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

Several landowners in Indiana, who acquired their properties subject to agreements made in 1959, sought to enroll their land in a federal conservation program. During the process, a title examination revealed that Trunkline Gas Company held easements over their properties, allowing it to construct and maintain pipelines. The landowners contended that Trunkline’s easement was limited to a fixed 66-foot corridor along the existing pipeline, which had been installed in 1960. Trunkline, however, asserted that the original agreements granted it rights to lay additional pipelines anywhere on the properties and to alter the route of the existing pipeline.The landowners filed suit in the United States District Court for the Northern District of Indiana, seeking a declaration that Trunkline’s easement was fixed and limited in scope. Trunkline counterclaimed, seeking confirmation of its broader, unexercised rights. The district court divided the litigation into two phases and, in both, granted partial summary judgment in Trunkline’s favor. The court concluded that the 1959 agreements created a floating or blanket easement, meaning the location for future pipelines was not fixed, and that Indiana law did not allow unexercised, future easement rights to be fixed to a defined location.On appeal, the landowners asked the United States Court of Appeals for the Seventh Circuit to certify a question to the Indiana Supreme Court regarding the fixity of floating easements, or, alternatively, to reverse the district court. The Seventh Circuit declined to certify, finding Indiana law sufficiently clear that unexercised, future rights under a floating easement are not fixed. The court affirmed the district court’s summary judgment, holding that Trunkline’s unexercised easement rights remain unfixed under Indiana law. View "Close Armstrong, LLC v Trunkline Gas Company, LLC" on Justia Law

Three individuals entered an apartment in Plover, Wisconsin, and committed an armed robbery, physically assaulting the two residents and stealing electronics and guitars. Two of the robbers, Lyndell Dale and Archie Biddell, were apprehended shortly after and implicated Maurice Holt as the third participant. Initially, the victims identified Gosha, Holt’s nephew, as the third assailant, but later expressed uncertainty. Two days after the robbery, Holt sold some of the stolen guitars, using his real name. A search of Holt’s residence, which Gosha frequented, yielded additional stolen property. Holt denied involvement and claimed he was elsewhere during the crime.Holt was tried in Wisconsin state court on charges including armed robbery. The prosecution relied on the sale of stolen items, pretrial identifications by Dale and Biddell, and circumstantial evidence. Neither victim could positively identify Holt at trial. Holt’s defense was twofold: that Gosha was the third robber, and that Holt had an alibi. Holt’s counsel attempted to introduce photographs to support the defense theory, but the trial court excluded them as irrelevant and cumulative. Holt was convicted on all counts and sentenced to twelve years. He pursued post-conviction relief, arguing the exclusion of evidence and ineffective assistance of counsel. The state post-conviction court and the Wisconsin Court of Appeals denied his claims, and the Wisconsin Supreme Court declined review.Holt sought habeas relief in the United States District Court for the Western District of Wisconsin, which granted his petition. On appeal, the United States Court of Appeals for the Seventh Circuit reversed. The Seventh Circuit held that the Wisconsin Court of Appeals reasonably applied Supreme Court precedent in rejecting Holt’s constitutional claims regarding exclusion of evidence and ineffective assistance of counsel. The court concluded that any errors did not have a substantial and injurious effect on the verdict and did not warrant habeas relief. View "Holt v. Boughton" on Justia Law

A Polish citizen was approved for an immigrant visa in 2009 based on a petition filed by her U.S. citizen sister. While awaiting visa availability, she remained in the United States unlawfully for over a year, making her inadmissible and subject to a ten-year bar from reentering the country. In 2020, her mother, a lawful permanent resident, died. She then applied for a waiver of her inadmissibility, citing her mother’s death as the qualifying hardship, and sought relief under a statutory provision that allows certain applications to proceed despite the death of a qualifying relative.The United States Citizenship and Immigration Services (USCIS) denied her waiver application, explaining that the relevant policy only applies if the deceased relative had been the qualifying petitioner for the underlying visa, which in her case was her sister, not her mother. Attempts to reopen or reconsider the decision were also denied. She then sought relief in the United States District Court for the Northern District of Illinois, requesting a declaratory judgment on her eligibility and challenging the agency’s decision under the Administrative Procedure Act (APA). The district court dismissed her case for lack of subject-matter jurisdiction, finding that the relevant immigration statutes precluded judicial review of the agency’s waiver decisions.Upon appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The court held that the statute unequivocally bars judicial review of all agency decisions regarding waivers of inadmissibility, including eligibility determinations, and that such decisions are committed to agency discretion. The presumption of reviewability under the APA was rebutted by the statute's clear jurisdiction-stripping language. The court also publicly admonished the plaintiff’s attorney for including fictitious citations in the appellate brief but imposed no further sanctions. View "Dec v Mullin" on Justia Law

Paul Daugerdas was convicted in federal court for orchestrating a fraudulent tax shelter scheme that defrauded the U.S. Treasury of significant tax revenue. A jury found him guilty of conspiracy to defraud the IRS, mail fraud, client tax evasion, and obstructing the internal revenue laws. The federal district court sentenced him to 15 years in prison, ordered forfeiture of $164.7 million, and imposed $371 million in restitution, to be paid jointly and severally with co-conspirators. The criminal restitution order set a payment schedule of 10% of Daugerdas’s gross monthly income following his release from prison.After the United States Court of Appeals for the Second Circuit affirmed the convictions and sentence, the Internal Revenue Service, relying on 26 U.S.C. § 6201(a)(4)(A), assessed the same $371 million restitution as a civil tax liability, making the entire amount immediately due. The IRS also filed a notice of federal tax lien against Daugerdas’s property in Illinois. Daugerdas challenged the IRS’s authority to impose and collect restitution in this manner, particularly objecting to the acceleration of the payment schedule. The United States Tax Court upheld the IRS’s actions, ruling that the statutory provision authorized the IRS to assess and collect restitution for tax-related offenses, even when the underlying criminal conviction was under Title 18 rather than Title 26.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the Tax Court’s judgment de novo. The court held that 26 U.S.C. § 6201(a)(4)(A) empowers the IRS to assess and collect restitution ordered under 18 U.S.C. § 3556 for tax-related crimes, including those prosecuted under Title 18, and that the IRS is not bound by the payment schedule set by the criminal court. The Seventh Circuit affirmed the Tax Court’s judgment for the Commissioner. View "Daugerdas v CIR" on Justia Law

Law enforcement officers executed a search warrant for methamphetamine at a rural Wisconsin property, where they believed Ryan Steinhoff, suspected of violent criminal activity, was present. During the early morning search, Steinhoff was found in a camper and, after initially appearing to comply with police orders, was tackled by an officer. In the course of his restraint, Steinhoff sustained a head injury from a rifle barrel, which required stitches. Body-camera footage captured the incident, but it was unclear whether the head injury was caused intentionally or accidentally.Steinhoff filed a lawsuit under 42 U.S.C. § 1983 in the United States District Court for the Western District of Wisconsin, alleging that Detective Kowalczyk and Investigator Malovrh used excessive force in violation of the Fourth Amendment. The district court granted summary judgment to Captain Ramberg, as Steinhoff conceded no excessive force was used by him. The court denied summary judgment to Investigator Malovrh on the claim regarding kneeling during handcuffing, and a jury later found in Malovrh’s favor on that issue. The district court granted summary judgment and qualified immunity to Detective Kowalczyk regarding the tackle, finding no clearly established law prohibiting his actions. The court also granted summary judgment to Investigator Malovrh on the rifle strike, concluding no reasonable jury could find the strike intentional.The United States Court of Appeals for the Seventh Circuit affirmed qualified immunity for Detective Kowalczyk, holding that his actions during a high-risk drug raid did not violate clearly established law. However, the appellate court reversed summary judgment for Investigator Malovrh, finding factual disputes about whether the rifle strike was intentional. The court remanded for a jury to resolve those disputes, as a blow to the head with a rifle could constitute excessive force if intentional. View "Steinhoff v Malovrh" on Justia Law

The petitioner was convicted of first-degree intentional homicide and related charges after a shooting at the Luna Lounge in Appleton, Wisconsin. Video evidence showed several people fleeing the scene, including the petitioner’s brother. Police interviewed three eyewitnesses—Watou Lee, Mikey Thao, and Ryan Thao—shortly after the incident. These witnesses described the shooter but did not explicitly identify the petitioner. However, police later received statements from other witnesses implicating the petitioner. The State did not disclose the initial interviews with Watou, Mikey, and Ryan to the defense and eventually destroyed the recordings, citing the witnesses’ fears for their safety. The defense only learned of the destroyed interviews after the witnesses were reinterviewed and those statements were provided. The petitioner moved to dismiss the charges or, alternatively, to bar the witnesses’ testimony, arguing violations of his due process rights under Brady v. Maryland and the principles set forth in California v. Trombetta and Arizona v. Youngblood.The Wisconsin Circuit Court denied the Brady claim but agreed the destruction of evidence violated due process, barring the State from calling the three witnesses at trial, though permitting the defense to do so. The petitioner did not object to this remedy and ultimately did not call the witnesses. He was convicted by a jury, and his conviction and denial of post-conviction relief were affirmed by the Court of Appeals of Wisconsin, with the Wisconsin Supreme Court declining review.On federal habeas review, the United States District Court for the Eastern District of Wisconsin denied relief, holding that the state appellate court did not act contrary to or unreasonably apply clearly established federal law. The United States Court of Appeals for the Seventh Circuit affirmed, holding that the state court’s application of Brady, Trombetta, and Youngblood was not objectively unreasonable and that the selected remedy did not violate clearly established federal law. View "Lee v Mlodzik" on Justia Law

Marion Thomas was stopped by Chicago police officers after failing to signal a turn. During the stop, officers reported smelling marijuana coming from his vehicle. After Thomas partially rolled down his window and refused to comply with several commands, officers opened his door and removed him from the car. Thomas was handcuffed and his car was searched, revealing a marijuana cigarette and a tray. Thomas claimed the items did not belong to him and experienced a medical issue, after which he was taken to the hospital. He was cited for the traffic violation and marijuana possession.Following his arrest, Thomas filed suit in the United States District Court for the Northern District of Illinois against the officers and the City of Chicago, alleging illegal search, illegal seizure, false arrest under 42 U.S.C. § 1983, and malicious prosecution under state law. Some claims and defendants were dismissed at summary judgment. At trial, the jury found for the defendants. Thomas moved for a new trial, arguing that the jury instructions were erroneous, that an officer gave misleading testimony, and that a question about his criminal record was prejudicial. The district court denied his motion.The United States Court of Appeals for the Seventh Circuit reviewed the case. It held that the challenged jury instructions accurately stated the law, including the principle that probable cause to arrest for any crime defeats a false arrest claim. The court found no abuse of discretion regarding the officer’s testimony about a marijuana “grinder,” as there was no evidence of fraud or prejudice. The court also determined that the question about Thomas’s criminal record did not prejudice the jury, since the objection was sustained and no answer was given. The Seventh Circuit affirmed the district court’s judgment. View "Thomas v McAuliffe" on Justia Law

Law enforcement in southern Illinois identified multiple Snapchat accounts linked to the same person, who used these accounts to impersonate a female and solicit nude images from minor boys. The investigation revealed that the defendant, Adam Power, knew some victims through his work as a choir director, substitute teacher, and day camp employee. He was arrested after police searched his devices and social media accounts, uncovering evidence of extensive child exploitation.A federal grand jury indicted Power on thirty-four counts related to child pornography and sexual exploitation of minors. He pleaded guilty to all counts without a plea agreement. The United States District Court for the Central District of Illinois ensured that Power’s pleas were knowing and voluntary, and asked him to confirm the factual basis for each count. At sentencing, the court considered the presentence report and the applicable Sentencing Guidelines, ultimately imposing a 60-year prison sentence, significantly less than the calculated Guidelines range of 740 years. The court highlighted the seriousness of the offenses and the lack of meaningful mitigating circumstances.On appeal to the United States Court of Appeals for the Seventh Circuit, Power sought to vacate his guilty pleas to eight counts, arguing the district court lacked an adequate factual basis for those pleas. Alternatively, he challenged his sentence as substantively unreasonable. The Seventh Circuit reviewed the guilty plea issue for plain error and found that Power failed to show a reasonable probability that, but for any alleged errors, he would not have pleaded guilty. The court also upheld the substantive reasonableness of the sentence, rejecting Power’s arguments regarding de facto life imprisonment and sentencing disparities. The Seventh Circuit affirmed the judgment of the district court. View "USA v Power" on Justia Law

USAA Savings Bank closed Michael Goff’s credit card account, providing him with inconsistent explanations for its actions. Goff pursued arbitration under the arbitration agreement contained in his credit card contract, seeking actual and punitive damages. The agreement allowed the arbitrator to award punitive damages but explicitly required a post-award review of such damages, with procedural protections and a written, reasoned explanation, before any punitive damages award could become final.An arbitrator held an evidentiary hearing and determined that USAA had violated the Equal Credit Opportunity Act by failing to provide Goff with adequate notice upon closing his account. Despite finding that Goff suffered no actual damages, the arbitrator awarded $10,000 in punitive damages and over $77,000 in attorney’s fees. USAA requested the post-award review mandated by the agreement, but the arbitrator declined, citing American Arbitration Association rules, and finalized the award without conducting the review.USAA filed a motion in the United States District Court for the Northern District of Illinois, seeking to vacate the arbitral award on the ground that the arbitrator had exceeded her authority by disregarding the post-award review requirement. The district court acknowledged the arbitrator’s error but confirmed the award, concluding it nonetheless “drew from the essence of the arbitration agreement.” USAA appealed, and Goff sought sanctions.The United States Court of Appeals for the Seventh Circuit held that the arbitrator exceeded her authority by ignoring the arbitration agreement’s clear requirement for a post-award review of punitive damages. The court determined there was no “possible interpretive route” to support the arbitrator’s action, vacated the district court’s judgment, denied Goff’s motion for sanctions, and remanded with instructions to refer the matter back to the original arbitrator for proceedings consistent with the agreement. View "USAA Savings Bank v Goff" on Justia Law

The plaintiff, a woman in her early sixties, stopped working in August 2015 due to chronic back pain related to degenerative spinal and hip conditions. She had a history of mental health issues, including previous disability benefits for bipolar disorder, but her primary complaint at the time was physical pain. After her pain worsened, she sought both physical and psychological treatment. Her treatment included various forms of physical therapy and pain management, as well as psychotherapy with a clinical psychologist specializing in pain management. This psychologist, after several months, opined that the plaintiff had significant mental limitations affecting her ability to perform complex work tasks. However, other medical experts who evaluated her found only mild mental limitations.The plaintiff applied for Social Security disability benefits in September 2015, alleging disability from August 2015. Her application was denied, after which the United States District Court for the Eastern District of Wisconsin remanded the case for further proceedings. Following a second remand from the Social Security Appeals Council, an Administrative Law Judge (ALJ) found that the plaintiff was disabled beginning in September 2017, but not before that date. The ALJ determined that her mental impairments prior to September 2017 were non-severe, giving little weight to her treating psychologist’s opinion.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether the ALJ erred in discounting the treating psychologist’s opinion and in finding the plaintiff’s mental limitations non-severe. The Seventh Circuit held that the ALJ appropriately considered the relevant regulatory factors, offered adequate reasons supported by the record for discounting the opinion, and that substantial evidence supported the ALJ’s findings. The Seventh Circuit therefore affirmed the judgment of the district court, upholding the denial of benefits for the period before September 1, 2017. View "Yokosh v Bisignano" on Justia Law