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

Robert Smith pleaded guilty to conspiracy to distribute methamphetamine and money laundering conspiracy. Nearly eleven months later, on the eve of his sentencing, Smith's attorney filed a motion to withdraw at Smith's request, citing dissatisfaction with representation. The court denied the motion and refused to appoint substitute counsel. Smith was sentenced to 324 months in prison, below the guidelines range. He appealed the denial of his request for substitute counsel and the substantive reasonableness of his sentence.The United States District Court for the Southern District of Illinois initially scheduled Smith's sentencing for January 2023, but granted several continuances at Smith's request. The court eventually set the sentencing for July 12, 2023, and warned against further delays. On July 11, Smith's attorney filed a motion to withdraw, which the court denied after a hearing. The court found no breakdown in communication between Smith and his attorney, attributing the motion to a tactical delay. Smith's subsequent attempts to retain new counsel were unsuccessful, and his attorney represented him at sentencing.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the district court did not abuse its discretion in denying the motion for substitute counsel, noting the motion's untimeliness and the adequacy of the court's inquiry into Smith's concerns. The court also found that the disagreements between Smith and his attorney were strategic and did not constitute a total breakdown in communication. Additionally, the court ruled that Smith's below-guidelines sentence was substantively reasonable, given the district court's thorough consideration of the relevant factors. The judgment of the district court was affirmed. View "United States v. Smith" on Justia Law

Three sets of parents refused to allow their newborns to receive Vitamin K shots at private hospitals in Illinois, citing concerns about risks and religious reasons. Hospital staff reported the refusals to the Illinois Department of Children and Family Services (DCFS), which investigated the parents for medical neglect. In one case, hospital staff took temporary protective custody of the child. The parents sued the hospitals and certain medical professionals under 42 U.S.C. § 1983, alleging violations of their Fourth and Fourteenth Amendment rights.The United States District Court for the Northern District of Illinois dismissed the cases, ruling that the private entities could only be liable under § 1983 if they were engaged in state action. The court found that the hospitals and their staff were not acting under color of state law when they reported the parents to DCFS or took temporary custody of the children. The parents appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's dismissal. The appellate court held that the hospitals and their staff did not act under color of state law. The court found no evidence of a conspiracy or joint action between the hospitals and DCFS to infringe on the parents' constitutional rights. The court also determined that the hospitals were not performing a public function traditionally reserved to the state, as the mere threat of taking protective custody did not constitute state action. Additionally, the court found no entwinement or symbiotic relationship between the hospitals and the state that would make the hospitals state actors. Therefore, the parents' § 1983 claims could not proceed. View "Scott v. University of Chicago" on Justia Law

In late 2016, Homeland Security Investigations (HSI) agents began investigating individuals sharing child pornography over peer-to-peer file-sharing networks. Using a proprietary software program called "eMule," HSI agents identified and downloaded child pornography files from Warren Siepman's computer on three separate occasions between October 2016 and March 2017. The software operated automatically, searching for specific child pornography files and downloading them without human intervention. Forensic examination of Siepman's hard drives revealed over one thousand child pornography files, and Siepman admitted to viewing and sharing these files on the network.A grand jury indicted Siepman on three counts of transportation of child pornography and one count of possession of child pornography. The case proceeded to trial in the United States District Court for the Northern District of Illinois, where the jury was instructed on the elements of the transportation charge. The court also provided an additional instruction defining "transports" in the context of peer-to-peer file sharing, which Siepman objected to. The jury found Siepman guilty on all counts. Siepman moved for a judgment of acquittal or a new trial, arguing that the court's instruction was erroneous and that the evidence was insufficient. The district court denied the motion, finding the instruction accurate and the evidence sufficient.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The court held that the instruction accurately reflected the law, stating that making files available for download on a peer-to-peer network constitutes "transportation" under federal law. The court also found that the evidence was sufficient to support the convictions, noting that the automated software's involvement did not negate the fact that an individual ultimately facilitated the download. The convictions were affirmed. View "United States v. Siepman" on Justia Law

Three sets of parents refused to allow their newborns to receive Vitamin K shots at private hospitals in Illinois due to concerns about risks and religious reasons. Hospital staff reported the refusals to the Illinois Department of Children and Family Services (DCFS), which investigated the parents for medical neglect. In one case, hospital staff took temporary protective custody of the child. The parents sued under 42 U.S.C. § 1983, alleging violations of their Fourth and Fourteenth Amendment rights by the hospitals and medical professionals.The United States District Court for the Northern District of Illinois dismissed the cases, ruling that the private entities were not engaged in state action and thus not liable under § 1983. The parents appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the private hospitals and their staff did not act under color of state law. The court found no evidence of a conspiracy or joint action between the hospitals and DCFS to infringe on the parents' constitutional rights. The court also determined that the hospitals were not performing a public function traditionally reserved to the state, as the mere threat of taking protective custody did not constitute state action. Additionally, the court found no symbiotic relationship or entwinement between the hospitals and the state to the point of largely overlapping identity.The Seventh Circuit affirmed the district court's dismissal of the parents' claims, concluding that without state action, there could be no § 1983 liability. View "Bougher v. Silver Cross Hospital and Medical Centers" on Justia Law

Ji Chaoqun, a Chinese national, came to the United States in 2013 to study electrical engineering. In 2022, he was indicted for conspiring to commit an offense against the United States, failing to register as a foreign agent, wire fraud, and making a false statement. Evidence presented at trial showed that Ji was recruited by the Chinese Ministry of State Security (MSS) before leaving China and engaged in various activities on their behalf, including purchasing background reports on U.S. scientists and attempting to infiltrate the U.S. Army Reserves.The United States District Court for the Northern District of Illinois convicted Ji on all counts and sentenced him to 96 months in prison. Ji appealed, arguing that the government should have to prove he was not engaged in a legal commercial transaction as an element of the offense and that the jury should have been required to unanimously agree on the specific act he committed. He also challenged the district court’s evidentiary and sentencing decisions.The United States Court of Appeals for the Seventh Circuit held that the specific act a foreign agent commits under 18 U.S.C. § 951 does not require jury unanimity and that the legal commercial transaction exception is an affirmative defense, not an element of the offense. The court also found no error in the district court’s evidentiary rulings or in its sentencing decisions. The Seventh Circuit affirmed Ji’s conviction and sentence. View "United States v. Chaoqun" on Justia Law

Cassandra Socha, a patrol officer with the Joliet Police Department (JPD), sent a text message to her neighbor criticizing her for testifying in the criminal trial of Socha’s boyfriend. A prosecutor recommended that Sergeant Edward Grizzle secure a search warrant for Socha’s cell phone, which he did, obtaining authority to search for any and all data related to electronic communications. Socha turned over her phone, expressing concerns about personal content. JPD detectives used forensic software to extract all data from her phone. Rumors later surfaced that explicit content from her phone had been seen by JPD members, with two detectives admitting to viewing such content.Socha sued the City of Joliet, Sgt. Grizzle, and others, bringing multiple claims under federal and Illinois law. The United States District Court for the Northern District of Illinois granted summary judgment to Sgt. Grizzle on the § 1983 claim, finding he was entitled to qualified immunity. The court also granted summary judgment to the City on the intrusion upon seclusion claim, rather than relinquishing supplemental jurisdiction over the Illinois law claim.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court agreed that Sgt. Grizzle was entitled to qualified immunity and affirmed the summary judgment on the § 1983 claim. However, the court disagreed with the district court on the intrusion upon seclusion claim, concluding that a reasonable jury could find that Detective McKinney accessed Socha’s photograph intentionally and without authorization. Therefore, the court reversed the grant of summary judgment on that claim and remanded the case for further proceedings. The court also noted that the district court should decide whether to exercise supplemental jurisdiction over the state law claim on remand. View "Socha v. City of Joliet" on Justia Law

Henry Beverly, a financial analyst at Abbott Laboratories, took a personal leave of absence during which he began working for Cook County without informing Abbott. His leave was extended twice, but when he requested a third extension, Abbott had already filled his position and terminated his employment. Beverly sued Abbott, alleging racial discrimination and defamation, among other claims.The United States District Court for the Northern District of Illinois granted summary judgment in favor of Abbott on some of Beverly’s claims, including those related to his termination, while allowing others to proceed to trial. The jury found in favor of Abbott on the remaining claims. Beverly appealed, challenging several pretrial, trial, and post-trial rulings.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s decisions. The appellate court held that the reduction in Beverly’s job duties did not amount to a constructive discharge and that Abbott’s reason for terminating Beverly’s employment was not pretextual. The court also upheld the district court’s mid-trial judgment as a matter of law on Beverly’s defamation claim, finding that the statement in question was a non-actionable opinion. Additionally, the appellate court found no abuse of discretion in the district court’s trial rulings, including those related to impeachment attempts and the exclusion of certain evidence. The court concluded that Beverly’s arguments did not warrant a new trial and affirmed the district court’s judgment in full. View "Beverly v. Abbott Laboratories" on Justia Law

The case involves a property owned by Indiana Land Trust #3082, located in Hammond, Indiana, which houses a lucrative fireworks and tobacco business operated by Omar and Haitham Abuzir. The City of Hammond seeks to use its eminent domain power to take this property to build a road connecting Indianapolis Boulevard and the Water Gardens neighborhood. The Abuzirs allege that the City’s actions are part of a conspiracy involving political motives and favoritism towards competitors who support the mayor.The Hammond Redevelopment Commission initially offered to purchase the property in 2018, but the Abuzirs declined. Consequently, the Commission initiated a condemnation action in Indiana state court under the state’s eminent domain statute. The Abuzirs objected, arguing that the taking was for a private purpose and motivated by ill will. Unable to assert counterclaims in state court, they filed a federal lawsuit alleging constitutional and federal law violations, including claims under the Fourteenth Amendment and 42 U.S.C. § 1983.The United States District Court for the Northern District of Indiana dismissed the Abuzirs' third amended complaint with prejudice, finding that the City had a legitimate government interest in building a road and that the Abuzirs failed to state a claim for equal protection, substantive due process, or civil conspiracy. The court noted that the Abuzirs' complaint itself provided a rational basis for the City’s actions.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The appellate court held that the Abuzirs failed to state a class-of-one equal protection claim because the City’s actions had a rational basis. The court also found that the proposed substantive due process claim was futile as the Abuzirs did not allege a deprivation of a protected interest. Lastly, the court upheld the denial of leave to add a § 1983 conspiracy claim, as the Abuzirs failed to establish any underlying constitutional violation. View "Indiana Land Trust #3082 v. Hammond Redevelopment Commission" on Justia Law

Charles Vavra, an employee of Honeywell International, Inc., was required to complete an online unconscious bias training. Vavra refused to participate in the training and was subsequently terminated. He then filed a lawsuit claiming that his termination was in retaliation for his opposition to the training and for his complaints about an email from the head of his business unit, which he found offensive.The United States District Court for the Northern District of Illinois granted summary judgment in favor of Honeywell. The court found that Vavra's retaliation claims were without merit, leading to his appeal to the United States Court of Appeals for the Seventh Circuit.The Seventh Circuit reviewed the district court’s decision de novo. The court held that Vavra’s opposition to the training did not constitute protected activity under Title VII or the Illinois Human Rights Act because he did not have an objectively reasonable belief that the training violated the law. Vavra had not accessed the training or known its contents, making his belief speculative. Additionally, even if his complaints about the email were considered protected activity, Vavra failed to establish a causal connection between his complaints and his termination. The court noted that Honeywell had consistently sought Vavra’s compliance with the training requirement and only terminated him after his final refusal. The Seventh Circuit affirmed the district court’s grant of summary judgment in favor of Honeywell. View "Vavra v. Honeywell International, Inc." on Justia Law

Consolidated Grain and Barge Company (Consolidated) entered into multiple agreements with the Indiana Port Commission (Commission) to build new rail tracks at the Southwind Maritime Centre. In exchange, Consolidated received the right to perform rail switching services for other tenants, allowing it to recoup its investment through service fees. However, in 2021, the Commission hired a new rail service provider, Squaw Creek Southern Railroad, to maintain the tracks and perform rail services, prompting Consolidated to sue, alleging breach of contract.The United States District Court for the Southern District of Indiana dismissed the case, finding that the plain meaning of the agreements did not support Consolidated's claims. The court determined that the agreements did not grant Consolidated perpetual rights to perform its own switching services at no cost, especially after the Commission exercised its right to hire a new rail service provider.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 the 2008 New Storage Tracks Agreement unambiguously revoked Consolidated's lease rights over the storage tracks, and any right to perform switching services was tied to the now-expired 2006 Track Use Agreement. The court also found that the Commission had followed the proper procedure in hiring a new rail service provider, as stipulated in the agreements. Consequently, Consolidated's rights to perform its own switching services were extinguished in 2021, and the contracts were not ambiguous as a matter of law. The court also rejected Consolidated's promissory estoppel claim, as it was based on the interpretation of the existing contracts. View "Consolidated Grain and Barge Co. v. Indiana Port Commission" on Justia Law