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

Edward C. Brown was convicted of distribution and possession of child pornography in 2015. After serving his prison sentence, he was placed on supervised release with conditions, including allowing unannounced visits by probation officers and reporting any cell phones he possessed. During an unannounced visit in April 2023, probation officers discovered an unreported cell phone in Brown's apartment. A forensic search of the phone revealed 75 thumbnail images of child pornography in an inaccessible cache folder. Brown was subsequently charged with possession of child pornography and convicted by a jury.The United States District Court for the Central District of Illinois admitted Brown's prior child pornography convictions as evidence under Federal Rules of Evidence 414 and 404(b). The court also allowed evidence of Brown's supervised release status. At trial, the jury heard testimony from government witnesses, including a probation officer, a police detective, and an FBI special agent, as well as defense witnesses who highlighted deficiencies in the forensic evidence. Despite the lack of metadata and direct evidence linking Brown to the images, the jury found him guilty. The district court denied Brown's motion for acquittal and sentenced him to 78 months in prison, followed by a 15-year term of supervised release. The court also revoked his supervised release from prior convictions, adding a consecutive 6-month prison term.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed Brown's conviction. The court held that the combination of the 75 thumbnail images, Brown's prior convictions, his interview admissions, and his failure to report the phone provided sufficient circumstantial evidence for a reasonable jury to find him guilty beyond a reasonable doubt. The court emphasized that the forensic evidence, while flawed, was supported by other incriminating factors, including Brown's technological knowledge and his concealment of the phone from probation. View "USA v Brown" on Justia Law

Mullins Food Products, Inc. was sued in Illinois state court for violating the Biometric Information Privacy Act (BIPA). Mullins requested its liability insurer, Citizens Insurance Company of America, to defend the suit, but Citizens declined and instead filed a federal suit seeking a declaratory judgment that it had no duty to defend or indemnify Mullins based on exclusions in the commercial liability insurance policies issued to Mullins in 2015, 2016, and 2017. While the federal suit was pending, Mullins settled the state-court action.The United States District Court for the Northern District of Illinois agreed with Citizens that the policy exclusions relieved Citizens of the duty to defend or indemnify Mullins. Specifically, the court found that the Access or Disclosure of Confidential or Personal Information exclusion and the Recording and Distribution of Material or Information in Violation of Law exclusion barred coverage for BIPA claims. The district court also ruled against Mullins on its counterclaim for breach of contract, reasoning that Citizens' timely filing of the declaratory judgment action precluded a finding of breach.The United States Court of Appeals for the Seventh Circuit reviewed the case and vacated the district court's decision. The appellate court concluded that the Access or Disclosure exclusion in the 2016 and 2017 policies barred coverage for BIPA claims, but the Statutory Violations exclusion did not. Therefore, Citizens had a duty to defend and indemnify Mullins under the 2015 policy, assuming Mullins provided timely notice of the state-court action. The appellate court remanded the case for further proceedings to determine the timeliness of Mullins' notice and to address Mullins' claim for reimbursement of defense costs. View "Citizens Insurance Company of America v Mullins Food Products, Inc." on Justia Law

An executive at a litigation funding company, Signal, resigned to start a competing business and sought legal advice from Signal’s outside counsel, Sugar Felsenthal Grais & Helsinger LLP. Signal sued the law firm and several of its attorneys, alleging legal malpractice, breach of contract, breach of fiduciary duty, and fraud. The district court dismissed some claims and granted summary judgment in favor of the defendants on the remaining claims. Signal appealed these rulings.The United States District Court for the Northern District of Illinois dismissed Signal’s breach of fiduciary duty claim and part of its fraud claim, allowing the legal malpractice, breach of contract, and fraudulent misrepresentation claims to proceed. The court also struck Signal’s request for punitive damages. During discovery, the court denied Signal’s motion to compel production of a memorandum prepared by one of the defendants. The district court later granted summary judgment in favor of the defendants on all remaining claims.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s rulings. The appellate court agreed that Signal failed to establish proximate cause and damages for its legal malpractice and breach of contract claims. The court also found that Signal waived its challenge to the summary judgment ruling on the fraudulent misrepresentation claim by not adequately addressing it on appeal. Additionally, the court upheld the district court’s decision to deny Signal’s motion to compel production of the memorandum, as Signal did not demonstrate that the document influenced the witness’s testimony. The appellate court concluded that the district court’s dismissal of the fraudulent concealment theory was harmless error and denied Signal’s motion to certify a question to the Illinois Supreme Court as moot. View "Signal Funding, LLC v Sugar Felsenthal Grais & Helsinger LLP" on Justia Law

David Walton, a Wisconsin prisoner, filed a lawsuit under 42 U.S.C. § 1983 against Ashley Nehls, a prison nurse, alleging that she violated his Eighth Amendment rights by engaging in a sexual relationship with him. Walton testified that the relationship was consensual. The district court granted summary judgment for Nehls, reasoning that a consensual sexual relationship does not constitute cruel or unusual punishment under the Eighth Amendment.The United States District Court for the Eastern District of Wisconsin reviewed the case and entered summary judgment in favor of Nehls. The court concluded that Walton's testimony about the consensual nature of the relationship meant that it could not be considered a violation of the Eighth Amendment. Walton appealed the decision, urging the appellate court to adopt a legal presumption that any sexual activity between a prisoner and a prison official is nonconsensual and violates the Constitution unless the prison official can show an absence of coercion.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The Seventh Circuit acknowledged the power dynamics between prisoners and prison officials and the evolving standards of decency, noting that all 50 states have criminalized sexual conduct between prison officials and prisoners. However, the court found that even if it applied the presumption of nonconsent, the evidence in the record established that the relationship between Walton and Nehls lacked any coercive factors. Therefore, the court affirmed the district court's entry of summary judgment for Nehls, leaving the broader legal question of adopting a presumption of nonconsent for another day. View "Walton v Nehls" on Justia Law

George and Maria Dernis borrowed money from Premier Bank, which was involved in fraudulent lending practices. The loans were secured by mortgages on their personal real estate. After Premier Bank collapsed, the FDIC was appointed as receiver and sold some of the bank's loans, including the Dernises' loans, to Amos Financial in 2014. The Dernises claimed that the FDIC was aware of the fraudulent nature of the loans and failed to take remedial action. They filed a lawsuit against the FDIC, which was dismissed by the district court. They then filed an amended complaint against the United States under the FTCA, alleging various torts based on the FDIC's conduct.The United States District Court for the Northern District of Illinois dismissed the amended complaint, determining that most of the claims were not timely exhausted under 28 U.S.C. § 2401(b). The court also found that the sole timely claim was barred by the FTCA’s intentional torts exception under 28 U.S.C. § 2680(h). The court dismissed the action with prejudice and entered final judgment.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that the Dernises failed to timely exhaust their administrative remedies for most of their claims. The court also held that the only timely claim was barred by the FTCA’s intentional torts exception, as it involved misrepresentation, deceit, and interference with contract rights. The court rejected the Dernises' argument that the FDIC’s "sue-and-be-sued" clause provided a broader waiver of sovereign immunity, noting that the United States was the sole defendant and the FTCA provided the exclusive remedy for tort claims against the United States. View "Dernis v United States" on Justia Law

In July 2019, Indiana Department of Child Services (DCS) workers encountered a two-month-old infant, L.M., with a severe skull fracture and extensive brain damage. The infant's parents, Erika and Brian Mabes, had taken him to the emergency room after finding him unresponsive. This led to child abuse and custody proceedings against the Mabeses. They eventually regained custody and sued nine DCS workers and a consultant doctor, alleging violations of their Fourth and Fourteenth Amendment rights under 42 U.S.C. § 1983.The United States District Court for the Southern District of Indiana denied the defendants' motions for summary judgment, finding unresolved factual disputes that precluded their requests for qualified immunity. The defendants appealed this decision.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court reversed the district court's decision, granting qualified immunity to all defendants. The court found that the DCS workers and the consultant doctor acted reasonably under the circumstances and did not violate clearly established constitutional rights. The court emphasized the urgency and severity of the situation faced by the DCS workers and the consultant doctor, concluding that their actions were lawful and reasonable. The court also noted that the plaintiffs failed to provide evidence that the defendants acted with intent to misrepresent facts or ignored exculpatory evidence. The court remanded the case for entry of judgment in favor of the defendants. View "Mabes v McFeeley" on Justia Law

Plaintiffs Republic Technologies (NA), LLC and Republic Tobacco, L.P. manufacture and market OCB brand organic hemp rolling papers, while defendant BBK Tobacco & Foods, LLP (HBI) markets RAW brand rolling papers. Republic sued HBI in 2016 for a declaration that OCB’s trade dress did not infringe RAW’s trade dress and later added false advertising claims. HBI counterclaimed, alleging that OCB’s trade dress infringed RAW’s trade dress. A jury trial in 2021 resulted in a mixed verdict, and the district court issued a permanent injunction against some of HBI’s advertising practices.The United States District Court for the Northern District of Illinois found HBI liable under Illinois law for false advertising but not under the federal Lanham Act. The jury also found that OCB’s trade dress for its 99-cent promotional pack infringed RAW’s trade dress, but not the full-priced pack. Republic’s motions for judgment as a matter of law and for a new trial were denied.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s decision, holding that the district court did not abuse its discretion in responding to the jury’s question about the definition of “consumer” and in denying Republic’s motion for a new trial. The court also upheld the jury’s finding of trade dress infringement, noting that sufficient evidence supported the jury’s verdict. Additionally, the court affirmed the district court’s permanent injunction, rejecting HBI’s arguments that the injunction was vague, overbroad, and improperly applied nationwide. The court concluded that the injunction was appropriately tailored to provide complete relief to Republic. View "Republic Technologies (NA), LLC v BBK Tobacco & Foods, LLP" on Justia Law

Carlos Estrada, an Indiana resident, was arrested on February 2, 2023, after arranging the sale of 2,579 grams of heroin to an undercover officer in New Jersey. A search of his Indianapolis residence revealed an additional 371 grams of heroin, a digital scale, and a box containing six pounds of lactose, a cutting agent. Estrada committed this offense six months after being released from prison and starting supervised release for a 2019 heroin-distribution conspiracy conviction in the Southern District of New York.The United States District Court for the Southern District of Indiana accepted Estrada's guilty plea to one count of possessing with intent to distribute at least 100 grams of heroin. The court sentenced him to 87 months in prison, at the low end of the advisory Sentencing Guidelines range. Estrada appealed, arguing that the district court erred procedurally by not varying downward his criminal history category, which included points from a 2018 misdemeanor marijuana possession conviction.The United States Court of Appeals for the Seventh Circuit reviewed the case. Estrada contended that the district court did not adequately explain its decision and misapprehended its authority to depart downward. The appellate court found that the district court's explanation was sufficient, considering Estrada's extensive criminal history, including serious juvenile offenses and the fact that he committed the current offense while on supervised release. The court also determined that the district court did not err in its understanding of its authority to vary downward. Consequently, the Seventh Circuit affirmed the district court's sentence of 87 months in prison. View "United States v Estrada" on Justia Law

Dr. William Partin filed a lawsuit against Baptist Healthcare System, Inc. and Dr. Daniel Eichenberger after he resigned from his position. Partin alleged that Baptist and Eichenberger retaliated against him in violation of the Emergency Medical Treatment and Active Labor Act (EMTALA) and brought claims under Indiana law for breach of contract, tortious interference with contractual relations, and defamation. The dispute arose from Partin's treatment of a suicidal patient, J.C., in Baptist's emergency department, where Partin ordered procedures against J.C.'s will, leading to complaints from hospital staff.The United States District Court for the Southern District of Indiana granted summary judgment in favor of Baptist and Eichenberger. The court found that no reasonable jury could conclude that Partin engaged in EMTALA-protected activity or that he was retaliated against for such activity. The court also determined that Partin's breach of contract claim failed because the bylaws did not create a contractual relationship between Partin and Baptist, and his resignation was not under duress. Additionally, the court found no evidence to support Partin's claims of tortious interference with contract or defamation.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 Partin did not engage in EMTALA-protected activity and that his belief in reporting a potential EMTALA violation was not objectively reasonable. The court also agreed that the bylaws did not create a contract between Partin and Baptist and that Partin's resignation was voluntary. Furthermore, the court found that Baptist's actions were justified and not malicious, and that the statements made by Eichenberger and Marksbury were protected by qualified privilege and not made in bad faith. View "Partin v Baptist Healthcare System, Inc." on Justia Law

Leon Carter was charged by the State of Wisconsin with sexual assault, strangulation, and kidnapping. During his trial, the jury sent a note to the judge with a question, but the bailiff answered it without consulting the judge. The jury found Carter guilty on all counts. After learning of the bailiff’s response, Carter moved for a mistrial, which was denied.On direct appeal, Carter’s appellate counsel filed a no-merit brief, summarizing the record and explaining why potential legal arguments, including those related to the bailiff’s actions, lacked merit. The Wisconsin Court of Appeals agreed and affirmed the convictions, and the Wisconsin Supreme Court denied certiorari.Carter then sought federal habeas relief, asserting two violations: that the state appellate court denied him a meaningful appeal under Anders v. California, and that the state trial judge erred by not holding a hearing to investigate jury intrusion, contrary to Remmer v. United States. The district court rejected the Anders claim and did not consider the Remmer claim. Carter appealed to the United States Court of Appeals for the Seventh Circuit.The Seventh Circuit concluded that Carter’s Anders claim failed, as the Wisconsin Court of Appeals had adequately reviewed the record and briefs, ensuring his appeal was resolved on its merits. The court also found that Carter’s Remmer claim could not overcome the high hurdle set by the Antiterrorism and Effective Death Penalty Act (AEDPA), as the bailiff’s communication with the jury did not rise to the level of presumptive prejudice established in Remmer. Consequently, the Seventh Circuit affirmed the district court’s decision. View "Carter v. Tegels" on Justia Law