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

Randall Ewing and Yasmany Gomez entered into a contract with 1645 W. Farragut LLC (Farragut) to purchase a house. The house was in need of substantial renovations, but Ewing and Gomez proceeded with the contract based on Farragut's assurance that the house would be renovated and ready by closing time. Unbeknownst to Ewing and Gomez, the house was under a stop work order, which hindered their ability to secure a mortgage. When they requested their earnest money back, Farragut refused. They subsequently sued Farragut for breach of contract, common law fraud, and fraud under the Illinois Consumer Fraud Act. The United States District Court for the Northern District of Illinois found Farragut liable for fraud and breach of contract and awarded Ewing and Gomez $905,000 in damages. Farragut appealed the decision and Ewing and Gomez cross-appealed, seeking to add Farragut's principal, Erik Carrier, to the case. The United States Court of Appeals for the Seventh Circuit affirmed the District Court's decisions, finding that the record supported the damages awarded and that the District Court did not abuse its discretion in denying the motion for a new trial and the motions to amend. View "Ewing v. 1645 W. Farragut LLC" on Justia Law

This case concerns Johnnie Wesley, who was brought in for questioning by Wisconsin police in connection with a murder investigation. Wesley invoked his right to remain silent during the initial interrogation, and the interrogation ceased. However, he was interrogated two more times, during which he made incriminating statements implicating himself in the murder. Wesley was subsequently charged with felony murder. He moved to suppress the incriminating statements on two grounds: (1) the officers did not honor his initial invocation of his right to remain silent, and (2) he unequivocally invoked his right to remain silent during the third interrogation. The motion was denied and Wesley was convicted. He then petitioned for a writ of habeas corpus in the Eastern District of Wisconsin, which was dismissed.On appeal to the United States Court of Appeals for the Seventh Circuit, the court affirmed the lower court's decisions. It held that the Wisconsin Court of Appeals reasonably applied Supreme Court precedent to Wesley’s case. The court determined that Wesley's right to remain silent was "scrupulously honored" after he invoked it during the first interrogation, and that he did not unequivocally invoke his right to remain silent during the third interrogation. The court reasoned that Wesley's statements during the third interrogation could reasonably be interpreted as exculpatory, rather than as an invocation of silence. View "Wesley v. Hepp" on Justia Law

In the United States Court of Appeals for the Seventh Circuit, the court looked at the appeal from the United States District Court for the Northern District of Illinois, Eastern Division. The defendant, Johneak Johnson, was indicted for possessing a firearm as a person previously convicted of a felony, in violation of 18 U.S.C. § 922(g)(1). The government appealed a pretrial ruling by the District Court, which excluded evidence of a laser sight attached to the firearm. The District Court had ruled that the evidence would cause unfair prejudice to the defendant, outweighing its probative value. The government's proposal to limit the laser sight evidence to reduce any risk of unfair prejudice was also denied by the District Court.The Court of Appeals reversed the District Court's decision, ruling that the District Court had incorrectly assessed the balance between the probative value of the laser sight evidence and the risk of unfair prejudice. The Court of Appeals held that the laser sight evidence was central to proving a key disputed element of the offense – possession of the firearm. It also found that the laser sight evidence tended to corroborate the testimony of the government's eyewitnesses, which was critical given the defense's intended strategy of attacking their credibility.The Court of Appeals also disagreed with the District Court's assessment of the risk of unfair prejudice, holding that the government's proposed limits on the laser sight evidence should minimize any risk that it will cause the jury to view the defendant as unduly dangerous. Consequently, the Court of Appeals held that the District Court abused its discretion in excluding the laser sight evidence under Rule 403 and remanded the case for further proceedings. View "USA v. Johnson" on Justia Law

This case involves the appeal of a judgment convicting Byron Pierson of unlawful possession of a firearm by a felon. Pierson contested the decision, arguing that the district court erred by not holding a hearing to determine if he had knowingly and voluntarily waived certain rights when he entered into a proffer agreement with the government. Furthermore, he argued that the court erred by allowing a witness to testify about the investigation that led to his arrest. The United States Court of Appeals For the Seventh Circuit affirmed the district court's decisions.The case began when an Indianapolis Police Officer responded to a 911 call from a woman who reported that Pierson threatened to "come back and shoot the house up." After learning about Pierson's criminal record and obtaining a description of his car, the officer decided to return to the woman's home later that evening. Upon returning, the officer saw the car described by the woman and initiated a traffic stop. Pierson was in the back seat of the car. When asked to step out of the car, Pierson hesitated and then fled on foot when an attempt was made to handcuff him. During the ensuing chase, officers saw a firearm under Pierson's body, which was later retrieved and used as evidence against him.Prior to his trial, Pierson had entered into plea negotiations with the government, signing a Proffer Letter that waived certain rights. After admitting possession of the firearm in two proffer sessions, Pierson withdrew his plea and decided to go to trial. Pierson moved to exclude statements he made during these plea negotiations, arguing that he had not knowingly and voluntarily waived his rights.The Court of Appeals found that Pierson failed to provide an evidentiary basis for his assertion that he had not knowingly and voluntarily entered into the proffer agreement. Given the lack of evidence to the contrary, the court did not find it necessary to hold an evidentiary hearing, and the proffer waiver was deemed valid. The court also noted that the government never sought to introduce any of Pierson's proffer statements at trial, meaning any potential error in refusing to hold a hearing was harmless.Additionally, Pierson contended that the district court erred in allowing the government to present evidence about the investigation that led to his arrest. The court found that Pierson had opened the door to this testimony in his opening statement by referencing a complaint made by his ex-girlfriend. The district court did not abuse its discretion in allowing this testimony, and immediately gave a limiting instruction to the jury on the proper use of this evidence.Given the strong evidence of Pierson's guilt, the Court of Appeals affirmed the district court's decisions. View "USA v. Pierson" on Justia Law

In this case, the United States Court of Appeals for the Seventh Circuit reviewed the denial of asylum, withholding of removal, and protection under the Convention Against Torture (“CAT”) for petitioner Kamaljit Singh, a native and citizen of India. Singh alleged that he had been persecuted in India due to his support for a minority political party, and feared return due to ongoing threats. The immigration judge (“IJ”) and the Board of Immigration Appeals (“BIA”) both denied Singh’s application on credibility grounds, finding inconsistencies in his account. On appeal, the Seventh Circuit upheld the BIA's decision, finding that the BIA's adverse credibility finding was supported by substantial evidence. The court also agreed with the BIA's determination that the harm Singh had suffered in India did not rise to the level of past persecution necessary to establish eligibility for asylum or withholding of removal. In addition, the court held that Singh had waived his claims for future persecution and CAT protection by failing to properly raise them before the BIA. Lastly, the court determined that Singh's due process claims, including a claim of ineffective assistance of counsel, had not been properly exhausted before the BIA and therefore could not be reviewed on appeal. As a result, Singh's petition for review was denied. View "Singh v. Merrick Garland" on Justia Law

The case in question was brought before the United States Court of Appeals for the Seventh Circuit. The plaintiff, Christine Boardman, was the former president of Local 73, a regional affiliate of the Service Employees International Union (International). The International imposed an emergency trusteeship on Local 73 due to internal conflict and removed Boardman from her position. In response, Boardman sued under the Labor Management Reporting and Disclosure Act, alleging that the trusteeship was a pretextual retaliation for her protected speech.The court agreed with the defendants' argument that the trusteeship was necessary to restore order and democratic procedures within Local 73, given the intense infighting between Boardman and Secretary-Treasurer Matthew Brandon. The court reasoned that this constituted a valid purpose for the trusteeship under the Act, which allows trusteeships to be established for purposes including "restoring democratic procedures."The court rejected Boardman's claim that the trusteeship was retaliatory, arguing that even if there was animus between Boardman and the International's President, Mary Kay Henry, this did not negate the valid purpose for the trusteeship. Furthermore, the court found no evidence that Boardman was treated differently from other union members who also engaged in protected speech. The court's decision affirmed the lower court's grant of summary judgment in favor of the defendants. View "Boardman v. Service Employees International Union" on Justia Law

Erik Bertaud, who suffered serious injuries when a tree branch fell on his head, applied for disability insurance benefits and supplemental security income from the Social Security Administration. His application was denied, and he appealed. The Appeals Council remanded the case twice, but after the third denial, Bertaud's request for review was denied, making the ALJ's decision the final decision of the Commissioner. Bertaud then sought judicial review, arguing that the ALJ had failed to develop the record of his disability, pointing to over 800 pages of new medical evidence. The district court denied Bertaud's motion for summary judgment and affirmed the Commissioner's decision, and Bertaud appealed to the United States Court of Appeals for the Seventh Circuit.The court held that although an ALJ has a duty to develop a full and fair record, this duty is limited when the claimant is represented by an attorney. The claimant's duty to submit evidence is ongoing and covers any additional related evidence they become aware of. The court noted that Bertaud was represented and his attorney had confirmed that the evidence was complete and supplemented the record when necessary. Therefore, the court concluded that the ALJ did not fail to develop Bertaud's medical record. The court affirmed the district court's decision denying Bertaud's motion for summary judgment and affirming the decision of the Commissioner. View "Bertaud v. O'Malley" on Justia Law

This case involves Daryl McGhee, who was charged with several federal offenses related to possession of a firearm and cocaine. The charges arose after the police received a 911 call from McGhee's wife reporting domestic violence and alleging that McGhee had left their house carrying a gun and a leather bag. The police followed footprints in the snow to find McGhee and later found the bag, which contained the gun and cocaine, under a nearby dumpster. During the trial, the United States District Court for the Central District of Illinois issued an order prohibiting McGhee from testifying about the domestic violence incident, even to deny the allegation, threatening to jail him and his defense counsel if they violated the order.The United States Court of Appeals for the Seventh Circuit found that while the district court's decision to limit McGhee's testimony was valid as it avoided turning the trial into a domestic dispute, the order was overly broad as it completely silenced McGhee, leaving the jury to potentially conclude that he did hit his wife. Despite this, the appellate court concluded that the exclusionary order did not have a substantial influence over the jury and did not result in a verdict inconsistent with substantial justice. The court expressed concerns about the district court's treatment of McGhee's defense counsel but ultimately affirmed the district court's judgment. View "USA v. McGhee" on Justia Law

In this case, the United States Court of Appeals for the Seventh Circuit affirmed a district court's decision to grant summary judgment in favor of the defendants on all federal claims made by the plaintiff. The plaintiff, Lamont Moore, was an inmate who filed a suit against a prison guard and the prison where he was subsequently sent to, alleging failure to protect him from another inmate's attack, violation of his rights under the Americans with Disabilities Act (ADA), and a conspiracy among the investigating officers to falsify the official report of the incident.The court found that Moore was unable to demonstrate that the prison guard was aware of and disregarded an excessive risk to his safety, a requirement for a successful claim of failure to protect. Moore's testimony indicated that his complaints to the guard about the other inmate were about annoyance and horseplay, not a fear for his safety.Regarding his ADA claim, the court found that Moore failed to demonstrate that any disability-based discrimination was intentional. Moore complained about the distance to the healthcare unit but never alerted anyone at any prison that he required an accommodation in order to access services. He was able to access every service in prison, albeit more slowly due to his loss of vision in one eye. There was no evidence that any defendant knew that he could not access any services or made a deliberate choice to deny him access to services.After resolving all of the federal claims, the court declined to exercise supplemental jurisdiction over the state law claims. View "Moore v. Western Illinois Correctional Center" on Justia Law

The case involves Timothy Bell, who, after serving a sentence for sexual assault, remained incarcerated in an Illinois prison for over 16 years under the state’s Sexually Violent Persons Commitment Act. Bell sued two state officials under 42 U.S.C. § 1983, claiming that his civil commitment had exceeded the duration allowed by the Act. The district court dismissed Bell's case, citing the Supreme Court’s 1994 decision in Heck v. Humphrey as barring his claims. On appeal, the United States Court of Appeals for the Seventh Circuit agreed with the lower court's judgment.The main holding in the case is that Heck v. Humphrey's favorable-termination requirement, which prevents prisoners from using § 1983 to challenge the fact or duration of their confinement unless their conviction or disciplinary sanction has been invalidated, applies to civil detainees such as those confined under the Illinois Sexually Violent Persons Commitment Act. The court reasoned that like a prisoner wishing to contest a criminal conviction or sentence, a civil detainee cannot sue a state official under § 1983 for violating his constitutional rights when a judgment in the plaintiff’s favor would necessarily imply the invalidity of his confinement, unless the grounds for the confinement have already been set aside in other proceedings. This conclusion remains the same regardless of whether the individual is civilly committed or criminally imprisoned.Furthermore, the court pointed out that Bell's release from confinement to home confinement did not change the court's conclusion. The Heck bar applies until the judgment that caused the detention is invalidated, even after a detainee's release. Therefore, Bell must wait until he receives a favorable termination of his civil commitment before seeking relief under § 1983 for his allegedly excessively long confinement. View "Bell v. Raoul" on Justia Law