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

While incarcerated at Ellsworth Correctional Institution in Wisconsin, the plaintiff was sexually assaulted and physically abused by a correctional officer, James Faulkner. Faulkner was later criminally convicted for these acts and sentenced to a lengthy prison term. The plaintiff subsequently filed a civil suit under 42 U.S.C. §1983 seeking damages from Faulkner and three supervisory officials, alleging violations of her constitutional rights.The United States District Court for the Eastern District of Wisconsin granted summary judgment to the supervisory officials, finding no evidence that they knew or should have known of Faulkner’s risk to inmates. The plaintiff did not appeal these rulings, effectively abandoning her claims against those defendants. Faulkner, having failed to answer the complaint, was found in default. The district court held a hearing to determine damages and ultimately awarded the plaintiff $1 million for pain and suffering and $3 million in punitive damages, but denied additional damages for lost income and future medical expenses due to insufficient and improperly presented evidence.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s evidentiary rulings and the plaintiff’s arguments regarding the scope of Faulkner’s employment. The appellate court held that the district judge did not abuse his discretion or commit legal error in excluding the plaintiff’s evidence on future damages, as the submissions failed to comply with statutory requirements and evidentiary rules. The court also rejected the plaintiff’s arguments concerning employer liability, noting that the employer was not named as a party and that such issues were not properly before the court. The Seventh Circuit affirmed the judgment of the district court. View "Dotson v. Faulkner" on Justia Law

Kevin Hodge was involved in a conspiracy to distribute methamphetamine and pleaded guilty to the charge. The indictment specified that the conspiracy involved more than 50 grams of methamphetamine, which typically carries a ten-year statutory minimum sentence. However, Hodge met the criteria for the statutory "safety valve," which allows courts to disregard mandatory minimum sentences. Despite this, the district court sentenced him to ten years without discussing his eligibility for safety valve relief.The United States District Court for the Southern District of Illinois initially handled the case. Hodge pleaded not guilty but later changed his plea to guilty. The court granted multiple continuances for his sentencing, partly due to his wife's serious health issues. The presentence investigation report (PSR) confirmed Hodge's eligibility for the safety valve, recommending a Guidelines range of 135 to 168 months. Hodge requested a sentence of time served, citing his wife's health and his role as primary caregiver. The district court sentenced him to 120 months, acknowledging his wife's health issues but emphasizing the large quantity of drugs involved. The court did not address Hodge's safety valve argument.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that the district court had committed procedural error by not addressing Hodge's statutory safety valve argument, which is a principal mitigating argument. The Seventh Circuit noted that the district court's silence on this issue left uncertainty about whether it considered the safety valve's applicability. Consequently, the Seventh Circuit vacated Hodge's sentence and remanded the case for resentencing, requiring the district court to engage with the safety valve argument. View "United States v. Hodge" on Justia Law

Sotir Libarov, a Bulgarian citizen, applied for lawful permanent resident status in the United States based on his marriage to Elizabeth Alonso Hernandez, a lawful permanent resident. USCIS interviewed both separately and concluded that the marriage was a sham, denying Libarov's application in June 2022. Libarov then submitted a FOIA request to ICE seeking documents related to himself. ICE initially routed the request to USCIS, but Libarov clarified he wanted documents from ICE. By November 2022, having received no response, Libarov filed a lawsuit against both ICE and USCIS.The United States District Court for the Northern District of Illinois dismissed Libarov's claims against USCIS and later granted summary judgment for ICE on most issues. The court ruled that Libarov could not seek declaratory relief solely for delayed FOIA disclosure and that FOIA provided an adequate remedy, precluding his APA claim. However, the court ordered ICE to disclose portions of the withheld document containing basic personal information about Libarov.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's judgment. The appellate court agreed that Libarov was not entitled to declaratory relief for the delayed FOIA response, as the agency had eventually conducted an appropriate search and provided the requested documents. The court also upheld the district court's decision to withhold parts of the document under FOIA's exemption 7(A), which protects information related to ongoing law enforcement proceedings. Finally, the appellate court confirmed that FOIA provides an adequate remedy, thus barring Libarov's APA claim. View "Libarov v ICE" on Justia Law

In August 2021, the Cook County Health and Hospitals System implemented a policy requiring all personnel to be fully vaccinated against infectious diseases, including COVID-19. Exemptions were allowed for disability, medical conditions, or sincerely held religious beliefs. Plaintiffs, who are healthcare employees or contractors, requested religious exemptions, which were granted. However, the accommodation provided was a transfer to unpaid status pending termination, with a limited time to find a non-existent remote position. Plaintiffs argued this was religious discrimination violating the Free Exercise Clause of the First Amendment.The United States District Court for the Northern District of Illinois previously denied plaintiffs' motions for preliminary injunctions against the vaccine mandates, including Cook County’s. The Seventh Circuit affirmed this denial, rejecting the plaintiffs' facial challenge to the mandate. On remand, plaintiffs amended their complaint but were denied permission to add a claim under the Illinois Religious Freedom Restoration Act until after the court ruled on the County’s motion to dismiss. The district court dismissed the second amended complaint, considering it a facial challenge, which had already been ruled upon.The United States Court of Appeals for the Seventh Circuit reviewed the case and held that the plaintiffs waived their as-applied challenge by not raising it in the district court or their opening brief on appeal. The court also noted that plaintiffs conceded they no longer sought injunctive relief and did not pursue a facial challenge. Consequently, the court affirmed the district court’s dismissal of the constitutional claim. Additionally, the court found no abuse of discretion in the district court’s denial of leave to amend the complaint to include the Illinois RFRA claim. The court criticized the plaintiffs' counsel for poor advocacy and procedural errors. View "Lukaszczyk v Cook County" on Justia Law

James Napier, the Director of the Middle School at the Orchard School, was not renewed for his contract in 2019 following orders from the new Head of School, Dr. Sherri Helvie. Napier, believing his termination was due to his sex, filed an employment discrimination suit against Orchard. After being rejected when he reapplied for his position, he added a retaliation claim to his lawsuit.The United States District Court for the Southern District of Indiana granted summary judgment in favor of Orchard on both claims. The court concluded that Napier had not presented sufficient evidence to establish a prima facie case of discrimination or retaliation. Specifically, the court found that Napier failed to show that his sex was the reason for his termination and that there was no connection between his protected activity and the rejection of his reapplication.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that Napier did not provide sufficient evidence to demonstrate that Helvie's reason for terminating him—breaching her trust—was pretextual. The court noted that Helvie's explanation for the termination was consistent and credible. Additionally, the court found that Napier's retaliation claim failed because there was no evidence that his litigation was the but-for cause of Orchard's decision not to rehire him. The court concluded that the decision was based on Napier's past performance issues and the fractured relationship with Helvie. View "Napier v Orchard School Foundation" on Justia Law

A citizen-journalist from South Bend, Indiana, challenged the constitutionality of Indiana's "buffer law," which makes it a crime to knowingly or intentionally approach a law enforcement officer within 25 feet after being ordered to stop approaching. The journalist, who records and livestreams police activity, argued that the law violated his First Amendment right to record the police in public spaces. The incident leading to the challenge occurred when the journalist was ordered by police to move back while recording a crime scene, which he complied with under threat of arrest.The United States District Court for the Northern District of Indiana consolidated the journalist's motion for a preliminary injunction with a trial on the merits. The district court found the buffer law constitutional, ruling that it only had an incidental effect on the public's First Amendment rights and served legitimate public safety interests. The court denied the journalist's request for an injunction and entered final judgment for the defendants.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that Indiana's buffer law is a content-neutral regulation of the time, place, and manner of expression. It found that the law is narrowly tailored to serve significant government interests, such as officer and bystander safety and the integrity of police investigations, without burdening substantially more speech than necessary. The court also determined that the law leaves open ample alternative channels for communication, as it does not prevent individuals from recording police activity from a reasonable distance. The Seventh Circuit affirmed the district court's judgment, upholding the constitutionality of Indiana's buffer law. View "Nicodemus v City of South Bend" on Justia Law

Rick Coley and David Duggar were convicted by a jury on drug and firearm charges related to their involvement in a drug-trafficking conspiracy led by Jason Betts in Indianapolis. Coley and Duggar argued that their relationships with Betts were merely buyer-seller relationships, not conspiratorial agreements. Coley also contested the sufficiency of the evidence for his firearm conviction, and both defendants challenged the denial of their motion to sever the drug-trafficking counts from the firearms counts.The United States District Court for the Southern District of Indiana denied the motion to sever, noting that the firearms were found in the defendants' rooms along with evidence of drug trafficking. The jury found Coley and Duggar guilty on all counts, and the judge denied their motions for acquittal, sentencing Coley to 360 months and Duggar to 276 months in prison.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the evidence was sufficient to support the conspiracy convictions, citing the recent en banc decision in United States v. Page, which established that repeated, distribution-quantity drug transactions alone can sustain a conspiracy conviction. The court also found sufficient evidence to support Coley's firearm conviction based on constructive possession, as the gun was found in his bedroom along with his personal items and drug-dealing implements.The Seventh Circuit affirmed the district court's decision, rejecting the defendants' arguments regarding the buyer-seller relationship, the sufficiency of the evidence for the firearm conviction, and the denial of the severance motion. The court concluded that the drug and firearm charges were properly joined and that the district judge did not abuse his discretion in denying the severance motion. View "United States v Coley" on Justia Law

Investigators suspected Lamont Coleman of running a heroin operation from his apartment building in Gary, Indiana. They conducted fourteen controlled drug purchases using confidential informants and undercover officers. Evidence from these buys and surveillance led to a search warrant for Coleman’s apartment and a neighboring house he owned. The search uncovered drugs, money, and firearms, leading to Coleman’s conviction on most counts of the indictment.The United States District Court for the Northern District of Indiana held a Franks hearing and denied Coleman’s motion to suppress evidence, finding sufficient probable cause for the search warrant. At trial, the jury convicted Coleman of being a felon in possession of a firearm, conspiring to distribute heroin, and possessing heroin with intent to distribute. The jury acquitted him of some drug distribution charges and possession of cocaine base with intent to distribute. Coleman was sentenced to 240 months in prison.The United States Court of Appeals for the Seventh Circuit reviewed Coleman’s appeal, which included four claims. Coleman argued that the district court constructively amended his indictment by issuing generic jury instructions, the government withheld exculpatory information, the court improperly excluded an affidavit as evidence, and the court erred in considering acquitted conduct at sentencing. The Seventh Circuit affirmed the district court’s decisions on all grounds. The court found no prejudice from the alleged constructive amendment, determined that the new evidence about the surveillance recordings was not material, upheld the exclusion of Leroy Coleman’s affidavit due to its unreliability, and noted that current precedent allows the consideration of acquitted conduct at sentencing. View "USA v Coleman" on Justia Law

Dyamond Davis, an employee at the Shapiro Development Center, informed her supervisor on May 12, 2017, that she needed to leave work due to pregnancy-related morning sickness. Her supervisor allowed her to leave, reminding her to complete the necessary paperwork. Davis was later granted FMLA leave retroactive to May, but DHS determined that part of her May 12 absence was unauthorized because it believed FMLA did not cover morning sickness and that Davis violated policies requiring the substitution of accrued paid leave for FMLA leave. Consequently, DHS terminated her employment. Davis appealed her termination unsuccessfully to the Illinois Civil Service Commission and then filed a lawsuit alleging FMLA interference. Another employee, Antionette Burns, joined the lawsuit with a similar claim.The United States District Court for the Central District of Illinois dismissed Burns’s claim for lack of Article III standing and granted summary judgment in favor of DHS on Davis’s claim. The court found that Burns failed to establish a concrete injury-in-fact and that DHS was entitled to rely on the medical certification provided by Davis’s doctor, which did not indicate a need for intermittent leave for morning sickness.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the dismissal of Burns’s claim without prejudice, agreeing that she failed to establish a concrete injury-in-fact. However, the court found that there were genuine disputes of material fact regarding Davis’s FMLA claim. The court noted that morning sickness qualifies as a serious health condition under FMLA and that DHS was aware of Davis’s need for intermittent leave due to morning sickness. The court also found that DHS may have improperly applied its paid leave substitution policy, which could have led to Davis’s termination. Therefore, the court reversed the district court’s grant of summary judgment for DHS on Davis’s claim and remanded the case for further proceedings. View "Davis v Illinois Department of Human Services" on Justia Law

Grant Gambaiani was sentenced to 34 years in prison after being found guilty by an Illinois jury of multiple crimes, including the repeated sexual assault of his minor cousin, D.G. During the trial, the courtroom was partially closed during D.G.'s testimony, which Gambaiani argued violated his Sixth Amendment right to a public trial. The Illinois Appellate Court affirmed his conviction, and the Supreme Court of Illinois denied review. Gambaiani then sought postconviction relief, claiming ineffective assistance of counsel during plea negotiations, but the state courts denied relief.Gambaiani filed a petition for a writ of habeas corpus in federal district court, claiming violations of his constitutional rights to a public trial and effective assistance of counsel. The district court denied his petition. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the case.The Seventh Circuit affirmed the district court's decision. The court held that the Illinois Appellate Court's conclusion that Gambaiani waived his right to a public trial by failing to object to the partial closure was not contrary to, or an unreasonable application of, clearly established federal law. The court also found that the partial closure of the courtroom during D.G.'s testimony did not violate Gambaiani's Sixth Amendment right. Additionally, the Seventh Circuit upheld the state court's determination that Gambaiani's attorneys provided effective assistance of counsel during plea negotiations, as the state court's credibility determinations were reasonable and supported by the record. View "Gambaiani v Greene" on Justia Law