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

In this case, the United States Court of Appeals for the Seventh Circuit reviewed the denial of asylum, withholding of removal, and protection under the Convention Against Torture (“CAT”) for petitioner Kamaljit Singh, a native and citizen of India. Singh alleged that he had been persecuted in India due to his support for a minority political party, and feared return due to ongoing threats. The immigration judge (“IJ”) and the Board of Immigration Appeals (“BIA”) both denied Singh’s application on credibility grounds, finding inconsistencies in his account. On appeal, the Seventh Circuit upheld the BIA's decision, finding that the BIA's adverse credibility finding was supported by substantial evidence. The court also agreed with the BIA's determination that the harm Singh had suffered in India did not rise to the level of past persecution necessary to establish eligibility for asylum or withholding of removal. In addition, the court held that Singh had waived his claims for future persecution and CAT protection by failing to properly raise them before the BIA. Lastly, the court determined that Singh's due process claims, including a claim of ineffective assistance of counsel, had not been properly exhausted before the BIA and therefore could not be reviewed on appeal. As a result, Singh's petition for review was denied. View "Singh v. Merrick Garland" on Justia Law

The case in question was brought before the United States Court of Appeals for the Seventh Circuit. The plaintiff, Christine Boardman, was the former president of Local 73, a regional affiliate of the Service Employees International Union (International). The International imposed an emergency trusteeship on Local 73 due to internal conflict and removed Boardman from her position. In response, Boardman sued under the Labor Management Reporting and Disclosure Act, alleging that the trusteeship was a pretextual retaliation for her protected speech.The court agreed with the defendants' argument that the trusteeship was necessary to restore order and democratic procedures within Local 73, given the intense infighting between Boardman and Secretary-Treasurer Matthew Brandon. The court reasoned that this constituted a valid purpose for the trusteeship under the Act, which allows trusteeships to be established for purposes including "restoring democratic procedures."The court rejected Boardman's claim that the trusteeship was retaliatory, arguing that even if there was animus between Boardman and the International's President, Mary Kay Henry, this did not negate the valid purpose for the trusteeship. Furthermore, the court found no evidence that Boardman was treated differently from other union members who also engaged in protected speech. The court's decision affirmed the lower court's grant of summary judgment in favor of the defendants. View "Boardman v. Service Employees International Union" on Justia Law

Erik Bertaud, who suffered serious injuries when a tree branch fell on his head, applied for disability insurance benefits and supplemental security income from the Social Security Administration. His application was denied, and he appealed. The Appeals Council remanded the case twice, but after the third denial, Bertaud's request for review was denied, making the ALJ's decision the final decision of the Commissioner. Bertaud then sought judicial review, arguing that the ALJ had failed to develop the record of his disability, pointing to over 800 pages of new medical evidence. The district court denied Bertaud's motion for summary judgment and affirmed the Commissioner's decision, and Bertaud appealed to the United States Court of Appeals for the Seventh Circuit.The court held that although an ALJ has a duty to develop a full and fair record, this duty is limited when the claimant is represented by an attorney. The claimant's duty to submit evidence is ongoing and covers any additional related evidence they become aware of. The court noted that Bertaud was represented and his attorney had confirmed that the evidence was complete and supplemented the record when necessary. Therefore, the court concluded that the ALJ did not fail to develop Bertaud's medical record. The court affirmed the district court's decision denying Bertaud's motion for summary judgment and affirming the decision of the Commissioner. View "Bertaud v. O'Malley" on Justia Law

This case involves Daryl McGhee, who was charged with several federal offenses related to possession of a firearm and cocaine. The charges arose after the police received a 911 call from McGhee's wife reporting domestic violence and alleging that McGhee had left their house carrying a gun and a leather bag. The police followed footprints in the snow to find McGhee and later found the bag, which contained the gun and cocaine, under a nearby dumpster. During the trial, the United States District Court for the Central District of Illinois issued an order prohibiting McGhee from testifying about the domestic violence incident, even to deny the allegation, threatening to jail him and his defense counsel if they violated the order.The United States Court of Appeals for the Seventh Circuit found that while the district court's decision to limit McGhee's testimony was valid as it avoided turning the trial into a domestic dispute, the order was overly broad as it completely silenced McGhee, leaving the jury to potentially conclude that he did hit his wife. Despite this, the appellate court concluded that the exclusionary order did not have a substantial influence over the jury and did not result in a verdict inconsistent with substantial justice. The court expressed concerns about the district court's treatment of McGhee's defense counsel but ultimately affirmed the district court's judgment. View "USA v. McGhee" on Justia Law

In this case, the United States Court of Appeals for the Seventh Circuit affirmed a district court's decision to grant summary judgment in favor of the defendants on all federal claims made by the plaintiff. The plaintiff, Lamont Moore, was an inmate who filed a suit against a prison guard and the prison where he was subsequently sent to, alleging failure to protect him from another inmate's attack, violation of his rights under the Americans with Disabilities Act (ADA), and a conspiracy among the investigating officers to falsify the official report of the incident.The court found that Moore was unable to demonstrate that the prison guard was aware of and disregarded an excessive risk to his safety, a requirement for a successful claim of failure to protect. Moore's testimony indicated that his complaints to the guard about the other inmate were about annoyance and horseplay, not a fear for his safety.Regarding his ADA claim, the court found that Moore failed to demonstrate that any disability-based discrimination was intentional. Moore complained about the distance to the healthcare unit but never alerted anyone at any prison that he required an accommodation in order to access services. He was able to access every service in prison, albeit more slowly due to his loss of vision in one eye. There was no evidence that any defendant knew that he could not access any services or made a deliberate choice to deny him access to services.After resolving all of the federal claims, the court declined to exercise supplemental jurisdiction over the state law claims. View "Moore v. Western Illinois Correctional Center" on Justia Law

The case involves Timothy Bell, who, after serving a sentence for sexual assault, remained incarcerated in an Illinois prison for over 16 years under the state’s Sexually Violent Persons Commitment Act. Bell sued two state officials under 42 U.S.C. § 1983, claiming that his civil commitment had exceeded the duration allowed by the Act. The district court dismissed Bell's case, citing the Supreme Court’s 1994 decision in Heck v. Humphrey as barring his claims. On appeal, the United States Court of Appeals for the Seventh Circuit agreed with the lower court's judgment.The main holding in the case is that Heck v. Humphrey's favorable-termination requirement, which prevents prisoners from using § 1983 to challenge the fact or duration of their confinement unless their conviction or disciplinary sanction has been invalidated, applies to civil detainees such as those confined under the Illinois Sexually Violent Persons Commitment Act. The court reasoned that like a prisoner wishing to contest a criminal conviction or sentence, a civil detainee cannot sue a state official under § 1983 for violating his constitutional rights when a judgment in the plaintiff’s favor would necessarily imply the invalidity of his confinement, unless the grounds for the confinement have already been set aside in other proceedings. This conclusion remains the same regardless of whether the individual is civilly committed or criminally imprisoned.Furthermore, the court pointed out that Bell's release from confinement to home confinement did not change the court's conclusion. The Heck bar applies until the judgment that caused the detention is invalidated, even after a detainee's release. Therefore, Bell must wait until he receives a favorable termination of his civil commitment before seeking relief under § 1983 for his allegedly excessively long confinement. View "Bell v. Raoul" on Justia Law

The case involves the plaintiff-appellant, Chris Martin, who suffered a back injury in June 2016 and stopped working. He sought medical attention in February 2018 and was diagnosed with a spine disorder in May 2018. Martin applied for Social Security disability benefits and was awarded supplemental security income after an administrative law judge (ALJ) found him disabled under the Social Security Act's stringent definition. However, he was denied disability insurance benefits because his insured status for those benefits had expired on December 31, 2017, a few weeks before he was found to have been disabled. Martin appealed, arguing that the ALJ should have consulted an additional medical expert to determine whether he was disabled earlier, before his insured status lapsed. The United States Court of Appeals for the Seventh Circuit concluded that the ALJ did not abuse her discretion in deciding not to consult another medical expert. The court explained that Social Security Ruling 18–01p allows an ALJ to decide whether to consult an additional medical expert to answer that question. Therefore, the court affirmed the denial of disability insurance benefits. View "Martin v. Kijakazi" on Justia Law

The defendant-appellant, Rickey Claybron, was convicted on counts of Hobbs Act robbery and firearm-related offenses. He appealed his sentence, arguing that Hobbs Act robbery did not qualify as a predicate crime of violence under 18 U.S.C. § 924(c) and that a retroactive amendment in the Sentencing Guidelines should have been applied to lower his criminal history category and consequently, his sentencing range. The United States Court of Appeals for the Seventh Circuit upheld Claybron's firearm-related convictions, ruling that Hobbs Act robbery does qualify as a crime of violence under § 924(c). However, the court agreed with Claybron's argument about the retroactive amendment to the Sentencing Guidelines. It ruled that because the amendment would reduce his Guidelines range and it was retroactive, Claybron's sentence for the robbery counts should be reconsidered. The court found that remand for resentencing was proper under 28 U.S.C. § 2106, given the lower Guidelines range Claybron would have had if the amendment had been in effect at sentencing. Consequently, while Claybron's convictions and sentences under 18 U.S.C. § 924(c) were affirmed, the sentence imposed on his convictions for the Hobbs Act robbery counts was vacated and remanded for resentencing in light of the Sentencing Guidelines amendments. View "USA v. Claybron" on Justia Law

In this case, the United States Court of Appeals for the Seventh Circuit reviewed the sentencing of Senque Bingham, who had pleaded guilty to drug offenses. Bingham had requested "safety-valve" relief under 18 U.S.C. § 3553(f) at sentencing, meaning he sought a sentence below the statutory minimum because he met certain criteria, including not having possessed a firearm in connection with his offense. However, the district court found Bingham ineligible for safety-valve relief, because he fulfilled the criteria for a firearms enhancement under U.S.S.G. § 2D1.1(b)(1), which applies if a dangerous weapon was possessed in connection with the offense.The appellate court found that the district court had erroneously conflated the scope of the safety-valve no-firearms condition with the broader scope of the Sentencing Guidelines firearms enhancement. The court clarified that the safety-valve no-firearms condition is narrower than the firearms enhancement, as the latter may apply even if a co-conspirator's possession of a firearm was reasonably foreseeable to the defendant, but not induced by them. The court held that eligibility for a firearms enhancement does not automatically disqualify a defendant from safety-valve relief.Because the district court's error in conflating these two provisions could have affected its sentencing decision, the Court of Appeals could not determine whether the error was harmless. Thus, the court vacated Bingham's sentence and remanded the case back to the district court for resentencing. View "USA v. Bingham" on Justia Law

In this case heard by the United States Court of Appeals For the Seventh Circuit, Kimberly Barnes-Staples applied for a Real Estate Director position with the General Services Administration (GSA). However, the GSA hired another candidate. Barnes-Staples subsequently sued the GSA, alleging that the interview process discriminated against her because of her race and sex in violation of Title VII of the Civil Rights Act. The district court granted summary judgment in favor of the GSA.Barnes-Staples argued that the GSA did not follow its internal anti-discrimination procedures, which she claimed allowed the GSA to hire a less qualified candidate. She also contended that she was the superior candidate, so the GSA's assertion that the other candidate was more qualified was pretextual. Furthermore, Barnes-Staples asserted that there was a systemic practice of discrimination against Black candidates and employees within the GSA.The Appeals Court, however, found that Barnes-Staples was not "clearly better qualified" than the candidate who was hired. It also found no evidence that the GSA created interview questions to favor the other candidate, nor was there evidence that the GSA violated its own guidelines during the interview process. The court also noted that while Barnes-Staples presented data on promotion and employment rates within the GSA, she failed to provide sufficient context or detail for this data to support her claim of systemic discrimination.The Appeals Court affirmed the district court's grant of summary judgment in favor of the GSA. Additionally, it found that Barnes-Staples had waived her sex discrimination claim as she did not properly develop this argument before the district court. View "Barnes-Staples v. Carnahan" on Justia Law