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

Miguel Salinas-Salcedo pled guilty to conspiracy to commit money laundering, admitting that over a two-and-a-half-year period he helped Mexican drug cartels launder nearly $3 million through 24 transactions. His role was to connect cartel members with individuals in the United States who could deposit and transfer large sums of cash into bank accounts without attracting government attention. Salinas-Salcedo acted as the intermediary, relaying instructions, authenticating transactions, and confirming deposits, ultimately earning over $44,000 in commissions. Unbeknownst to him, some of his contacts were undercover law enforcement agents.The United States District Court for the Northern District of Illinois, Eastern Division, sentenced Salinas-Salcedo after applying a four-level enhancement under U.S.S.G. §2S1.1(b)(2)(C) for being “in the business of laundering funds.” Salinas-Salcedo argued that he was merely a “middleman” and not in the business of laundering funds as contemplated by the guidelines. The district court rejected this argument, finding his participation integral to the conspiracy and imposing a below-guidelines sentence of 96 months.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s interpretation of the Sentencing Guidelines de novo, as the facts were undisputed. The appellate court held that Salinas-Salcedo’s conduct fell squarely within the scope of the “business of laundering funds” enhancement, as defined by the guidelines and relevant statutes. The court found that his regular, multi-year involvement, substantial earnings, and discussions with undercover agents satisfied the enhancement’s factors. The Seventh Circuit also rejected Salinas-Salcedo’s claim of procedural error, concluding that the district court adequately addressed his objections. The judgment was affirmed. View "United States v. Salinas-Salcedo" on Justia Law

Christopher Hill was charged with possession with intent to distribute methamphetamine after law enforcement, acting on information from a confidential informant, arranged a controlled purchase and arrested him en route to the meeting location. During the arrest, officers recovered approximately 100 grams of methamphetamine, a handgun, other drugs, and cash. Hill claimed the drugs were for personal use. He was indicted four days later and the case proceeded to a jury trial.During jury selection in the United States District Court for the Southern District of Indiana, two prospective jurors with family ties to law enforcement were questioned. Juror 53, who had been married to a sheriff’s officer and knew an officer involved in the case, expressed concerns about impartiality and was excused for cause. Juror 55, whose sons were in law enforcement, initially expressed concern about her ability to be impartial but ultimately stated she could judge the case based on the evidence and give equal weight to all testimony. The district court denied the motion to strike Juror 55 for cause, and she served on the jury. The jury found Hill guilty, and he was sentenced to 188 months in prison.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether Hill’s right to an impartial jury was violated by the district court’s decision to seat Juror 55. Applying an abuse of discretion standard, the appellate court held that the district court did not err in crediting Juror 55’s assurances of impartiality, distinguishing her responses from those of Juror 53. The Seventh Circuit concluded that the trial judge acted within her discretion and affirmed Hill’s conviction. View "United States v. Hill" on Justia Law

A professional musician employed by the Indianapolis Symphony Orchestra was placed on furlough in March 2020 due to the COVID-19 pandemic. In December 2020, she developed severe symptoms, including dizziness and tinnitus, after contracting COVID-19, which rendered her unable to perform. She was rehired by the orchestra in September 2021 but soon went on sick leave because her symptoms persisted. In February 2022, she applied for long-term disability benefits under her employer’s group policy, stating that her last day of work was in March 2020 and that her disability began in December 2020.The insurance company denied her claim, reasoning that she was not an “active, full-time employee” at the time her disability began, as required by the policy. The claimant appealed internally, submitting new information that she had returned to work in September 2021 but was again unable to perform due to her illness. The insurer treated this as a fundamentally different claim, maintaining its denial and advising her to file a new application based on the later date.She then filed suit under the Employee Retirement Income Security Act (ERISA) in the United States District Court for the Southern District of Indiana. Both parties moved for summary judgment, and the district court granted summary judgment in favor of the insurer, finding that she was not eligible for benefits based on her initial application and that her new information constituted a separate claim for a different loss.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court’s judgment. The court held that the claimant was not eligible for benefits for a disability beginning in December 2020, and that her subsequent information regarding a September 2021 onset constituted a new claim, requiring exhaustion of administrative remedies before judicial review. View "Moratz v. Reliance Standard Life Insurance Co." on Justia Law

Three Illinois residents who hold concealed carry licenses challenged a provision of the Illinois Firearm Concealed Carry Act that prohibits carrying loaded and accessible firearms on public transportation, such as buses and trains, with exceptions for unloaded and properly stored firearms. The plaintiffs argued that this restriction violated their Second Amendment rights, as they wished to carry firearms for self-defense while using public transit but refrained from doing so due to the law’s threat of arrest and prosecution.The case was first heard in the United States District Court for the Northern District of Illinois, Western Division. The district court found that the plaintiffs had standing, as they faced a credible threat of prosecution under the challenged statute. On the merits, the district court applied the Supreme Court’s test from New York State Rifle & Pistol Ass’n, Inc. v. Bruen and concluded that the public transit firearm restriction was not sufficiently supported by the nation’s historical tradition of firearm regulation. The court granted summary judgment for the plaintiffs, declaring the restriction unconstitutional as applied to them.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision de novo. The Seventh Circuit held that Illinois’s restriction on carrying loaded and accessible firearms on public transportation is consistent with the Second Amendment, as it fits within a longstanding tradition of regulating firearms in sensitive and crowded, confined places. The court found that such regulations are analogous to historical restrictions in places like schools, legislative assemblies, and other crowded venues, and that the temporary disarmament required by the law is justified by public safety concerns unique to public transit. The Seventh Circuit reversed the district court’s judgment and remanded the case for further proceedings. View "Schoenthal v. O'Neill Burke" on Justia Law

A special education teacher with a long and distinguished career in an Illinois public school district was involuntarily transferred from one elementary school to another at age 52. After the transfer, she alleged that she was subjected to a hostile work environment at her new school. She claimed that she was assigned a disproportionate number of challenging students, unfairly criticized, denied adequate classroom support, and intimidated by an administrator. She believed these actions were motivated by her age, although she acknowledged that no one made any explicit age-related remarks.After she filed a complaint under the Age Discrimination in Employment Act (ADEA), the United States District Court for the Central District of Illinois granted summary judgment in favor of the school district. The district court found that she had not produced evidence from which a reasonable juror could conclude that the alleged harassment was either objectively hostile or based on her age.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the grant of summary judgment de novo. The appellate court assumed, without definitively deciding, that hostile work environment claims are cognizable under the ADEA. However, it held that the teacher failed to present sufficient evidence that any of the conduct she experienced was motivated by age-based animus. The court found her assertions to be speculative and unsupported by direct or circumstantial evidence. As a result, the Seventh Circuit affirmed the district court’s judgment, holding that there was no reasonable basis to infer age-based workplace harassment under the ADEA. View "Blumenshine v. Bloomington School District No. 87" on Justia Law

Cordell Sanders, an inmate at Pontiac Correctional Center, suffered from serious mental health issues and spent over eight years in segregation housing due to multiple disciplinary infractions. He received mental health services from various providers employed by Wexford Health Sources, the prison’s contracted healthcare provider. Sanders alleged that these providers were deliberately indifferent to his mental health needs, offering inadequate treatment and failing to advocate for him during disciplinary proceedings. He also claimed that Wexford maintained a widespread practice of denying mental health care until inmates were in crisis and failed to implement policies guiding provider participation in disciplinary hearings.The United States District Court for the Central District of Illinois granted summary judgment in favor of all defendants. The court found that Sanders had not presented sufficient evidence to support his claims of deliberate indifference or to establish a Monell claim against Wexford. Sanders appealed this decision, arguing that the providers’ treatment was ineffective and that Wexford’s practices and lack of policy amounted to constitutional violations.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s summary judgment order de novo. The appellate court held that Sanders failed to provide evidence from which a reasonable jury could find that the providers’ conduct constituted deliberate indifference under the Eighth Amendment. The court emphasized the lack of expert testimony regarding the effectiveness of Sanders’s treatment and found no substantial departure from professional standards. Regarding Wexford, the court concluded that Sanders did not demonstrate a widespread practice of denying care or that the absence of a more detailed policy caused constitutional harm. The Seventh Circuit affirmed the district court’s grant of summary judgment for all defendants. View "Sanders v. Moss" on Justia Law

Lauren Richwine, through her business Death Done Differently, provides services as a “death doula,” assisting clients and their families with end-of-life planning, emotional support, and guidance on funeral arrangements. Richwine is not a licensed funeral director, and her website notes that her services are performed under the supervision of a licensed funeral director. In 2021, a complaint was filed with the Indiana Public Licensing Agency alleging that Richwine was practicing funeral services without a license. Following an investigation, the Indiana Attorney General sought a cease-and-desist order from the State Board of Funeral and Cemetery Service, which was approved. The order prohibited Richwine and her company from advertising or providing certain services related to funeral planning, community death care, and support with funeral homes.After the cease-and-desist order was issued, Richwine and Death Done Differently filed suit in the United States District Court for the Northern District of Indiana, Fort Wayne Division, arguing that enforcement of the Indiana statute against them would violate their First Amendment rights. The district court granted a preliminary injunction, enjoining enforcement of the statute against the plaintiffs. The defendants appealed, arguing that the plaintiffs had waived their rights by signing the cease-and-desist agreement and that federal abstention doctrine barred the suit. The district court rejected these arguments, finding no clear and unmistakable waiver of federal rights and no ongoing state proceeding that would justify abstention.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision. The Seventh Circuit held that the Indiana statute, as applied to Richwine and Death Done Differently, burdens substantially more speech than necessary to further the state’s interests in public health, safety, and consumer protection. The court found that the statute’s restrictions on the plaintiffs’ speech and advertising likely violate the First Amendment. The Seventh Circuit affirmed the district court’s preliminary injunction and remanded for further proceedings. View "Richwine v. Matuszak" on Justia Law

James Weiss owned a company that manufactured sweepstakes machines, which in 2018 operated in a legal gray area under Illinois law. Seeking to secure favorable legislation, Weiss arranged for his company to make monthly payments to a lobbying firm owned by State Representative Luis Arroyo, who then became a vocal advocate for legalizing sweepstakes machines. After initial legislative efforts failed, Weiss and Arroyo sought to amend existing gaming legislation by enlisting the support of State Senator Terrance Link. Unbeknownst to them, Link was cooperating with federal authorities. During meetings, Arroyo assured Link he would be compensated for his support, and Weiss’s company provided checks intended for Link under a fictitious name created by the FBI. Weiss was later stopped by FBI agents, interviewed without Miranda warnings, and made false statements during the encounter.The United States District Court for the Northern District of Illinois, Eastern Division, denied Weiss’s pretrial motions to suppress his statements to the FBI and to exclude Arroyo’s recorded statements. At trial, the jury heard evidence of the bribery scheme, including testimony from Link and federal agents, and found Weiss guilty on all charges after deliberation. The district court sentenced Weiss to 66 months’ imprisonment, exceeding the calculated guidelines range, and declined to delay sentencing for anticipated changes to the Sentencing Guidelines.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed Weiss’s challenges to the admission of his statements, the admission of Arroyo’s statements as coconspirator statements, the jury instructions regarding “official acts,” and the sentence imposed. The Seventh Circuit held that Weiss was not in custody for Miranda purposes during the FBI interview, the district court did not err in admitting Arroyo’s statements, the jury instructions did not constitute plain error, and the sentence was both procedurally and substantively reasonable. The court affirmed the district court’s judgment in all respects. View "United States v. Weiss" on Justia Law

Dr. Padma Rao brought a defamation suit against JP Morgan Chase Bank and its employee, Keifer Krause, after Krause informed the administrator of her late mother’s estate that Rao, acting under a power of attorney, had designated herself as the payable on death (POD) beneficiary of her mother’s accounts. This statement led the estate administrator to accuse Rao of fraud and breach of fiduciary duty in probate court. The dispute centered on whether Rao had improperly used her authority to benefit herself, which would be illegal under Illinois law.The case was initially filed in Illinois state court, but Chase removed it to the United States District Court for the Northern District of Illinois before any defendant was served, invoking “snap removal.” The district court dismissed all claims except for defamation per se. On summary judgment, the court ruled in favor of the defendants, finding that Krause’s statements were not defamatory, could be innocently construed, and were protected by qualified privilege. Rao appealed both the dismissal of her consumer fraud claim and the grant of summary judgment on her defamation claim.The United States Court of Appeals for the Seventh Circuit first addressed jurisdiction, dismissing Krause as a party to preserve diversity jurisdiction. The court affirmed the dismissal of Rao’s consumer fraud claim, finding she had not alleged unauthorized disclosure of personal information. However, it reversed the summary judgment on the defamation per se claim against Chase, holding that Krause’s statements could not be innocently construed and that a qualified privilege did not apply, given evidence of possible recklessness. The case was remanded for a jury to determine whether the statements were understood as defamatory. View "Padma Rao v J.P. Morgan Chase Bank, N.A." on Justia Law

Earl Miller, who owned and operated several real estate investment companies under the 5 Star name, was responsible for soliciting funds from investors, primarily in the Amish community, with promises that their money would be used exclusively for real estate ventures. After becoming sole owner in 2014, Miller diverted substantial investor funds for personal use, unauthorized business ventures, and payments to friends’ companies, all in violation of the investment agreements. He also misled investors about the nature and use of their funds, including issuing false statements about new business activities. The scheme continued even as the business faltered, and Miller ultimately filed for bankruptcy.A federal grand jury in the Northern District of Indiana indicted Miller on multiple counts, including wire fraud and securities fraud. At trial, the government presented evidence, including testimony from an FBI forensic accountant, showing that Miller misappropriated approximately $4.5 million. The jury convicted Miller on one count of securities fraud and five counts of wire fraud, acquitting him on one wire fraud count and a bankruptcy-related charge. The United States District Court for the Northern District of Indiana sentenced Miller to 97 months’ imprisonment, applying an 18-level sentencing enhancement based on a $4.5 million intended loss, and ordered $2.3 million in restitution to victims.The United States Court of Appeals for the Seventh Circuit reviewed Miller’s appeal, in which he challenged the district court’s loss and restitution calculations. The Seventh Circuit held that the district court reasonably estimated the intended loss at $4.5 million, as this amount reflected the funds Miller placed at risk through his fraudulent scheme, regardless of when the investments were made. The court also upheld the restitution award, finding it properly included all victims harmed by the overall scheme. The Seventh Circuit affirmed the district court’s judgment. View "USA v Miller" on Justia Law