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

The case involves Shamond Jenkins, who was convicted of robbing a Centier Bank branch in South Bend, Indiana, in December 2020. Jenkins was identified as a suspect in three robberies in northern Indiana between December 2020 and January 2021. During a traffic stop on January 8, 2021, Jenkins was found with cash, including a bait bill from the South Bend robbery, and was wearing red-and-white Air Jordan sneakers similar to those worn by the robber. Jenkins was charged with multiple counts, including the South Bend bank robbery, to which he pleaded not guilty.In the district court, Jenkins was found guilty of the South Bend bank robbery but not guilty of the Granger Centier Bank robbery. The jury could not reach a unanimous decision on the Check Into Cash robbery. Jenkins objected to the Presentence Investigation Report's recommendations, including an enhancement for obstructing justice by presenting false testimony and the inclusion of juvenile adjudications in his criminal history. The district court overruled these objections and sentenced Jenkins to 100 months in prison.The United States Court of Appeals for the Seventh Circuit reviewed Jenkins's appeal. Jenkins argued that the evidence was insufficient to convict him, that his Fifth and Sixth Amendment rights were violated due to the face mask he had to wear during the trial, and that the district court erred in applying a sentencing enhancement for perjury and in counting his juvenile convictions. The Seventh Circuit found no error in the district court's decisions. The court held that the face mask did not render the in-court identifications unduly suggestive or violate Jenkins's confrontation rights. The court also upheld the sufficiency of the evidence and the sentencing decisions, affirming Jenkins's conviction and sentence. View "USA v Jenkins" on Justia Law

Waukegan Potawatomi Casino, LLC (WPC) alleged that its Fourteenth Amendment rights were violated when the City of Waukegan did not advance its casino proposal for licensing consideration. WPC claimed it experienced intentional discrimination during the application process as a "class of one." The City of Waukegan certified three other applicants but not WPC, which alleged that the process was rigged to benefit another applicant, Lakeside Casino, LLC. WPC pointed to the relationship between the City's mayor and a founding partner of Lakeside, as well as the City's handling of supplemental information from applicants, as evidence of discrimination.The United States District Court for the Northern District of Illinois granted summary judgment for the City. The court concluded that WPC, as an arm of a sovereign Native American tribe, could not maintain a claim under 42 U.S.C. § 1983. Additionally, the court found that WPC's class-of-one equal protection claim failed because WPC was not similarly situated to the other applicants and there were multiple conceivable rational bases for the City's conduct.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court held that WPC could not carry its heavy burden as a class-of-one plaintiff. The court noted that there were several rational bases for the City's decision, including differences in the casino proposals and the applicants' experience. The court also found that WPC failed to identify a similarly situated comparator who was treated more favorably. The court concluded that the City's conduct throughout the review process, including its handling of supplemental information, had rational justifications. Thus, WPC's class-of-one claim failed under both prongs of the analysis. View "Waukegan Potawatomi Casino, LLC v City of Waukegan" on Justia Law

Manuel Antonio Herrera Hernandez, an inmate at Waupun Correctional Institution, alleged that his legal paperwork was misplaced during his temporary transfer to restrictive housing in October 2021. Before entering restrictive housing, Hernandez surrendered his personal property, including legal documents. Upon return, he signed a form indicating receipt of all his property but later realized his legal paperwork was missing. Hernandez claimed that Sergeant Theresa Lee assured him he would receive his paperwork once he returned to the general population, but it remained missing. Hernandez filed a grievance, which was rejected as untimely by the complaint examiner, and the warden affirmed this decision.Hernandez then filed a lawsuit in federal court under 42 U.S.C. § 1983, claiming that Sergeant Lee and other prison officials deprived him of his right of access to the courts. The United States District Court for the Eastern District of Wisconsin granted summary judgment for the defendants, ruling that Hernandez failed to exhaust administrative remedies.The United States Court of Appeals for the Seventh Circuit reviewed the case. Hernandez argued that his time in restrictive housing complicated his ability to file a timely grievance and that he was not provided a handbook explaining the grievance process in Spanish. The court found that Hernandez did not preserve the handbook issue in the district court. However, the court determined that there were genuine disputes regarding whether Hernandez had any reason to file a grievance before learning his paperwork was missing and whether Sergeant Lee's assurances excused his failure to exhaust administrative remedies.The Seventh Circuit reversed the district court's summary judgment and remanded the case for an evidentiary hearing to resolve the factual disputes regarding the exhaustion of administrative remedies. The court also noted the need to determine the personal involvement of the other defendants in the alleged deprivation. View "Hernandez v Lee" on Justia Law

Kein Eastman was abducted at gunpoint from his grandmother’s house by Kenwyn Frazier, taken to an apartment in East St. Louis, and subjected to threats, beatings, and a gunshot over a piece of jewelry. Eastman fled the scene with a bloodied face and has not been seen since. Kenwyn and his brother Kendrick Frazier were charged with kidnapping and found guilty by a jury. They appealed on several grounds, including a violation of Kendrick’s Sixth Amendment right to his choice of counsel, the constitutionality of the federal kidnapping statute, the sufficiency of the evidence, and aspects of their sentencing.The United States District Court for the Southern District of Illinois denied the Fraziers' motion to dismiss the indictment and their post-trial motions for acquittal or a new trial. The court also applied a four-level sentencing enhancement, finding that Eastman sustained permanent or life-threatening bodily injury. Kendrick’s request for joint representation by attorney Beau Brindley was denied due to potential conflicts of interest, and he retained separate counsel.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s decisions. The appellate court found no abuse of discretion in denying Kendrick’s choice of counsel, given the potential for conflicts of interest. The court upheld the constitutionality of the federal kidnapping statute, citing precedent that the use of instrumentalities of interstate commerce, such as cars and cellphones, suffices for federal jurisdiction. The court also found sufficient evidence to support Kendrick’s conviction for aiding and abetting the kidnapping. Lastly, the court affirmed the application of the sentencing enhancement, agreeing that the evidence supported the finding that Eastman sustained a permanent or life-threatening injury. View "United States v. Frazier" on Justia Law

Felix Franco, a commercial truck driver, was asleep in his parked semi-trailer truck when it was hit by another truck driven by an employee of Richland Refrigerated Solutions, LLC. Franco claimed that the accident caused a back injury that necessitated surgery, while Richland acknowledged the accident but disputed the cause of Franco's injury. Franco had a history of degenerative back problems and had experienced back pain before the accident. The case went to trial, and a jury found in favor of Richland.The United States District Court for the Western District of Wisconsin handled the initial trial. Franco sought to admit medical illustrations as evidence, but the court only allowed two as demonstrative exhibits. The court provided jury instructions and a special verdict form, focusing on whether the accident caused Franco's injury. The jury ultimately ruled in favor of Richland, and Franco's post-trial motions were denied.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's rulings, including the denial of Franco's motions for judgment as a matter of law and a new trial. The appellate court found that there was sufficient evidence for the jury to conclude that the accident did not cause Franco's injury. The court also upheld the jury instructions and special verdict form, stating they accurately reflected Wisconsin law. Additionally, the court found no abuse of discretion in the district court's decision to exclude two of Franco's medical illustrations. The judgment of the district court was affirmed in all respects. View "Franco v Richland Refrigerated Solutions, LLC" on Justia Law

Joshua Smitson applied for social security disability benefits and supplemental security income, claiming that his asthma and chronic obstructive pulmonary disease (COPD) prevented him from working. His medical records indicated frequent episodes of shortness of breath and difficulty walking and standing for long periods. He was hospitalized for a week in 2021 due to an acute respiratory exacerbation. Smitson used a nebulizer four times a day, with each session lasting about thirty minutes. Despite his conditions, his medication regimen effectively controlled his symptoms.An administrative law judge (ALJ) denied Smitson's application for benefits, concluding that his conditions were limiting but not disabling. The ALJ found that Smitson could manage his symptoms with proper medical treatment and determined that he had the residual functional capacity (RFC) to perform "light work" with certain limitations. A vocational expert testified that jobs were available for someone with Smitson's RFC. The United States District Court for the Southern District of Indiana affirmed the ALJ's decision. After Smitson's death, his widow, Lacey Thorlton, continued the appeal.The United States Court of Appeals for the Seventh Circuit affirmed the ALJ's decision. The court emphasized that claimants bear the burden of proving their disability and that the ALJ's decision must be supported by substantial evidence. The court found that the ALJ's conclusion that Smitson could perform light work was supported by substantial evidence, including medical records showing that his conditions were well-managed with medication. The court acknowledged that the ALJ could have more directly addressed Smitson's testimony about his nebulizer use but concluded that the ALJ's decision, when viewed holistically, sufficiently considered this evidence. The court found no compelling evidence in the record to reverse the ALJ's decision. View "Thorlton v King" on Justia Law

William Hudson was convicted in Wisconsin state court of conspiracy to commit first-degree intentional homicide and conspiracy to commit arson. The convictions stemmed from an agreement Hudson made with another inmate, Scott Seal, to kill Seal’s ex-girlfriend and commit arson in exchange for payment. Seal, however, was an informant. After Hudson was released, he met with an undercover officer posing as Seal’s defense attorney, accepted an envelope with $6,000 and the targets' addresses, and was arrested. Hudson claimed he never intended to commit the crimes but was trying to scam Seal to support himself and his sister, Dana Hudson.Hudson filed a direct appeal alleging outrageous governmental conduct and ineffective assistance of trial counsel for not arguing the government’s conduct. The Wisconsin circuit court denied postconviction relief, and the Court of Appeals of Wisconsin affirmed. The Supreme Court of Wisconsin denied review. Hudson then filed a postconviction motion under Section 974.06, claiming ineffective assistance of trial counsel for not calling Dana as a witness and not investigating her testimony. The Wisconsin circuit court held evidentiary hearings and denied relief, finding counsel’s performance was not deficient. The Court of Appeals of Wisconsin affirmed, and the Supreme Court of Wisconsin denied review.Hudson filed a habeas petition in federal court, claiming ineffective assistance of trial counsel and postconviction counsel. The district court denied the petition, holding that the state court had not misapplied Strickland v. Washington and that trial counsel’s performance satisfied Strickland’s deferential standard. The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision, concluding that even if counsel’s performance was deficient, Hudson failed to demonstrate that the deficiencies prejudiced the outcome of the case. View "Hudson v DeHaan" on Justia Law

Rhonda Sutton was charged with conspiracy to commit health care fraud. At her arraignment in June 2018, the district court appointed counsel to represent her. Sutton pleaded not guilty in January 2020. After several delays due to the COVID-19 pandemic, the district court set her trial for November 2022. In September 2022, Sutton requested her attorneys to engage in plea negotiations, but she ultimately decided to proceed to trial. She then expressed dissatisfaction with her counsel and requested new representation. Her counsel filed a motion to withdraw, which the district court denied, citing no conflict or communication breakdown and suspecting a delay tactic.The United States District Court for the Northern District of Illinois denied Sutton's motion to substitute appointed counsel, finding no conflict or communication breakdown and suspecting her request was a delay tactic. The trial proceeded as scheduled, and the jury returned guilty verdicts on all counts. Post-trial, Sutton's counsel filed another motion to withdraw, which the district court granted, appointing new counsel for sentencing. At sentencing, Sutton raised objections to the proposed conditions of supervised release, but she waived her challenge to one condition by not objecting at the appropriate time.The United States Court of Appeals for the Seventh Circuit reviewed the case. Sutton raised two issues on appeal: the denial of her pretrial motion to withdraw and the constitutionality of a supervised release condition. The court held that the district court did not abuse its discretion in denying the motion to withdraw, as Sutton had no right to insist on counsel she could not afford, and her request appeared to be a delay tactic. The court also found that Sutton waived her challenge to the supervised release condition by not objecting at the appropriate time. The judgment of the district court was affirmed. View "USA v Sutton" on Justia Law

Jeffery Henson was convicted of federal fraud, including aggravated identity theft, money laundering, and wire fraud, for diverting nearly $330,000 from his employer to his personal account. He was ordered to pay $436,495.93 in restitution. Following his arrest, Illinois police found $17,390 in cash in his car. The government sought to apply this cash towards Henson's restitution, but Henson argued that the money was obtained through an illegal search and seizure, as the warrant was issued nine hours after the search.The United States District Court for the Central District of Illinois, through a magistrate judge, granted the government's motion to turn over the cash. Henson appealed, contending that the magistrate judge lacked the authority to issue a final decision on the matter.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court determined that the magistrate judge acted outside of his authority, as there was no final decision in the case. The Federal Magistrates Act and the local rules of the Central District of Illinois did not authorize the magistrate judge to issue a final decision on the turnover motion without the district court's explicit assignment. Consequently, the Seventh Circuit dismissed the appeal for lack of appellate jurisdiction, as the magistrate judge's order was not an appealable final decision. View "USA v Henson" on Justia Law

In March 2021, Jamal Shehadeh was involved in a controlled drug buy orchestrated by the Taylorville, Illinois Police Department. A confidential informant paid Shehadeh for methamphetamine, and the transaction was recorded on video. Shehadeh was arrested shortly after leaving the informant's house, waived his constitutional rights, and admitted to delivering the drugs. Shehadeh claimed he knew the buy was a setup and intended to embarrass the police by taking the buy money without delivering drugs. However, he ended up giving the informant methamphetamine, which he claimed he thought was road salt.A grand jury indicted Shehadeh for delivering methamphetamine. The government moved to preclude cross-examination of a witness, Chief Dwayne Wheeler, about past misconduct, which Shehadeh's counsel did not oppose. The district court granted the motion. Shehadeh later filed a pro se motion to cross-examine Wheeler on additional topics, which the court struck. At trial, Shehadeh testified about his plan, but the jury found him guilty. The district court applied a two-level obstruction of justice enhancement and a career offender enhancement, resulting in a Guidelines range of 262 to 327 months. Shehadeh was sentenced to 92 months in prison.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that Shehadeh waived his evidentiary arguments by not objecting to the district court's rulings and failing to renew objections during the trial. The court also concluded that any error in applying the obstruction of justice enhancement was harmless because the career offender enhancement controlled the length of Shehadeh's sentence. The Seventh Circuit affirmed the conviction and sentence. View "USA v Shehadeh" on Justia Law