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

The case revolves around Denny Anderson, who was sentenced in 2012 for possessing a firearm as a felon, after shooting at a man and using racial slurs. The maximum penalty for the illegal-possession offense is typically 10 years, but the Armed Career Criminal Act (ACCA) mandates a 15-year minimum sentence for anyone with three prior convictions for a "violent felony." Anderson was sentenced to an agreed-upon term of 180 months (15 years) in prison. He was resentenced in 2021, following a successful habeas petition he filed in 2013. The government maintained that he was subject to a 15-year minimum sentence due to his prior convictions.The district court agreed that Anderson's convictions for burglary, robbery, and Florida aggravated assault qualified as violent felonies, triggering a 15-year minimum sentence. Anderson did not object to his designation as an armed career criminal. The court then resentenced him to 188 months in prison.The United States Court of Appeals for the Seventh Circuit reviewed the case and concluded that Anderson’s Florida conviction in 2001 is not a predicate violent felony and that the government may not substitute one of Anderson’s other prior convictions as an alternative predicate offense. Because Anderson does not have three predicate convictions, the ACCA enhancement was improper. The court vacated the judgment and remanded the case for resentencing. View "United States v. Anderson" on Justia Law

The case revolves around John Sabo, who was sentenced to a probation term that exceeded the maximum limit set by Wisconsin law. After his probation should have ended, he was imprisoned for violating its conditions. Sabo sued two groups of defendants under 42 U.S.C. § 1983: Sheri Hicks and Debra Haley, officials from the Wisconsin Department of Corrections who failed to correct his unlawful probation term, and Megan Erickson and Barb Hanson, the probation officers who enforced it. Sabo alleged that all four defendants violated his right of due process and showed deliberate indifference to his unjustified imprisonment.The district court dismissed all claims against Hicks and Haley, and most against Erickson and Hanson, before entering summary judgment for Erickson and Hanson on the deliberate indifference and unreasonable seizure claims. Sabo appealed the dismissal of his claims against Hicks and Haley.The United States Court of Appeals for the Seventh Circuit found that Sabo's complaint stated claims of deliberate indifference against Hicks and Haley. The court held that assuming all facts and inferences in Sabo’s favor, the record did not compel a finding of qualified immunity for Hicks and Haley. Therefore, the court vacated the district court’s dismissal of those claims. However, the court affirmed the district court's decision in all other respects, including the summary judgment for Erickson and Hanson on the deliberate indifference and unreasonable seizure claims. View "Sabo v. Erickson" on Justia Law

A German citizen, Asli Baz, filed a suit under the International Child Abduction Remedies Act (ICARA) to compel Anthony Patterson, a U.S. citizen, to return their six-year-old son, A.P., from Illinois to Germany. The couple had previously lived together in Chicago, but after their relationship ended, they continued to cohabit and share custody of their son. Baz later moved to Germany with A.P., with Patterson's consent. However, Patterson later took A.P. from his school in Germany and brought him back to the U.S., refusing to return him to Germany.The U.S. District Court for the Northern District of Illinois found that A.P.’s habitual residence at the time he was retained was in Germany, where he had lived with Baz for over a year, and that the retention in Illinois violated Baz’s rights of custody under German law. It thus granted Baz’s petition and ordered the child’s return. Patterson appealed, challenging both the jurisdiction of the district court and its rulings on the merits of the petition.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court rejected Patterson's argument that the district court lacked jurisdiction due to a provision in the Illinois Allocation Judgment, which stated that the Circuit Court of the State of Illinois had exclusive jurisdiction over the case. The court also found that the district court did not err in determining that A.P.'s habitual residence was Germany, and that Baz was exercising her rights of custody at the time of the retention. The court emphasized that its decision did not touch on any matters of custody, which should be resolved by the courts of the child's habitual residence. View "Baz v. Patterson" on Justia Law

The case involves Thomas Brooks, II, who was charged with and pleaded guilty to possessing a firearm as a convicted felon. The incident occurred when Brooks was leaving an apartment complex and saw police officers waiting outside to arrest him due to several outstanding warrants. Brooks began to run and during the chase, he threw a loaded firearm and an extended magazine into the grass. The police apprehended him and retrieved the discarded items.Prior to his sentencing, the United States Probation Office prepared a Presentence Investigation Report, which calculated an offense level of 19 and a criminal history category VI, yielding an advisory guidelines range of 63 to 78 months in prison. Brooks argued that the reckless endangerment enhancement should not apply because the government could not demonstrate that his actions created a substantial risk of serious bodily harm. The district court disagreed and applied the two-level reckless endangerment enhancement.On appeal to the United States Court of Appeals for the Seventh Circuit, Brooks challenged his sentence on three grounds: the application of a two-level enhancement for reckless endangerment while fleeing from police, the district court's failure to address one of his key mitigation arguments, and the district court's decision to sentence him above the Guidelines range. The Court of Appeals affirmed the district court's decision, finding that the district court did not err in its application of the enhancement, adequately addressed Brooks's mitigation arguments, and provided a sufficient explanation for the above-Guidelines sentence. View "United States v. Brooks" on Justia Law

Monica Rongere, a former Diversity Procurement Officer for the City of Rockford, Illinois, sued the city after her employment was terminated. Rongere claimed that she was overworked and underpaid compared to her male colleagues, and that her termination was due to her complaints about this disparity. She brought claims under the Equal Pay Act, Title VII of the Civil Rights Act of 1964, the Illinois Human Rights Act, the Illinois Whistleblower Act, and Illinois common law, alleging equal pay, sex discrimination, hostile work environment, and retaliation.The district court ruled in favor of the City on the Equal Pay Act, Title VII, and Illinois Human Rights Act claims, and relinquished jurisdiction over the remaining state-law claims. Rongere appealed this decision.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court found that Rongere failed to identify adequate comparators for her equal pay and sex discrimination claims, did not show that she engaged in protected activity based on an objectively reasonable belief for her retaliation claim, did not present sufficient evidence of a hostile work environment, and did not explain how the district court abused its discretion in relinquishing jurisdiction over the remaining claims. The court also found that Rongere did not hold an objectively reasonable belief that the City paid male employees more than female employees for the same work, which was necessary for her retaliation claims. View "Rongere v. City of Rockford" on Justia Law

This case involves a dozen gas stations in the Green Bay, Wisconsin area, who alleged that Costco Wholesale Corporation violated a Wisconsin law prohibiting the sale of gasoline below a statutorily defined cost. The plaintiffs sought an injunction to prevent Costco from selling gasoline below that level and damages of over half a million dollars each. Costco argued that it lowered its prices to match a competitor's price, which the statute allows, and that the plaintiffs failed to establish the causal element of the statutory claim.The case was initially heard in the United States District Court for the Eastern District of Wisconsin, which sided with Costco and awarded it summary judgment. The plaintiffs appealed this decision, challenging both the summary judgment and an evidentiary ruling made earlier in the proceedings.The United States Court of Appeals for the Seventh Circuit affirmed the lower court's decision. The court found that for 238 of the 256 days in question, Costco was immune from liability under the "meeting competition" exception in the Wisconsin law. For the remaining 18 days, the court found that the plaintiffs failed to show that they were injured or threatened with injury as a result of Costco's actions. The court also upheld the lower court's denial of the plaintiffs' request to supplement their expert report. View "Pit Row, Inc. v. Costco Wholesale Corporation" on Justia Law

Shamar Betts was indicted for inciting a riot in violation of the Anti-Riot Act, 18 U.S.C. § 2101, after he posted a flyer on Facebook calling for a riot at a mall in Champaign, Illinois. The riot resulted in damage to several businesses. Betts moved to dismiss the indictment, arguing that the Anti-Riot Act was overbroad and violated the First Amendment, but the district court denied his motion. Betts then pled guilty and was sentenced to 48 months’ imprisonment and ordered to pay $1,686,170.30 in restitution to 35 businesses under the Mandatory Victims Restitution Act (MVRA), 18 U.S.C. § 3663A.On appeal, Betts challenged the constitutionality of the Anti-Riot Act, the application of a sentencing guideline by analogy, and the district court's order of restitution. The Court of Appeals for the Seventh Circuit upheld the constitutionality of the Anti-Riot Act, finding no compelling reason to overrule its previous decision in United States v. Dellinger, which upheld the Act. The court also found no error in the district court's application of a sentencing guideline by analogy to the Anti-Riot Act.However, the court agreed with Betts's argument that the government failed to meet its burden of showing that he directly and proximately caused damages to all businesses included in the restitution order. The court vacated the sentence with regard to the amount of restitution ordered and remanded the case for the limited purpose of reconsidering the amount of restitution. View "United States v. Betts" on Justia Law

The Greenwald Family Limited Partnership, a landowner in the Village of Mukwonago, Wisconsin, had a longstanding positive relationship with the Village, collaborating on several development projects. However, this relationship soured after a failed land deal in 2014 and several other conflicts. The Partnership sued the Village, alleging that it had been irrationally singled out for unfavorable treatment, violating its Fourteenth Amendment rights. The Partnership pointed to several adverse municipal decisions, focusing primarily on the failed land deal and a new road that was rerouted from the Partnership’s property.The case was initially filed in state court but was later removed to federal court. The district court concluded that the Village had a rational basis for its actions regarding the failed land deal, the new road, and other decisions affecting the Partnership’s properties. The court entered summary judgment in favor of the Village and relinquished jurisdiction over the state-law claims.The case was then brought before the United States Court of Appeals for the Seventh Circuit. The court affirmed the district court's decision, stating that the Partnership had failed to show that the Village’s actions lacked any conceivable rational basis. The court found that the Village’s decisions were rationally related to its legitimate interests in promoting its land-use objectives and protecting public funds. The court concluded that the Partnership was a disappointed landowner, but not a victim of unconstitutional discrimination. View "Greenwald Family Limited Partnership v. Village of Mukwonago" on Justia Law

In 2014, Allan Kustok was convicted of murdering his wife, Anita “Jeannie” Kustok. Kustok claimed that his wife had accidentally shot herself or committed suicide. However, the state argued that Kustok had shot his wife and presented evidence of his extramarital affairs, his purchase of the gun used in the shooting, and inconsistencies in his account of the incident. After his conviction, Kustok sought a new trial, arguing that new evidence cast doubt on the testimony of an expert witness for the prosecution. His motion was denied, and his subsequent appeals were unsuccessful.Kustok then filed a state postconviction petition, arguing that his trial counsel had been ineffective for failing to discover exculpatory evidence before the trial. The state courts found that Kustok had waived this claim by not raising it on direct appeal. Kustok then filed a federal habeas corpus petition, presenting the same claim. The district court held that the state-court waiver meant Kustok had procedurally defaulted the claim for federal-court purposes.The United States Court of Appeals for the Seventh Circuit agreed that Kustok had procedurally defaulted his claim. The court also concluded that Kustok did not qualify for any exception to the procedural-default rules, and therefore affirmed the dismissal of his petition. The court found that even if Kustok's lawyer had introduced evidence about a certain soot stain at trial, it was not substantially likely that the jury would have returned a different verdict. View "Kustok v. Mitchell" on Justia Law

The case involves Quintin Scott, a former pretrial detainee at the Cook County Jail, who filed a class action lawsuit against Cook County and its sheriff. Scott alleged that the county provided him and other pretrial detainees with inadequate dental care, violating the Fourteenth Amendment. The district court refused to certify the class, and Scott settled his individual claim but reserved his right to appeal the class ruling and to seek an incentive award for his role as the named plaintiff.The County argued that Scott lacked standing to pursue the class aspects of the case, contending that he no longer had a live interest in the litigation and that courts were forbidden from granting incentive awards. The United States Court of Appeals for the Seventh Circuit disagreed, finding that Scott had standing and that incentive awards were permissible. The court also concluded that the district court had abused its discretion in denying class certification, as it had misapplied a previous decision and used too strict a standard.The Court of Appeals vacated the district court's order and remanded the case for further proceedings, noting that the district court was free to revise the class definition as needed to address any overbreadth issues. The court also noted that the district court had not addressed whether the proposed class met the requirements of numerosity and adequacy of representation, which must be satisfied before the class can be certified. View "Scott v. Dart" on Justia Law