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

A native of Ivory Coast and citizen of Mali entered the United States as a student in 2000. The Department of Homeland Security initiated removal proceedings against him in 2010 for failing to maintain his student status. He admitted the allegations and conceded removability. While his removal case was pending, he was a victim of domestic violence by his U.S. citizen spouse, leading to her criminal conviction and their eventual divorce. He applied for a U visa and for cancellation of removal as a victim of domestic violence. His attorney withdrew from representation in June 2019. Before his scheduled October 2019 immigration hearing in Chicago, the petitioner was robbed, losing his savings and becoming destitute. He was unable to secure transportation to the hearing after his friend failed to provide a ride and he lacked funds for a bus ticket. He did not contact the Immigration Court to explain his absence. The Immigration Judge ordered him removed in absentia.After the Immigration Judge denied his motion to reopen and rescind the removal order—finding he failed to show "exceptional circumstances" for missing the hearing—the petitioner appealed to the Board of Immigration Appeals. The Board agreed, reasoning that his financial hardship and failed transportation arrangements did not amount to exceptional circumstances because he had not demonstrated that these events prevented him from notifying the court in advance.The United States Court of Appeals for the Seventh Circuit reviewed the Board’s decision for abuse of discretion. The Seventh Circuit held that the Board did not abuse its discretion in denying the motion to reopen. The court found that, although the petitioner faced significant hardships, his failure to notify the court of his predicament undermined his claim of exceptional circumstances. The petition for review was denied. View "Nimaga v. Blanche" on Justia Law

The plaintiff, Kimberly Ballard, worked for Ameren Illinois Company and was terminated from her position in February 2018. She alleged that her dismissal, as well as other adverse actions at work, stemmed from discrimination and retaliation based on her physical disability. After her termination, Ballard submitted a Complainant Information Sheet (CIS) to the Illinois Department of Human Rights (IDHR) within 300 days, as required for federal discrimination claims, and later engaged in further correspondence with the agency. Ultimately, the IDHR finalized a formal charge of discrimination more than 300 days after her termination, which led to her receiving a right-to-sue letter from the Equal Employment Opportunity Commission (EEOC).The United States District Court for the Central District of Illinois dismissed Ballard’s lawsuit, concluding that her CIS did not qualify as a “charge” of discrimination under the Americans with Disabilities Act (ADA) because it did not include a request for remedial action, and thus she failed to meet the statutory 300-day filing requirement. The district court further denied Ballard’s motion for reconsideration, which argued that either her CIS was sufficient under Supreme Court precedent or, alternatively, that equitable tolling should apply due to confusing communications from the IDHR. The district court did not address her equitable tolling argument.The United States Court of Appeals for the Seventh Circuit reviewed the case. The appellate court affirmed that, under its precedent, a CIS is not a “charge” for ADA purposes and upheld the district court’s dismissal on that ground. However, the court found that Ballard’s equitable tolling argument warranted consideration due to possible misleading conduct by the IDHR and an incomplete record. The Seventh Circuit vacated the district court’s judgment and remanded the case for further proceedings regarding equitable tolling. View "Ballard v Ameren Illinois Company" on Justia Law

A longtime Speaker of the Illinois House of Representatives was prosecuted in federal court for engaging in extensive bribery schemes. The first involved a major utility company, Commonwealth Edison (ComEd), which, facing financial difficulties, funneled more than $3 million to the defendant’s political associates through intermediaries and sham contracts in exchange for the defendant’s legislative support of ComEd’s agenda over several years. The government presented evidence that these payments resulted in concrete legislative actions by the defendant that benefitted ComEd, including support for specific bills and regulatory changes. The second scheme involved the defendant’s agreement to recommend a Chicago alderman for a state board appointment in exchange for business referrals and benefits to the defendant’s family.Following a lengthy trial in the United States District Court for the Northern District of Illinois, the jury convicted the defendant on several counts, including conspiracy, federal-program bribery, honest-services wire fraud, and Travel Act violations. The jury acquitted him on some counts and was deadlocked on others. The district court denied the defendant’s motions for acquittal and for a new trial, then imposed a sentence of imprisonment and a substantial fine.On appeal to the United States Court of Appeals for the Seventh Circuit, the defendant challenged the sufficiency of the evidence and the adequacy of the jury instructions. The Court of Appeals held that sufficient evidence supported each conviction and found no prejudicial error in the jury instructions, including those related to the definition of “official act,” “corruptly,” and the intent elements of bribery. The court also concluded that any potential instructional error regarding state law bribery under the Travel Act was harmless beyond a reasonable doubt. The convictions and sentence were affirmed. View "USA v. Madigan" on Justia Law

The case centers on Ashantae Corruthers, who, at the request of her friend Regina Lewis, agreed to purchase a firearm for Lewis’s cousin, Darrion Lafayette, in exchange for money. In November 2020, the group traveled from Illinois to Indiana, where Corruthers bought a Glock 48 pistol and ammunition for Lafayette, falsely certifying on the ATF purchase form that she was the true buyer. The firearm was later used by Lafayette in multiple incidents, including the fatal shooting of a police officer in Champaign, Illinois. Afterward, Corruthers falsely reported the firearm as stolen and made misleading statements to federal agents regarding her involvement.A federal grand jury indicted Corruthers and Lewis for conspiracy to illegally purchase and transfer a firearm and conspiracy to engage in misleading conduct. Lewis pled guilty and was sentenced to 60 months’ imprisonment on the firearm charge and 102 months on the misleading conduct charge, to run concurrently. Corruthers also pled guilty. In her case, the United States District Court for the Central District of Illinois calculated her guidelines range at 21 to 27 months but imposed an above-guidelines sentence of 48 months, citing the seriousness and consequences of her conduct. The court rejected the government’s argument to apply the higher offense level for obstruction of a murder investigation, finding that the post-shooting inquiry was not a murder investigation.The United States Court of Appeals for the Seventh Circuit reviewed both Corruthers’s appeal of her sentence and the government’s cross-appeal. The court held that the district court did not abuse its discretion by imposing an above-guidelines sentence, as it fully considered the relevant factors and provided adequate justification. It also affirmed the district court’s refusal to apply the higher guidelines for obstruction, finding no clear error in its determination of the investigation’s scope. The sentence was affirmed. View "USA v. Corruthers" on Justia Law

Mitchell Melega, serving as the financial controller for two companies owned by Erik Jones, participated in a scheme to defraud two regional banks. The companies, involved in vehicle sales and property management, submitted false promises and forged documents to secure loan advances for nonexistent projects or vehicles. Melega played a central role in submitting fraudulent documents, directing employees to hide the scheme, and helping divert the funds for unauthorized purposes. The fraudulent activities spanned over a year and caused more than $7,000,000 in losses to the banks. Both Melega and Jones were indicted on multiple counts, but while Jones entered a plea agreement with a set sentencing range and received 54 months' imprisonment, Melega entered an open plea and proceeded to sentencing without a stipulated range.The United States District Court for the Central District of Illinois calculated Melega’s sentencing range using the 2023 U.S. Sentencing Guidelines, applying a two-level enhancement for the use of sophisticated means and another two-level enhancement for his role as a supervisor in the offense. The court found Melega directly engaged in complex concealment and management of the fraudulent scheme, including instructing others to provide false information. After considering these enhancements and mitigation evidence, the court sentenced Melega to 75 months, a term below the advisory guideline range.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether the enhancements were properly applied, whether the court relied on unreliable facts, and whether there was an unwarranted sentencing disparity compared to Jones. The Seventh Circuit held that the district court did not clearly err in applying either enhancement, did not rely on inaccurate or unreliable information, and provided a reasonable basis for the sentencing disparity. The appellate court affirmed Melega’s sentence. View "USA v Melega" on Justia Law

An individual applied for a position as a citizenship and immigration assistant with the United States Citizenship and Immigration Services (USCIS), which required a security clearance. After being tentatively selected, the applicant’s background investigation revealed concerns that led to a prolonged delay. When the security issues remained unresolved for over a year, the agency rescinded the job offer. The applicant alleged that the delay and ultimate rescission were not due to genuine security concerns but were instead a pretext for retaliation based on prior complaints and litigation against the Department of Homeland Security (DHS) for disability discrimination.Previously, the applicant had been terminated from a different DHS position following a work-related injury and a subsequent Inspector General investigation, which substantiated some misconduct but not the most serious allegations. After several unsuccessful attempts to regain federal employment, and following additional administrative complaints, the applicant filed suit in the United States District Court for the Northern District of Illinois, asserting retaliation under the Rehabilitation Act. The Secretary of Homeland Security moved to dismiss, relying on Department of the Navy v. Egan, which bars judicial review of security-clearance decisions. The district court dismissed the case for lack of subject-matter jurisdiction.The United States Court of Appeals for the Seventh Circuit reviewed the case and clarified that Egan’s rule is not jurisdictional but is instead a merits-based limitation, mandating judicial deference to executive security-clearance decisions. The appellate court held that the applicant’s retaliation claim required impermissible judicial scrutiny of the agency’s security-clearance reasoning and thus fell squarely within Egan’s bar. The court modified the district court’s dismissal to reflect a merits-based dismissal (for failure to state a claim) rather than a jurisdictional one and affirmed the judgment as modified. View "Shiba v Mullin" on Justia Law

Michael Lincoln applied for disability insurance benefits and supplemental security income, alleging that his ability to work was limited due to conditions including prostate cancer, for which he received treatment beginning in late 2019. His treatment concluded in mid-2020, and his cancer entered remission. Lincoln continued to experience symptoms such as fatigue and reported using a cane at times, but also engaged in various daily activities. He claimed an inability to work beginning in October 2019.An administrative law judge (ALJ) held a hearing in May 2022 and, in August 2022, concluded that Lincoln was not disabled. The ALJ determined that Lincoln had the residual functional capacity to perform “light work” with certain postural limitations, and specifically found that Lincoln could perform his past work as a school bus driver. In reaching this conclusion, the ALJ found that Lincoln’s subjective complaints regarding fatigue and cane use were not entirely consistent with the medical evidence and daily activities. The ALJ also found the opinions of state agency medical consultants more persuasive than that of Lincoln’s treating nurse practitioner. The Appeals Council denied further review, making the ALJ’s decision final. The United States District Court for the Central District of Illinois affirmed the ALJ’s decision.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the ALJ’s findings, applying a deferential “substantial evidence” standard. The court held that substantial evidence supported the ALJ’s determination regarding Lincoln’s residual functional capacity, including the findings related to Lincoln’s fatigue, cane use, and the persuasiveness of medical opinions. Accordingly, the court affirmed the judgment of the district court, upholding the denial of benefits. View "Lincoln v. Bisignano" on Justia Law

Keisha Lewis worked for the Indiana Department of Transportation, handling federal relocation claim vouchers for those displaced by highway projects. After receiving a remote-work accommodation due to a kidney condition, Lewis began experiencing conflicts with her supervisors over her work responsibilities, performance, and compliance with job duties. Issues escalated when she refused to process certain vouchers and failed to comply with supervisor instructions, resulting in a backlog of over 400 parcels. Despite being warned that failure to perform her job duties would be considered insubordination, Lewis continued to dispute her work obligations and was eventually terminated for poor performance and insubordination.After her dismissal, Lewis filed suit against the Department and two supervisors, asserting claims of disability discrimination and retaliation under the Rehabilitation Act, as well as race discrimination and retaliation under Title VII and 42 U.S.C. § 1981. Some claims were voluntarily dismissed, and the United States District Court for the Southern District of Indiana granted summary judgment for the defendants on the remaining claims, concluding that no reasonable jury could find in Lewis’s favor.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s summary judgment ruling de novo. The appellate court held that the Rehabilitation Act requires plaintiffs to show that disability was the sole cause of an adverse employment action, a standard Lewis did not meet. The court further found no evidence of pretext or retaliatory intent in her termination, and that her race discrimination and retaliation claims failed due to lack of supporting evidence and waiver of arguments. The Seventh Circuit affirmed the district court’s grant of summary judgment for the defendants. View "Lewis v Indiana Department of Transportation" on Justia Law

Hyatt Hotels Corporation managed a loyalty program for guests, which was funded by contributions from both Hyatt-owned and third-party-owned Hyatt-branded hotels. These contributions, along with income from direct sales of points and investment returns, were held in a centralized fund managed by Hyatt. When members redeemed points, funds were used to compensate hotels and pay for program-related expenses. The Internal Revenue Service (IRS) asserted that income flowing into this fund from third-party sources, direct sales, and investments should be treated as Hyatt’s income for tax purposes.The United States Tax Court reviewed the IRS’s notice of deficiency and Hyatt’s petition challenging it. Hyatt argued that the fund’s income was not its own under the claim of right and trust fund doctrines, and, alternatively, that if it was, Hyatt should be allowed to use the trading stamp method of accounting to offset the income with estimated costs. The Tax Court rejected both arguments, holding that Hyatt’s benefit from the fund made the income taxable to Hyatt and that the trading stamp method was unavailable because the rewards were not tangible property.On appeal, the United States Court of Appeals for the Seventh Circuit found that the Tax Court’s analysis was incomplete. Specifically, the appellate court held that the Tax Court erred by failing to consider whether the claim of right doctrine provided an independent basis for excluding the fund’s income from Hyatt’s taxable income. The Seventh Circuit clarified that the claim of right doctrine is broader than the trust fund doctrine and may permit exclusion even when the trust fund doctrine does not apply. The court vacated the Tax Court’s decision and remanded the case for further proceedings to determine whether the fund’s income was Hyatt’s under the claim of right doctrine. View "Hyatt Hotels Corporation & Subsidiaries v. CIR" on Justia Law

A Wisconsin statute enacted in 2023 required that electronic nicotine delivery systems (such as vapes and e-cigarettes) could only be sold in the state if they had received premarket authorization from the Food and Drug Administration (FDA), were pending FDA review as of specified dates, or did not contain nicotine. The law also imposed financial penalties and authorized private lawsuits against violators. Several businesses and consumers involved in the manufacture, distribution, retail, and use of these products challenged the statute, arguing that federal law granting the FDA authority over tobacco products preempted the Wisconsin statute. They also asserted that the law violated the Equal Protection Clause, and sought preliminary and permanent injunctions to prevent enforcement.The United States District Court for the Western District of Wisconsin denied the motion for a preliminary injunction. The district court found that the Wisconsin law was not preempted by federal statutes, specifically the Federal Food, Drug, and Cosmetic Act (FDCA) and the Family Smoking Prevention and Tobacco Control Act (TCA). The court concluded that Congress had not intended to preempt states from imposing additional or more stringent requirements on the sale of tobacco products, and that the plaintiffs had not shown a likelihood of success on the merits or that the balance of equities favored an injunction.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision. The Seventh Circuit held that the text and structure of the relevant federal statutes, including the TCA’s preservation and savings clauses, demonstrated that Congress did not preempt state authority to regulate, or even prohibit, the sale of tobacco products. The court affirmed the district court’s denial of a preliminary injunction, holding that the plaintiffs had failed to show a reasonable likelihood of success on the merits of their preemption claim. View "Wisconsinites for Alternatives to Smoking v. Casey" on Justia Law