tracking warrant, the police identified McGhee as the suspected dealer. They conducted three controlled buys and a trash pull at McGhee's residence, which led to the discovery of rubber gloves and baggies with a white powdery residue that tested positive for cocaine. This evidence led to a search warrant for McGhee's residence, vehicle, person, and electronic devices, resulting in the discovery of nearly a kilogram of various drugs, a handgun, and other drug trafficking paraphernalia.McGhee sought to suppress the evidence recovered at his residence and moved for a hearing to challenge the validity of the search warrant. He argued that the affidavit's use of "SUBJECT PREMISES," in reference to both his residence and the Millman Street house, was impermissibly ambiguous. The district court denied the motion. McGhee later renewed his motion to suppress, arguing that the trash pull was constitutionally unreasonable because it was executed without a warrant. The court denied this motion as well.On appeal, McGhee raised ten challenges to the criminal proceedings resulting in his convictions and sentence. The court considered some of his arguments on the merits and resolved others on procedural grounds. Ultimately, the court affirmed the judgment of the district court in all respects. View "United States v. McGhee" on Justia Law

The case involves Jay Liestman, who was convicted for transporting child pornography, a violation of 18 U.S.C. § 2252(a)(1). Liestman had a prior conviction for possessing child pornography under Wisconsin law. The district court imposed an enhanced mandatory minimum sentence of 15 years’ imprisonment under § 2252(b)(1) due to his prior conviction. The main issue was whether the state conviction qualifies as a predicate conviction under § 2252(b)(1), which prescribes enhanced penalties for certain recidivist child sex offenders.Previously, the district court had ruled that Liestman's prior conviction for possessing child pornography triggered 18 U.S.C. § 2252(b)(1)’s enhancement for repeat sex offenders, which increases the mandatory minimum term of imprisonment from 5 to 15 years if the defendant has a prior conviction “under the laws of any State relating to ... the production, possession, receipt, mailing, sale, distribution, shipment, or transportation of child pornography.” Liestman argued that the enhancement did not apply because the Wisconsin statute reached offense conduct that Congress did not expressly enumerate in the text of § 2252(b)(1). The district court disagreed and sentenced Liestman to the enhanced mandatory minimum of 15 years.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court held that the phrase “relating to” in § 2252(b)(1) brings within the ambit of the enhancement any prior offense that categorically bears a connection with the conduct enumerated in § 2252(b)(1), regardless of whether it sweeps more broadly than that enumerated conduct in some respects. Therefore, Liestman's prior offense of conviction for possessing child pornography under Wisconsin law can serve as a predicate offense under § 2252(b)(1). View "United States v. Liestman" on Justia Law

A group called Protect Our Parks, Inc. (POP) has been challenging the location of the planned Obama Presidential Center in Chicago's historic Jackson Park. The Center, which is currently under construction, is being built on a site selected by the Barack Obama Foundation. POP argues that the park should have been off-limits and that the Center could have been placed elsewhere. They have raised multiple arguments based on federal and state law to prevent the construction of the Center in the park.Previously, POP had asked the court to halt construction until its federal-law theories were resolved. However, the court declined to grant the preliminary injunction as POP failed to show that it was likely to succeed with those contentions. The district court also refused POP’s request to amend its pleadings and dismissed the state-law causes of action. The district court then awarded summary judgment against POP on the federal-law theories.In the United States Court of Appeals for the Seventh Circuit, POP asked the court to overturn the district court’s final judgment in its entirety. However, the court found that POP’s arguments remained unpersuasive and identified no legal error in the earlier analysis of POP’s case. The court also concluded that POP’s state-law theories were rightly dismissed and that the district court did not abuse its discretion when it denied POP’s motion to amend the complaint. Therefore, the court affirmed the judgment of the district court. View "Protect Our Parks, Inc. v. Buttigieg" on Justia Law

On July 4, 2022, a mass shooting occurred in Highland Park, Illinois, where Robert Eugene Crimo III used a Smith & Wesson M&P15 rifle to kill seven people and wound 48 others. Victims of the shooting and their estates filed multiple consolidated suits against Crimo, his father, the gun shops where Crimo acquired the rifle, and the rifle's manufacturer, Smith & Wesson. The plaintiffs argued that Smith & Wesson should not have offered the M&P15 to civilians, as it is a machine gun reserved for police and military use. They also claimed that the manufacturer is liable because the weapon was advertised in a way that attracted irresponsible individuals.The defendants, including Smith & Wesson, filed notices of removal to federal court, asserting that the victims' claims arise under federal law. However, the two Crimos, who are the principal asserted wrongdoers, neither filed their own notices of removal nor consented to Smith & Wesson’s. This led the plaintiffs to move for remand, arguing that all defendants must consent to removal under federal law. Smith & Wesson countered that removal was authorized by a statute that allows removal whether or not other defendants elect to be in federal court.The United States District Court for the Northern District of Illinois was not persuaded by Smith & Wesson's arguments and remanded the cases to state court. Smith & Wesson appealed this decision to the United States Court of Appeals for the Seventh Circuit.The Seventh Circuit affirmed the district court's decision to remand the cases to state court. The court rejected Smith & Wesson's argument that the state suits presented multiple "claims" against them, stating that the company's belief that each legal theory is a separate "claim" is incorrect. The court clarified that the core claim in these suits is that Crimo killed and injured multiple persons, and Smith & Wesson may bear secondary liability for their role in facilitating his acts. The court also suggested that the district judge should consider whether Smith & Wesson must reimburse the plaintiffs' costs and fees occasioned by the unjustified removal and appeal. View "Roberts v. Smith & Wesson Brands, Inc." on Justia Law

The case revolves around Brenda Warnell, who applied for disability insurance benefits and supplemental security income under the Social Security Act in 2019. Warnell claimed she was unable to work due to debilitating migraines and chronic pain in her back, shoulders, and neck. Her medical record was mixed, with some physicians assessing her as having severely limited functional capacity, while others found her capable of limited physical exertion.The Administrative Law Judge (ALJ) denied Warnell's claim, finding that the medical evidence did not substantiate the severity of her alleged functional limitations. The ALJ concluded that Warnell's pain symptoms did not prevent her from performing light work with moderate noise and limited physical requirements. The ALJ's decision was affirmed by the district court.In the United States Court of Appeals for the Seventh Circuit, Warnell challenged the ALJ's decision, arguing that the ALJ needed to provide more detailed accounts of the medical evidence. The court rejected this argument, stating that the ALJ's decision was supported by substantial evidence and met the light standard set by the Supreme Court. The court found that the ALJ had provided a sufficient explanation for her decision, highlighting specific evidence that contradicted Warnell's claims and addressing conflicting evidence. The court affirmed the ALJ's decision, rejecting Warnell's claim that the ALJ needed to provide more detailed accounts of the medical evidence. View "Warnell v. O'Malley" on Justia Law

In the case under review, the United States Court of Appeals for the Seventh Circuit affirmed the convictions and sentences of two defendants, Christopher Tate and Sandra Kellogg, charged with conspiracy to distribute illegal drugs and other drug offenses. The government had charged twelve people with these offenses. Ten of them pleaded guilty, while Tate and Kellogg chose to go to trial. They were tried jointly, and the jury convicted them on all counts. Both defendants appealed, challenging the sufficiency of the evidence for one of their conviction counts and objecting to one of the enhancements used to determine their sentencing guidelines.The court found that the evidence was sufficient for both defendants' convictions. For Tate, the jury could have reasonably found that he at least jointly possessed the methamphetamine found in his car. For Kellogg, even if a juror could not have found a larger conspiracy connecting her, Harris, Mr. Tate, and others, she did not establish prejudice from the supposed variance between the larger conspiracy charged and the smaller conspiracy proven at trial.In terms of sentencing enhancements, the court found that the district court correctly applied the firearm-possession enhancement for Mr. Tate and the manager-supervisor enhancement for Ms. Kellogg. The court concluded that Mr. Tate's total offense level would have been the maximum under the Guidelines with or without the enhancement. As for Ms. Kellogg, she did not raise an objection to the enhancement in the district court and thus the matter was waived. View "United States v. Tate" on Justia Law

The United States Court of Appeals For the Seventh Circuit heard an appeal from Christopher Tate and Sandra Kellogg, who were charged with conspiracy to distribute illegal drugs and other drug offenses. They were tried jointly, and the jury convicted them on all counts. The district court imposed substantial, yet below-guidelines, prison sentences. On appeal, both defendants challenged the sufficiency of the evidence on one of the counts of their convictions and the enhancements used to determine their guidelines sentencing ranges.The court affirmed the convictions and sentences of both defendants. It concluded that the jury could have found that Tate at least jointly possessed the methamphetamine found in his car. The court also held that although Kellogg argued that she was not part of the larger conspiracy, she failed to establish prejudice resulting from the supposed variance between the larger conspiracy charged in the indictment and the smaller conspiracy proven at trial.Furthermore, the court held that the sentencing enhancements applied by the district court were justified. It found that the evidence supported the application of a 2-level firearm-possession enhancement against Tate, and that any error in its application would have been harmless. Similarly, the court found that Kellogg's challenge to the application of a 3-level enhancement for her role as a manager or supervisor of criminal activity was unavailing. Despite Kellogg's argument that she was not a "manager or supervisor" and that the criminal activity did not involve five or more participants, the court found sufficient evidence to support the district court's findings. View "United States v. Kellogg" on Justia Law

The case arose from a drug trafficking operation led by Keith White in an Indiana prison. White, along with others, was indicted for conspiracy to distribute heroin after three inmates died of drug overdoses. He pleaded guilty and was sentenced under enhanced penalties due to his criminal history, which included two felony convictions for cocaine dealing. This was his second appeal challenging his sentence.White argued that his status as a career offender under the Sentencing Guidelines was improperly determined based on the Supreme Court’s decision in Kisor v. Wilkie. He contended that the guideline’s definition of a “controlled substance offense” unambiguously excluded inchoate offenses, such as conspiracy, and thus the application note expanding this definition deserved no deference.The United States Court of Appeals for the Seventh Circuit disagreed. It noted that the Supreme Court’s decision in Kisor did not unsettle Stinson v. United States, which provided that commentary in the Guidelines interpreting or explaining a guideline is authoritative unless it violates the Constitution, a federal statute, or is inconsistent with the guideline. Thus, the court deferred to the Sentencing Commission’s interpretation of the career-offender guideline.Additionally, the court rejected White's argument that the “major questions doctrine” invalidated the application note. The court concluded that the application note was not a “transformative expansion” of the Sentencing Commission’s authority, and, therefore, the doctrine did not apply. The court affirmed the judgment. View "USA v. White" on Justia Law

In this case, the United States Court of Appeals for the Seventh Circuit held that a potential class of consumers who purchased infant formula manufactured by Abbott Laboratories at a plant later found to be unsanitary lacked standing to sue for economic harm. This was due to their inability to demonstrate a concrete injury-in-fact, one of the three elements required for Article III standing. The plaintiffs argued that they suffered economic harm because they would not have paid the purchase price had they known the products were at a substantial risk of being contaminated. However, the court found that the plaintiffs' alleged injury was not particularized as they did not claim that the specific products they purchased were contaminated.The court compared the case to previous decisions, notably "In re Aqua Dots," where a universal defect in a product that rendered it valueless conferred standing, and "Wallace v. ConAgra Foods, Inc.," where the plaintiffs' risk of harm was considered mere speculation. The court found that the plaintiffs' claims were more similar to the latter case, as there was only a potential risk of contamination, not a universal defect. As such, the plaintiffs' claims were dismissed for lack of standing.This decision reaffirms that plaintiffs must demonstrate a concrete and particularized injury-in-fact to establish standing in federal court. Speculative or hypothetical injuries, or injuries that are not particularized because they do not affect the plaintiff in a personal and individual way, do not meet the threshold for standing. View "Economic Loss Plaintiffs v. Abbott Laboratories" on Justia Law

In the early hours of a snowy morning, police officer Owen McGuinness responded to a hit-and-run accident in Rockford, Illinois. Upon arrival, he received conflicting accounts from Daniel Madero, who was accused of being the driver of the hit-and-run vehicle, and three witnesses who claimed they had followed the vehicle and identified Madero as the driver. Madero was arrested for aggravated battery and issued traffic citations. An investigation later concluded that Madero's vehicle was likely not involved in the hit-and-run accident, and no charges were pressed against him.Madero subsequently filed a federal complaint claiming false arrest in violation of the Fourth and Fourteenth Amendments. The district court granted summary judgment to Officer McGuinness, determining that he had probable cause to arrest Madero based on the information available at the time.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court concluded that Officer McGuinness had probable cause to arrest Madero given the testimony of the three witnesses who insisted that Madero was the driver of the hit-and-run vehicle, despite Madero's denial. Discrepancies in the witnesses' accounts and later recantations did not dispel the probable cause at the time of arrest. Therefore, Madero's claim of false arrest was rejected. View "Madero v. McGuinness" on Justia Law