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

Donald Pierce was convicted of multiple counts of child molestation and of being a repeat sexual offender. The case revolved around the testimonies of the victim and several adults who had been told about the incidents. Pierce's lawyer did not object to the sequence of these testimonies, which violated an Indiana evidentiary rule. Pierce later petitioned for post-conviction relief, arguing that his lawyer's failure to object meant he was deprived of constitutionally adequate representation. This was denied by the Indiana Court of Appeals, which found that the lawyer's failure to object was strategic and did not constitute constitutionally deficient performance. Pierce then sought habeas relief, alleging the state appellate court had unreasonably applied Supreme Court precedent and made an unreasonable fact determination. However, the United States Court of Appeals for the Seventh Circuit affirmed the previous decision, finding that the state court did not unreasonably apply the precedent and its fact determination was not unreasonable. View "Pierce v. Vanihel" on Justia Law

In this case, the United States Court of Appeals for the Seventh Circuit addressed a dispute involving the owners of two parcels of real estate in Chicago who contended that banks tried to collect notes and mortgages that belonged to different financial institutions. The state judiciary had ruled that the banks were entitled to foreclose on both parcels, but the properties had not yet been sold and no final judgments defining the debt were in place. The plaintiffs attempted to initiate federal litigation under the holding of Exxon Mobil Corp. v. Saudi Basic Industries Corp., arguing that their case was still pending. However, the district court dismissed the case, citing the Rooker-Feldman doctrine, which states that only the Supreme Court of the United States can review the judgments of state courts in civil suits.The Appeals court held that the application of the Rooker-Feldman doctrine was incorrect in this case because the foreclosure litigation in Illinois was not yet "final". According to the court, the foreclosure process in Illinois continues until the property is sold, the sale is confirmed, and the court either enters a deficiency judgment or distributes the surplus. Since these steps had not occurred, the plaintiffs had not yet "lost the war", and thus parallel state and federal litigation could be pursued as per Exxon Mobil Corp. v. Saudi Basic Industries Corp.However, by the time the district court dismissed this suit, the state litigation about one parcel was over because a sale had occurred and been confirmed, and by the time the Appeals court heard oral argument that was true for the second parcel as well. The Appeals court stated that Illinois law forbids sequential litigation about the same claim even when the plaintiff in the second case offers novel arguments. The court found that the plaintiffs could have presented their constitutional arguments in the state court system and were not free to shift what is effectively an appellate argument to a different judicial system.The court also noted that Joel Chupack, the lead defendant, was the trial judge in the state case and was not a party to either state case. He did not claim the benefit of preclusion. Judge Chupack was found to be entitled to absolute immunity from damages, as he acted in a judicial capacity.The judgment of the district court was modified to reflect a dismissal with prejudice rather than a dismissal for lack of jurisdiction, and as so modified it was affirmed. View "Bryant v. Chupack" on Justia Law

This case involves a federal habeas corpus petition by Darnell Dixon, who was convicted of home invasion and murder by an Illinois state court and sentenced to life imprisonment. Dixon's habeas petition primarily focused on claims of actual innocence and prosecutorial misconduct. The United States Court of Appeals for the Seventh Circuit affirmed the denial of his habeas petition by the United States District Court for the Northern District of Illinois.The case involved a series of events including a drug-related robbery and subsequent murders. Dixon and Eugene Langston were implicated in the murders, with Langston identified in a police lineup by a witness, Horace Chandler. However, Chandler later recanted this identification. The state's case against Dixon relied heavily on a confession that Dixon later claimed was false. Dixon's confession and Chandler's identification of Langston were central to the state's theory of accomplice liability, arguing that Dixon was accountable for Langston's acts.In his habeas petition, Dixon argued that he was denied due process when the trial court excluded evidence that charges against his alleged accomplice, Langston, were dismissed. He also asserted that his trial counsel was ineffective for failing to object to the exclusion of that evidence. Furthermore, Dixon claimed that the state committed prosecutorial misconduct by presenting conflicting positions regarding Langston's involvement in the murders at trial and during post-conviction proceedings.However, the Seventh Circuit found that Dixon's claim of actual innocence, based on the state's post-conviction contention that Langston's involvement was irrelevant and evidence of abusive and perjurious conduct by the case's police detective, did not meet the high standard required to conclusively prove his innocence. The Seventh Circuit also rejected Dixon's arguments of prosecutorial misconduct and ineffective assistance of counsel, finding no clear error in the district court's factual findings on these issues. View "Darnell Dixon v. Tarry Williams" on Justia Law

In an appeal from the United States District Court for the Northern District of Indiana, the United States Court of Appeals for the Seventh Circuit reviewed a case concerning Adam Tyrale Williams Jr.'s ongoing effort to reduce his sentences for crack-cocaine offenses. Williams was convicted in 2001 of various drug-related offenses, and over the years, he sought sentence reductions based on retroactive amendments to the guidelines and, most recently, the First Step Act of 2018. The district court denied Williams's most recent application for sentence reduction, but the appellate court vacated the decision because the district court failed to calculate the amended statutory sentencing ranges applicable to Williams's convictions. Upon remand, Williams further emphasized changes to his record and conditions of confinement that occurred after the order was vacated. However, the district court again denied Williams's request shortly after receiving the updated motion. The appellate court found that the district court's reliance on its previous reasoning and failure to adequately explain its decision was an abuse of discretion. Thus, the appellate court vacated the judgment and remanded for further proceedings, indicating that a more complete explanation from the district court was necessary given the changes in law and facts relevant to the case. View "USA v. Williams" on Justia Law

Adrian L. Johnson was pulled over by a Deputy Sheriff for driving with a suspended license. The officer's trained dog indicated the presence of a controlled substance in Johnson's car, leading to a search of the vehicle. The officer found drugs, drug paraphernalia, and two handguns. Johnson was subsequently charged with possession of drugs with intent to distribute and possession of a firearm in furtherance of a drug trafficking crime. He moved to suppress all evidence, arguing that the search of his car violated his Fourth Amendment rights. The district court denied the motion, and Johnson pled guilty, reserving his right to appeal the suppression ruling. The United States Court of Appeals for the Seventh Circuit agreed with the district court, holding that the officer did not unconstitutionally prolong the stop to conduct the dog sniff, and that the subsequent search of Johnson's car did not violate the Fourth Amendment. The officer had probable cause to search the car because the dog's alerts indicated the presence of contraband. Therefore, the judgment of the district court was affirmed. View "USA v. Johnson" on Justia Law

This case involves a group of plaintiffs who were minors at the time their guardians purchased and activated DNA test kits from Ancestry.com. The plaintiffs, through their guardians, provided their DNA samples to Ancestry.com for genetic testing and analysis. The plaintiffs later sued Ancestry.com, alleging that the company violated their privacy rights by disclosing their confidential genetic information to another business. Ancestry.com moved to compel arbitration based on a clause in its Terms & Conditions agreement, which the plaintiffs' guardians had agreed to when they purchased and activated the test kits.The United States Court of Appeals for the Seventh Circuit, applying Illinois law, held that the plaintiffs were not bound to arbitrate their claims under the agreement between their guardians and Ancestry.com. The court reasoned that the plaintiffs neither signed the agreement nor created Ancestry.com accounts, and did not independently engage with Ancestry.com's services. Furthermore, the court refused to bind the plaintiffs to the agreement based on equitable principles, including the doctrine of direct benefits estoppel. The court noted that while the plaintiffs theoretically could benefit from Ancestry.com's services, there were no allegations that the plaintiffs had actually accessed their DNA test results.The court therefore affirmed the district court's decision denying Ancestry.com's motion to compel arbitration. The court's holding clarified that under Illinois law, a minor cannot be bound to an arbitration agreement that their guardian agreed to on their behalf, unless the minor independently engaged with the services provided under the agreement or directly benefited from the agreement. View "Coatney v. Ancestry.com DNA, LLC" on Justia Law

In this case before the United States Court of Appeals for the Seventh Circuit, the defendant, Christopher Christophel, was convicted of knowingly attempting to persuade, induce, or entice a minor to engage in sexual activity. He was convicted based on his online communications with an undercover federal agent who was posing as a 15-year-old girl. Christophel appealed his conviction, arguing that the trial court erred in giving a jury instruction that, in his view, misstated the elements of the offense.The specific issue on appeal was whether the language of a particular jury instruction, which stated that the government did not need to prove that the defendant intended to have sex with the minor, only that he intended to entice the minor to have sex with him, accurately summarized the law. Christophel contended that this instruction described a wider range of behavior than that proscribed by the statute.The appellate court held that, when viewed in its entirety, the jury instruction did not misstate the law. Although the term "causing ... assent" might suggest unintentional conduct when read out of context, when read in the context of the entire instruction, it was best understood as a shorthand reference to the specific conduct described in the first paragraph of the instruction: knowingly taking a substantial step with the intent to commit the offense of enticement of a minor.Even if the jury instruction could have been clearer, the court found that Christophel was not prejudiced by any potential error. Given the overwhelming evidence of Christophel's intent, any potential error would have been harmless. The court affirmed the judgment. View "USA v. Christophel" on Justia Law

In this federal case before the United States Court of Appeals for the Seventh Circuit, Thomas Moorer, who had been arrested and indicted on charges including murder and attempted murder, challenged the constitutionality of his pretrial detention, claiming that there was no probable cause for his arrest. Moorer was ultimately acquitted by a jury of all charges. The defendants in the case were officers of the Chicago Police Department.The case arose from a fatal shooting that took place in an apartment shared by multiple people. Multiple witnesses, including Edwin Ramos, whose brother Edward was killed in the shooting, identified Moorer as the perpetrator. Edwin informed the police that the man who entered the apartment was nicknamed “Boom.” Moorer was subsequently arrested and charged with first-degree murder and other crimes, and a grand jury returned a 135-count indictment against him.Moorer claimed that the witness identifications were unreliable and that police failed to properly investigate his alibi. He argued that the prosecutors would have concluded there was no probable cause if they had been properly informed of all the facts known to the officers.However, the Court of Appeals found that the officers did have probable cause to arrest and detain Moorer, based on seven independent witness identifications. The court noted that the question for pretrial detention is not whether the officers have proof beyond a reasonable doubt that the accused committed the crime, but whether a reasonable person would have a sound reason to believe the suspect committed a crime. The court concluded that Moorer had not identified any facts known to the defendants that would eliminate probable cause.Therefore, the court affirmed the decision of the district court, which had granted summary judgment in favor of the defendants. View "Moorer v. City of Chicago" on Justia Law

In a case involving a series of toxic tort claims brought by individuals allegedly harmed by lead paint pigment, the United States Court of Appeals for the Seventh Circuit affirmed in part and reversed in part the decision of the United States District Court for the Eastern District of Wisconsin. The case involved approximately 170 plaintiffs, all alleging injuries stemming from their exposure to white lead carbonate, a lead paint pigment, when they were children. The district court had granted summary judgment to the defendants on all claims, based largely on the legal doctrine of "issue preclusion" and "law of the case." The appellate court agreed with much of the district court's reasoning. However, it held that a small group of plaintiffs who had filed their own separate cases had a due process right to try their cases separately. The appellate court also disagreed with the district court's application of issue preclusion to another group of plaintiffs who had filed separate cases and hadn't participated in the earlier proceedings. The appellate court concluded that these plaintiffs had not had a "full and fair opportunity to litigate" the issue of the defendants' duty to warn under a lead dust-based theory of liability. The court therefore sent the cases back to the district court for further proceedings. View "Thompson v. Armstrong Containers Inc." on Justia Law

In this consolidated appeal of multiple toxic tort cases, approximately 170 plaintiffs alleged harm from exposure to white lead carbonate (WLC), a lead paint pigment, during their childhood in the 1990s and early 2000s. They sued several manufacturers of WLC for negligence and strict liability. The United States Court of Appeals for the Seventh Circuit affirmed the lower court's decision in part and reversed in part. The court upheld the district court’s application of the law of the case doctrine to dismiss many of the plaintiffs' claims, finding that the plaintiffs had chosen to bring their claims under a single complaint and were therefore bound by the court's earlier rulings. The court reversed the district court's grant of summary judgment against a small group of plaintiffs who had filed their own cases, ruling that due process protected their right to try their claims. View "Gibson v. Armstrong Containers, Inc." on Justia Law