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

The case involves Millard Williams, who was convicted for orchestrating the shipment of a package containing furanyl fentanyl, a Schedule I controlled substance, while in a Georgia jail. Williams was found guilty of conspiring to possess and possessing at least 100 grams of furanyl fentanyl. The jury also determined that furanyl fentanyl is an “analogue of fentanyl,” triggering a ten-year mandatory minimum sentence under 21 U.S.C. § 841(b)(1)(A)(vi). Williams appealed, arguing that furanyl fentanyl is not an “analogue of fentanyl” as defined in the statute, and that the district court’s definition of “analogue” renders the provision unconstitutionally vague.The United States Court of Appeals for the Seventh Circuit disagreed with Williams. The court held that the term “controlled substance analogue” is distinct from the term “analogue of fentanyl,” and therefore, the court must look to the ordinary meaning of the word “analogue.” The court found nothing problematically vague about the definition that emerges as applied to furanyl fentanyl. The court also rejected Williams’s other challenges to his conviction and sentence, including his argument that the district court should have suppressed the evidence found inside the intercepted package. The court concluded that the district court made no errors requiring resentencing. View "USA v. Williams" on Justia Law

Rodney Clemons, an inmate at Stateville Correctional Center, filed a lawsuit against Wexford Health Sources, Inc., and two of its physicians, alleging that they were deliberately indifferent to his serious foot condition. Clemons had injured his right ankle before his incarceration and suffered from pain in his right ankle and foot for several years while incarcerated. He claimed that the defendants prioritized cost concerns over reasoned medical judgment.The case was initially heard in the United States District Court for the Northern District of Illinois, Eastern Division. The district court granted summary judgment to the defendants, concluding that the treatment plan adopted by the physicians was reasonable and that there was no evidence of a widespread pattern of indifference that could infer a constitutional violation by Wexford.Clemons appealed to the United States Court of Appeals for the Seventh Circuit. The appellate court affirmed the district court's decision. The court found that the prison doctor's treatment decisions were not so unacceptable that no minimally competent professional would have responded in the same way. The court also found that the alleged policy of limiting referrals to trim costs was not facially unconstitutional. Furthermore, Clemons failed to show a pattern of violations that would infer that Wexford was aware of and condoned the misconduct of their employees. Therefore, the court concluded that Clemons failed to show that the defendants were deliberately indifferent to his serious medical needs. View "Clemons v. Wexford Health Sources, Inc." on Justia Law

The case revolves around Tondalaya Gamble, a Black physician who worked at Cook County Health’s John Stroger Hospital for approximately eleven years. Gamble sued Cook County and her former department and division chairs, Edward Linn and Fidel Abrego, alleging race discrimination. She claimed that Cook County violated Title VII of the Civil Rights Act of 1964 and the Illinois Human Rights Act, and that Linn and Abrego violated 42 U.S.C. §§ 1981 and 1983. Gamble argued that she was paid less than similarly situated non-Black physicians.The United States District Court for the Northern District of Illinois granted summary judgment in favor of the defendants, concluding that no reasonable jury could find in Gamble’s favor on any of her claims. The court found that Gamble failed to establish that she was similarly situated to her chosen comparators, two white physicians, Bruce Rosenzweig and Karen Fish. The court noted that Rosenzweig was a part-time employee while Gamble was full-time, and that Fish had more experience and was hired to perform different duties.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court agreed that no reasonable jury could find that Gamble was similarly situated to Rosenzweig or Fish. The court noted that the part-time versus full-time distinction was not dispositive in and of itself, but that other differences, such as their different duties and experience, made them inapt comparators for Gamble’s discrimination claim. The court concluded that Gamble presented no other evidence suggesting that her pay or demanding work responsibilities were because of her race. View "Gamble v. County of Cook" on Justia Law

The case involves a group of consumers who filed arbitration claims against Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc., alleging that Samsung unlawfully collected and stored sensitive biometric data through their electronic devices, in violation of Illinois law. Samsung denied the allegations and refused to pay the administrative filing fees required by the American Arbitration Association (AAA). The AAA terminated the arbitration proceedings, and the consumers filed a petition to compel arbitration in district court. The district court ordered Samsung to arbitrate and to pay the associated AAA filing fees. Samsung appealed, disputing the existence of an arbitration agreement with the consumers and challenging the district court’s authority to require it to pay the AAA’s fees.The United States Court of Appeals for the Seventh Circuit reversed the district court's decision. The court found that the consumers failed to meet their evidentiary burden in proving the existence of an arbitration agreement with Samsung. Furthermore, the court held that the district court exceeded its authority by ordering Samsung to pay the AAA's filing fees. The court reasoned that the parties' alleged agreement incorporated the AAA's rules and procedures, which granted the AAA substantial discretion over resolving fee disputes. Therefore, the court concluded that the arbitration had been conducted according to the terms of the alleged agreement, and the district court did not have the authority to order Samsung to pay the AAA's fees. View "Wallrich v. Samsung Electronics America, Inc." on Justia Law

Jerome Ford was sentenced to 96 months in prison for possessing a firearm despite his felony conviction, followed by three years of supervised release. The judgment included a condition that Ford must pay a fine of $250 immediately, even though this condition was not mentioned during sentencing or in the presentence report.Ford appealed to the United States Court of Appeals for the Seventh Circuit, arguing that the payment condition was unauthorized because it was not mentioned during sentencing or in the presentence report. He requested that the payment condition be removed from the judgment. The court noted that when there is a conflict between the oral pronouncement and the written judgment in a criminal case, the oral pronouncement usually prevails. However, there is an exception for conditions of supervision required by law, which do not need to be announced orally.The court found that the payment condition was not required by law, but was included in a list of mandatory conditions in the Sentencing Guidelines. Ford argued that these guidelines ceased being mandatory after a previous case, United States v. Booker, declared them to be advisory. The court noted that this argument was not necessarily true, as the conditions of supervised release were not affected by the Booker decision.However, the court accepted the prosecutor's implied concession that the payment condition may not be mandatory. As a result, the court decided that the payment condition must be vacated. The court noted that this decision may not benefit Ford, as a statute provides that people who do not pay their fines may be returned to prison. The court also noted that the district judge could add the payment condition to the judgment at any time. The court modified the district court's judgment to delete the payment condition. View "United States v. Ford" on Justia Law

The case revolves around a dispute over attorney's fees in a Social Security disability benefits case. The plaintiff, Christian Arnold, was represented by the law firm Binder & Binder. After Arnold was determined to be disabled and entitled to past-due benefits, the law firm requested attorney's fees under 42 U.S.C. § 406(b), based on a contingency fee agreement Arnold had signed. However, the district court reduced the requested fees by nearly sixty percent, arguing that the full request would result in a "windfall" for the law firm, which was prohibited by statute. Binder & Binder appealed this decision.The case was initially heard by an administrative law judge (ALJ) who concluded that Arnold was not disabled. Arnold appealed this decision to the district court, which remanded the case back to the ALJ. On remand, the ALJ ruled in Arnold's favor, and the Social Security Administration issued a Notice of Award to Arnold for past-due benefits. Binder & Binder then moved for attorney's fees in the district court under 42 U.S.C. § 406(b), based on their contingency fee agreement with Arnold. The district court, however, reduced the requested fees.The United States Court of Appeals for the Seventh Circuit reviewed the case and concluded that the district court had abused its discretion by not basing its analysis primarily on the contingency agreement before considering the reasonableness of the request. The Court of Appeals vacated the district court's decision and remanded the case for further proceedings consistent with its opinion. The court emphasized that the contingency fee agreement should be the starting point for determining reasonableness under § 406(b), and any reduction should be justified based on relevant factors such as the claimant's satisfaction with their attorney's representation, the attorney's expertise and efforts expended, and the uncertainty of recovery and risks of an adverse outcome. View "Arnold v. O'Malley" on Justia Law

Anthony Day and Omarr Williams were charged with robbing a bank in Hammond, Indiana. Day was identified as the man who brandished a silver revolver during the robbery. After the robbery, the police tracked Day down using a GPS tracker embedded in the stolen cash. They found him in a wooded area, along with cash, an OGIO bag, parts of the robbers' disguises, and two firearms: a silver Smith & Wesson revolver and an American Tactical assault rifle. The police arrested Day and Williams, and a grand jury charged Day with bank robbery, brandishing a firearm during a crime of violence, and being a felon in possession of a firearm.In the district court, Day moved to exclude reference to the American Tactical assault rifle, arguing that there was no evidence he used it during the robbery. He also requested a unanimity instruction, meaning the jurors would have to agree on which gun he possessed for the charge of being a felon in possession of a firearm. The district court denied both requests, citing a previous decision by the United States Court of Appeals for the Seventh Circuit. The jury found Day guilty on all counts, and he was sentenced to 292 months in prison. Day appealed his conviction for being a felon in possession of a firearm, challenging the district court's failure to give his requested jury instruction.The United States Court of Appeals for the Seventh Circuit reviewed Day's argument de novo. The court noted that the Sixth Amendment guarantees the right to trial by an impartial jury, which requires jury unanimity for convictions for serious crimes. However, this requirement only applies to the elements of the offense, not the means used to commit an element of the crime. The court explained that the particular firearm possessed is not an element of the crime, but rather the means used to satisfy the element of "any firearm." Therefore, jurors do not need to agree on which weapon the defendant possessed. The court also noted that where a defendant possessed multiple firearms, the government may only bring one charge if the defendant's possession of the firearms was "simultaneous and undifferentiated." The court found that the evidence supported a single course of possession of the firearms, not two distinct instances of possession. Therefore, the court affirmed the judgment of the district court, concluding that no unanimity instruction was required. View "USA v. Day" on Justia Law

The case revolves around Zebulon Marzette, who was convicted for possessing a firearm as a felon. The incident occurred on September 20, 2019, when a 911 call reported people pounding on a door and waving guns at an apartment complex in South Bend, Indiana. Responding officers encountered a chaotic scene and eventually pulled over a car leaving the area. Marzette, who had walked to the location of the car stop, was handcuffed and placed in a squad car. A gun was found in a purse in the back seat of the stopped car, and subsequent DNA testing revealed Marzette's DNA on the trigger. Marzette was charged with felony possession of a firearm.The case was tried in the United States District Court for the Northern District of Indiana. Marzette objected to the introduction of the DNA evidence, arguing that each custodian in the gun’s chain of custody needed to testify to prove that the gun and the DNA evidence were authentic and reliable. The district court disagreed and overruled Marzette’s objection, admitting the DNA-related testimony and testing results into evidence. The jury returned a guilty verdict and Marzette was sentenced to 36 months’ imprisonment.On appeal to the United States Court of Appeals for the Seventh Circuit, Marzette challenged the district court’s admission of the DNA evidence and the hearsay testimony about the 911 call. The appellate court found that the district court did not abuse its discretion in admitting the DNA evidence, as the government had provided a substantially complete chain of custody. Regarding the 911 call, the court concluded that even if it was an error to admit the dispatch call, the government could have presented effectively the same case with its exclusion. Therefore, the court affirmed the district court's decision. View "USA v. Marzette" on Justia Law

The case involves Bernell Brasher, who was convicted for conspiracy to distribute methamphetamine. The case began when a confidential source informed the Drug Enforcement Administration (DEA) that Bacaree Oaks had a pound of meth for sale. The source suggested he would sell the meth on credit and pay Oaks and Brasher $5,000 afterward. Instead, the source turned the meth over to law enforcement. The meth was tested and found to be 99% pure methamphetamine. Brasher and Oaks were later arrested. During his arrest, Brasher admitted to owing money to his supplier in Mexico for about 100 pounds of meth he had on the street.Brasher was indicted for conspiracy to distribute methamphetamine and pleaded guilty. The presentence investigation report (PSR) concluded that Brasher's relevant conduct included four instances of past drug distribution activity. Brasher objected to the PSR's findings, but his objections are not part of this appeal. The district court sentenced Brasher to 200 months’ imprisonment, which fell within his Guidelines range.On appeal, Brasher argued that his past conduct was too dissimilar from his offense of conviction—and too long before it—to factor into his Guidelines calculation. The court disagreed, finding sufficient similarity between the offense of conviction and the uncharged conduct to satisfy the plain error standard. The court also rejected Brasher's argument that the district court failed to explain why the past conduct was relevant. The court affirmed the district court's judgment. View "United States v. Brasher" on Justia Law

A mortgage company, Approved Mortgage Corporation, initiated two wire transfers, but the instructions for the transactions were altered by a third party. The funds were transferred to Truist Bank, which deposited the funds into an account it had previously flagged as suspicious. The funds were then withdrawn in the form of cashier’s checks. Approved Mortgage sued Truist, seeking damages in the amount of the transfers. The company asserted two claims under the Indiana Uniform Commercial Code (UCC), which governs the rights, duties, and liabilities of banks and their customers with respect to electronic funds transfers, and a common law negligence claim.The district court dismissed the UCC claims due to lack of privity between Approved Mortgage and Truist, and dismissed the negligence claim as preempted by the UCC. The court held that the UCC does not establish an independent remedy and must be read with another section of the UCC, which entitles a sender to a refund only from the bank which received its payment.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the dismissal of the UCC claims, agreeing with the lower court that the UCC does not establish an independent remedy and must be read with another section of the UCC. However, the appellate court reversed the dismissal of the negligence claim, holding that to the extent the negligence claim arises from Truist’s issuance of the cashier’s checks after Truist credited the funds to the suspicious account, the claim is not preempted by the UCC. The case was remanded to the district court for further proceedings. View "Approved Mortgage Corporation v. Truist Bank" on Justia Law