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

The case revolves around a dispute between Zimmer Biomet, a medical-device manufacturer, and six of its former sales distributors. The dispute arose from a compensation agreement that guaranteed the distributors a lifetime of long-term commissions on all sales made within their distributorship after retirement. As the company grew and acquired competitors, a disagreement emerged over which product categories fell within the distributorship and were thus subject to the long-term commission agreement.The district court found the agreement ambiguous and sent the case to trial. The jury returned a split verdict, finding that Biomet owed long-term commissions on some products but not others. Biomet appealed the denials of its motions for summary judgment and judgment as a matter of law, and the distributors cross-appealed the dismissal of two counts of their complaint.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decisions. The appellate court agreed that the distributorship agreement was ambiguous regarding the specific categories of products it covered. It also found that the trial record supported the jury’s verdict in favor of the distributors on their Indiana breach-of-contract claim. The court rejected Biomet's argument that the agreement unambiguously limited long-term commissions to reconstructive products, finding that the agreement did not provide clear guidance on which product categories were covered. The court also upheld the dismissal of two counts in the distributors’ complaint, finding that they either lacked a contractual basis or were duplicative of another count. View "Hess v. Biomet, Inc." on Justia Law

The case involves a dispute between Great American Insurance Company (Great American) and State Farm Fire and Casualty Company (State Farm) over who was responsible for paying the defense costs in a lawsuit against board members at the College of DuPage. The lawsuit was filed by Robert Breuder, the former president of the college, who alleged defamation and other claims after his employment was terminated. The board members were insured under a policy issued by the Illinois Community College Risk Management Consortium (Consortium), which was assigned to Great American, and a personal liability umbrella policy issued by State Farm. Great American sued State Farm to recoup losses from defense costs that it claimed State Farm had the duty to provide on behalf of one board member.The district court dismissed Great American's claims, finding that the language of the State Farm insurance contract was unambiguous and that State Farm had no duty to provide defense costs because the primary policy provided by Great American’s assignor covered the underlying loss. Great American appealed the decision.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court found that the language of the State Farm policy was clear that it would only provide a defense if the loss was not covered by any other insurance policy. Since the Consortium policy covered the loss, State Farm had no duty to provide defense costs. The court rejected Great American's arguments that the language of the State Farm insurance contract was ambiguous and that State Farm's coverage was primary as it related to the board member's liability for conduct committed in her individual capacity. View "Great American Insurance Co. v. State Farm Fire and Casualty Co." on Justia Law

The defendant, Travis Montgomery, pleaded guilty to distributing methamphetamine. The government presented evidence that Montgomery stored the drugs, cash, and drug trafficking paraphernalia in a storage unit leased by his sister. The district court applied a two-level enhancement under § 2D1.1(b)(12) of the United States Sentencing Guidelines, which requires an increase where a defendant “maintained a premises for the purpose of … distributing a controlled substance.” Montgomery objected to this enhancement, arguing that his use of the storage unit did not meet the requirements of the enhancement.The district court, however, found that the storage unit qualified as a “premises” under § 2D1.1(b)(12), and that Montgomery had used it primarily for storing and distributing drugs. This enhancement increased Montgomery’s total offense level, leading to a sentence of 235 months of imprisonment and five years of supervised release.On appeal to the United States Court of Appeals for the Seventh Circuit, Montgomery challenged the application of the § 2D1.1(b)(12) enhancement. The court agreed with the district court that the storage unit constituted a “premises” under the enhancement. However, the court was uncertain whether Montgomery sufficiently “maintained” the storage unit for the purposes of § 2D1.1(b)(12), given that he did not lease the unit himself and his use of it was for only a short time. The court also found that the record fell short of indicating that Montgomery was using the storage unit primarily for distributing drugs during the month in question. As a result, the court vacated the judgment and remanded the case for further fact-finding. View "United States v. Montgomery" on Justia Law

Juan Santiago Lopez, a Mexican citizen, sought to overturn an immigration judge's denial of his request for cancellation of removal. Lopez had been in the United States for nearly 20 years, working for the same company and raising four children with his wife. However, he had also accumulated three convictions for driving while intoxicated. The Department of Homeland Security initiated removal proceedings against him after his third conviction. Lopez conceded his removability but applied for cancellation of removal relief, arguing that his family circumstances, particularly the burden his removal would place on his wife, warranted cancellation.The immigration judge denied Lopez's request for cancellation of removal but granted his request for voluntary departure. The judge acknowledged Lopez's positive equities, such as his long-term residence, employment, and family ties in the U.S., but found that his history of drunk driving and disregard for U.S. laws outweighed these factors. The Board of Immigration Appeals affirmed the immigration judge's decision.In the United States Court of Appeals for the Seventh Circuit, Lopez challenged the immigration judge's discretionary decision and argued that the missing date and time information in his Notice to Appear required termination of removal proceedings. The court dismissed his petition for lack of jurisdiction, citing the Supreme Court's decision in Wilkinson v. Garland, which clarified that courts lack jurisdiction to review substantive challenges to an immigration judge's discretionary decision denying cancellation of removal. The court also rejected Lopez's argument about the Notice to Appear, noting that objections to such violations can be forfeited if not raised in a timely manner. View "Lopez v. Garland" on Justia Law

Joseph Van Sach, a federal prison inmate, was sentenced to 87 months for assaulting a correctional officer. The incident occurred when Van Sach refused to comply with orders to submit to hand restraints, leading to the use of pepper spray and physical restraint by officers. Later, Van Sach punched a correctional officer in the eye, causing severe swelling, sharp pain, and bruising. He was subsequently convicted by a jury of one count of forcible assault on a federal officer.The probation officer prepared a presentence report recommending the base offense level for aggravated assault, along with several enhancements, resulting in a total offense level of 25 and a criminal history category of III. This calculation yielded a guidelines range of 70 to 87 months in prison. The government objected to the report, seeking a higher sentence due to the officer's persistent headaches and extreme physical pain. However, the district court overruled the government's objection and adopted the guidelines calculation as set forth in the report, sentencing Van Sach to 87 months in prison.On appeal to the United States Court of Appeals for the Seventh Circuit, both Van Sach and the government agreed that the district court erred in applying the guideline provision for aggravated assault, as the correctional officer did not suffer serious bodily injury. They argued that the court should have used a different guideline provision, which would have resulted in a lower guidelines range of 24 to 30 months. The government conceded the error but argued it was harmless because the district court considered other factors in sentencing. However, the appellate court found the error was not harmless and vacated Van Sach's sentence, remanding the case for resentencing using the correct guideline provision. View "USA v. Sach" on Justia Law

The case involves Roland Black, who was convicted of attempting to possess with intent to distribute a controlled substance, specifically furanyl fentanyl. Law enforcement intercepted a package addressed to Black, believing it contained narcotics. After obtaining a warrant, they found the substance, replaced it with sham narcotics, and delivered the package to Black's residence. Black was arrested after the package was opened and he was found with luminescent powder from the sham narcotics on his hands.Prior to his trial, Black had unsuccessfully moved to dismiss the indictment and suppress all evidence derived from the seizure of the package. He argued that the officers lacked reasonable suspicion to seize the package and requested an evidentiary hearing to resolve related factual disputes. The district court denied these motions, ruling that the totality of the circumstances supported the officers' reasonable suspicion determination.In the United States Court of Appeals for the Seventh Circuit, Black appealed his conviction, raising four arguments. He contended that the officers lacked reasonable suspicion to seize the package, the jury instruction about his requisite mens rea was erroneous, the jury’s verdict was not supported by sufficient evidence, and the court erred in denying his motion to dismiss based on the court’s treatment of furanyl fentanyl as an analogue of fentanyl.The Court of Appeals affirmed the lower court's decision. It found that the officers had reasonable suspicion to seize the package, the jury instruction accurately stated the law, the jury’s verdict was supported by more than sufficient evidence, and Black's motion to dismiss argument was foreclosed by precedent. View "USA v. Black" on Justia Law

Mario Giannini and Robert Czernek were involved in a series of fraudulent schemes in Bloomingdale Township, Illinois. Giannini worked for Bulldog Earth Movers, a contractor owned by his girlfriend, Debra Fazio. Czernek, the Township's Highway Commissioner, approved inflated invoices from Bulldog, and the excess funds were split between Czernek and Bulldog. Giannini, Czernek, and Fazio were indicted on counts of wire and honest services fraud. Czernek cooperated with the government and pleaded guilty, while Giannini and Fazio proceeded to trial. However, Fazio was acquitted on all counts after the government's case-in-chief.The district court had previously denied Giannini's motion for a mistrial based on the government's late disclosure of investigating agents' notes regarding an inculpatory statement he made to Czernek. Giannini also argued that the court erred in allowing the prosecutors to discuss Fazio's conduct in closing arguments, despite her acquittal.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court found that the district court did not abuse its discretion in denying the motion for a mistrial, as the late disclosure of the agents' notes did not sufficiently prejudice Giannini. The court also found no error in allowing the prosecutors to discuss Fazio's conduct, as it was highly relevant to the charges against Giannini. The court concluded that even if it was error to allow the comments, it was harmless given the overwhelming evidence against Giannini. View "United States v. Giannini" on Justia Law

The defendant, Christopher Johnson, was indicted and pleaded guilty to wire fraud and aggravated identity theft after purchasing stolen credit card data and using it to produce counterfeit cards. The district court, when calculating the loss under U.S.S.G. § 2B1.1, deferred to the guidelines commentary and assessed a $500 minimum loss for each card. Johnson argued that the guidelines commentary was not entitled to deference as an interpretation of § 2B1.1, citing the Supreme Court's decision in Kisor v. Wilkie.The district court denied Johnson's objection, holding that the term "loss" in the context of § 2B1.1 was genuinely ambiguous and that the minimum loss amount was a reasonable interpretation of that term. The court also stated that even without deferring to the guidelines commentary, it would still have assessed a loss of $500 per card. Johnson was sentenced to 58 months' imprisonment: 34 months for wire fraud and the mandatory 24 months for aggravated identity theft.On appeal to the United States Court of Appeals for the Seventh Circuit, Johnson challenged the district court's deference to the guidelines commentary. The court, however, affirmed the judgment of the district court. The court held that the Supreme Court's decision in Kisor v. Wilkie did not disturb the Supreme Court’s holding in Stinson v. United States that guidelines commentary is “authoritative unless it violates the Constitution or a federal statute, or is inconsistent with, or a plainly erroneous reading of” the guideline it interprets. The court concluded that the guidelines commentary assessing $500 minimum loss per credit card therefore remains binding under Stinson. View "USA v. Johnson" on Justia Law

The plaintiff, Mary Rodgers-Rouzier, worked as a bartender on steamboats operated by American Queen. She alleged that she and her coworkers were wrongly denied overtime wages. Rodgers-Rouzier filed a suit as a collective action, and over one hundred of her coworkers joined her proposed collective action. Meanwhile, American Queen moved to dismiss the case, arguing that Rodgers-Rouzier had agreed to arbitration. The district court denied the motion, but American Queen moved again to dismiss based on the arbitration agreement, this time invoking Indiana state law. The district court granted this motion, over Rodgers-Rouzier’s objections.The district court had previously denied American Queen's motion to dismiss the case for improper venue because Rodgers-Rouzier had agreed to arbitration. However, American Queen then moved again to dismiss based on the arbitration agreement, this time invoking Indiana state law. The district court granted this motion, over Rodgers-Rouzier’s objections that American Queen had waived its argument and the court lacked authority to apply Indiana law in this context. The court further determined that all the workers who had filed consent forms were not parties to the action.The United States Court of Appeals for the Seventh Circuit reversed the district court's decision. The court concluded that although American Queen’s arguments were not waived and the court had authority to enforce the arbitration agreement under Indiana law, Indiana law would hold American Queen to its bargain that its arbitration agreement was governed by the Federal Arbitration Act (FAA). Therefore, Rodgers-Rouzier’s case may continue in federal court. The court did not decide whether it may do so as a collective action and left that question for further litigation. View "Rodgers-Rouzier v. American Queen Steamboat Operating Company, LLC" on Justia Law

The case revolves around Seldrick Carpenter, who was serving a six-year term of supervised release after completing a federal sentence for distributing fentanyl. After the death of his mother, Carpenter began using drugs and acting out against his probation officer. When behavioral therapy failed to address these issues, his probation officer petitioned to revoke his supervised release. Carpenter was then suspected of setting a car on fire. The Probation Office alleged that Carpenter committed several supervised release violations, including arson, criminal damage to property, intimidation, and aggravated battery. Before the revocation hearing, Carpenter requested a jury trial under the Sixth Amendment and Article III, § 2, cl. 3. The district court denied the motion and presided over Carpenter’s revocation hearing without a jury. The court found Carpenter guilty of several violations and revoked his supervised release, imposing a revocation sentence of 30 months’ imprisonment.The United States Court of Appeals for the Seventh Circuit was tasked with determining whether a supervised release revocation proceeding held under 18 U.S.C. § 3583(e)(3) constitutes the “trial of [a] crime” or a “criminal prosecution” within the meaning of either clause. The court agreed with the district court's decision that it does not. The court concluded that neither the Sixth Amendment nor Section 2 of Article III of the U.S. Constitution guarantee a jury trial in a revocation hearing like Carpenter’s. A defendant in Carpenter's situation is entitled only to those procedures dictated by the Federal Rules of Criminal Procedure and the Due Process Clause of the Fifth Amendment. The court also rejected Carpenter's argument that Article III, § 2 can apply to proceedings outside the scope of the Sixth Amendment. The court affirmed the district court's decision. View "United States v. Carpenter" on Justia Law