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

Joe Feazell, an inmate at Pontiac Correctional Center, sued his doctor, Andrew Tilden, and the prison’s healthcare contractor, Wexford Health Sources, Inc., alleging deliberate indifference to his hemorrhoid condition and significant gastrointestinal bleeding, violating the Eighth Amendment. Feazell claimed that Dr. Tilden failed to respond promptly to his abnormal lab results and adequately treat his hemorrhoids, while Wexford's treatment protocol was ineffective and deliberately indifferent.The United States District Court for the Central District of Illinois initially denied the defendants' motion for summary judgment. The parties consented to proceed before a magistrate judge, who later granted summary judgment for Wexford and partial summary judgment for Dr. Tilden. Feazell went to trial on his remaining claim against Dr. Tilden but was barred from testifying about his medical diagnoses or their causes. The jury returned a verdict for the defense.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the magistrate judge's summary judgment decision, finding no evidence that Wexford's Collegial Review policy caused Feazell to receive deficient care or that Dr. Tilden was aware of Feazell's hemorrhoids before the colonoscopy. The court also upheld the magistrate judge's evidentiary rulings, barring Feazell from testifying about medical diagnoses or causation, as he was not qualified to provide such testimony.The Seventh Circuit concluded that Feazell failed to demonstrate a genuine issue of material fact regarding Wexford's policy causing a violation of his Eighth Amendment rights and that Dr. Tilden was not deliberately indifferent to Feazell's medical needs. The court affirmed the district court's judgment. View "Feazell v Wexford Health Sources, Inc." on Justia Law

Defendants Falandis Russell and Terrance Williams committed a series of armed commercial robberies in Chicago over nearly a year and a half. They were indicted for conspiracy to obstruct commerce by robbery, with Russell facing eleven additional counts and Williams six counts of obstruction of commerce by robbery. Russell's counsel requested a forensic psychologist to assess his cognitive capacity, leading to a diagnosis of intellectual disability and ADHD. A competency examination was conducted, and Dr. Jajko found Russell unfit for trial. However, further evaluations by Dr. Muhkin and Dr. Dinwiddie concluded that Russell was competent, suggesting he was malingering.The United States District Court for the Northern District of Illinois held a competency hearing and found Russell competent to stand trial. Both defendants pleaded guilty, with Russell reserving the right to challenge the competency determination. Russell was sentenced to 180 months of imprisonment and 60 months of supervised release, while Williams received 114 months of imprisonment. Williams objected to a supervised release condition requiring him to notify another person if his probation officer determined he posed a risk, but the court imposed it with amendments.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's competency determination for Russell, finding no clear error in the reliance on the evaluations by Drs. Muhkin and Dinwiddie. The court also found no procedural error in Russell's sentencing, noting that the district court adequately considered his cognitive impairments. However, the court vacated the supervised release condition imposed on Williams, agreeing that certain terms were vague, and remanded for further proceedings to reconsider the necessity and scope of the condition. View "USA v Williams" on Justia Law

Mark Petersen sued Deputy Stefanie Pedersen under 42 U.S.C. § 1983, alleging false arrest for drunk driving and an unlawful blood draw. On December 27, 2018, Deputy Pedersen responded to a car crash in rural Wisconsin. She found Petersen, who was intoxicated, attempting to change a tire on a car registered to him. Witnesses confirmed he was the only person near the car. Petersen had a history of uncooperative behavior with law enforcement and prior OWI charges. Based on the scene, his behavior, and his intoxication, Pedersen arrested him for OWI and obtained a search warrant for a blood draw, which confirmed his high BAC.In the Circuit Court of Winnebago County, Petersen was charged with OWI – 4th Offense. He moved to suppress the BAC evidence, arguing lack of probable cause for his arrest. The state court granted his motion, leading to the dismissal of the charges. Petersen then filed a § 1983 lawsuit in the United States District Court for the Eastern District of Wisconsin, which was reduced to claims against Deputy Pedersen for false arrest and unreasonable search. The district court granted summary judgment for Pedersen, finding probable cause for the arrest and a valid search warrant for the blood draw, and also granted her qualified immunity.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s decision, holding that probable cause supported Petersen’s arrest based on the totality of the circumstances, including his intoxication, the scene of the crash, and witness statements. The court also found the blood draw was lawful as it was conducted pursuant to a valid search warrant. Additionally, the court held that Deputy Pedersen was entitled to qualified immunity for both the arrest and the blood draw. View "Petersen v Pedersen" on Justia Law

Derrick Clark and Shawn Mesner worked for Didion Milling, Inc., a corn milling company. In May 2017, Didion’s grain mill exploded, killing five employees. The Occupational Health and Safety Administration (OSHA) investigated and referred Didion for criminal prosecution. The government charged Didion and several employees with federal crimes related to their work at the mill. Clark and Mesner proceeded to trial, challenging the district court’s evidentiary rulings, jury instructions, the indictment, the sufficiency of the evidence, and the constitutionality of their convictions.The United States District Court for the Western District of Wisconsin convicted Clark on four counts and Mesner on two counts. Clark was found guilty of conspiracy to commit federal offenses, false entries in records, using false documents within the EPA’s jurisdiction, and obstruction of agency proceedings. Mesner was found guilty of conspiracy to commit mail and wire fraud and conspiracy to commit federal offenses. Both defendants were sentenced to 24 months’ imprisonment and one year of supervised release.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court vacated Mesner’s conviction on Count 4, remanding for an entry of judgment of acquittal and further proceedings consistent with the opinion. The court affirmed the district court’s evidentiary rulings and jury instructions, as well as Clark’s convictions and Mesner’s conviction on Count 1. The court found sufficient evidence to support the convictions and determined that the jury instructions, when considered as a whole, accurately reflected the law. The court also rejected challenges to the constitutionality of the OSHA regulation involved. View "USA v Mesner" on Justia Law

Carlos Antonio de Paz-Peraza, a citizen of El Salvador, sought asylum and withholding of removal in the United States due to threats from MS-13 gang members. Between May and July 2016, the gang threatened him multiple times, demanding he join them or risk his family's safety. They stole his phone and work tools, and on two occasions in July, they threatened him with a firearm, resulting in a shootout where both a gang member and de Paz-Peraza's police officer friend were shot. De Paz-Peraza fled to the United States on July 25, 2016, fearing for his life and the safety of his family, who continued to receive threats from the gang.The Department of Homeland Security initiated removal proceedings against de Paz-Peraza, which he conceded. He applied for asylum, withholding of removal, and relief under the Convention Against Torture (CAT). An Immigration Judge (IJ) found him credible and acknowledged his past persecution but denied his asylum application, stating that his political opinion was not expressed to the gang and that his proposed social groups were not cognizable. The IJ also found no nexus between the harm suffered and any proposed social group, concluding that the gang targeted him for recruitment and not because of his membership in a particular social group. The IJ denied withholding of removal on the same grounds and rejected his CAT claim, as he feared private actors, not the government. The Board of Immigration Appeals affirmed the IJ's decision without a written opinion.The United States Court of Appeals for the Seventh Circuit reviewed the IJ's decision under the substantial evidence standard. The court held that de Paz-Peraza failed to establish a nexus between his persecution and his membership in the proposed social group of young male Salvadorans. The court found that the gang's threats were related to recruitment and retaliation, not his social group status. Consequently, the court denied his petition for review. View "Antonio de Paz-Peraza v. Bondi" on Justia Law

Employees of United Airlines, including pilots, flight attendants, and other staff, challenged the company's COVID-19 vaccination mandate and masking requirement issued in 2021. United required employees to either get vaccinated or apply for religious or medical exemptions by specific deadlines. Plaintiffs alleged that despite submitting or attempting to submit exemption requests, they were either fired, placed on unpaid leave, or subjected to a hostile work environment.The United States District Court for the Northern District of Illinois dismissed the plaintiffs' claims with prejudice, finding that they had not stated any viable claim for relief despite having sufficient opportunities to do so. The court addressed each of the plaintiffs' twelve claims, noting that many were forfeited due to the plaintiffs' failure to respond to substantive arguments. The court also found deficiencies in the proposed amended complaints and ultimately dismissed the action with prejudice after determining that further amendments would be futile.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that the plaintiffs' claims were either improperly preserved or inadequately pled. The court found that the plaintiffs had forfeited their FDCA, invasion of privacy, and negligence claims by failing to address the district court's findings of forfeiture. The court also upheld the dismissal of the Illinois Whistleblower Act claim, as the plaintiffs did not show how receiving a COVID-19 vaccine would violate federal regulations. Additionally, the court affirmed the dismissal of the Title VII claims due to the plaintiffs' failure to obtain right-to-sue letters from the EEOC, which is a prerequisite for such lawsuits. The appellate court concluded that the district court did not err in denying further opportunities to amend the complaint. View "Anderson v. United Airlines" on Justia Law

Roger Snake, an elder member of the Ho-Chunk tribe, pleaded guilty in 2011 to two counts of abusive sexual contact with minors. After completing his prison sentence in 2020, he began a lifetime term of supervised release. Snake violated several conditions of his release, including having unapproved and unsupervised contact with minors and traveling outside the judicial district without permission. The district court revoked his supervised release and sentenced him to 24 months in prison, which was above the recommended range in the Sentencing Guidelines.The United States District Court for the Western District of Wisconsin initially addressed Snake's violations informally, reminding him of the conditions of his supervised release. However, after further violations, including being found alone with minors in his home, the court issued a summons. Snake admitted to the violations, and his lawyer requested home detention instead of prison, citing his role as a tribal elder. The district court rejected this argument, emphasizing the severity of his violations and the risk he posed to minors.The United States Court of Appeals for the Seventh Circuit reviewed the case. Snake argued that the district court failed to adequately explain the reasons for imposing a sentence above the guideline range. The appellate court, applying a highly deferential standard of review, found that the district court had sufficiently explained its decision. The court noted that the district judge had considered the relevant statutory factors and the egregiousness of Snake's violations. The appellate court affirmed the district court's decision, emphasizing the need for clear explanations in sentencing and the importance of addressing potential procedural errors promptly. View "United States v. Snake" on Justia Law

Lazerek Austin, a state prisoner, filed a lawsuit under 42 U.S.C. § 1983 against three medical providers, alleging deliberate indifference to his serious medical needs in violation of the Eighth Amendment. Austin, representing himself, requested the court to recruit counsel due to his severe mental illness and lack of access to legal resources. The district court initially granted his motion for recruited counsel but was unable to find a volunteer attorney despite extensive efforts. Consequently, Austin continued to litigate his case pro se, participating in discovery and responding to motions.The United States District Court for the Central District of Illinois eventually granted summary judgment in favor of the defendants, concluding that a reasonable jury could not find that they violated Austin’s constitutional rights. Austin appealed, arguing that the district court erred by not continuing to search for counsel after initially granting his motion.The United States Court of Appeals for the Seventh Circuit reviewed the district court's decision for abuse of discretion. The appellate court noted that federal courts cannot compel attorneys to provide free services to civil litigants and that the district court made reasonable efforts to recruit counsel. The court emphasized that the district court was not required to search indefinitely for a volunteer attorney and that it reasonably concluded Austin was capable of litigating his case pro se. The appellate court affirmed the district court's decision, finding no abuse of discretion in its handling of Austin's motion for recruited counsel and its determination that Austin could proceed without counsel. View "Austin v. Hansen" on Justia Law

In January 2017, Deaunta Tyler, along with Ledell Tyler and Dalvent Jackson, forcibly entered a home in Rock Island, Illinois, armed with firearms, searching for cocaine. They found a family instead and, brandishing weapons, demanded the non-existent drugs. The intruders moved the family around the house at gunpoint, passing firearms among themselves and threatening to kill the victims. Jackson fired a handgun inside the house. The intruders eventually left with cash and a small amount of marijuana. The next day, police identified the men, leading to a high-speed chase and Tyler's eventual arrest.A grand jury indicted Tyler on three counts: attempted Hobbs Act robbery, possession of a firearm in furtherance of a crime of violence, and being a felon in possession of a firearm. Tyler was convicted on all counts. The district court sentenced him to 330 months in prison. Following the Supreme Court's decision in United States v. Taylor, which held that attempted Hobbs Act robbery is not a "crime of violence" under 18 U.S.C. § 924(c), Tyler moved to vacate his § 924(c) conviction. The district court granted the motion, vacated the § 924(c) conviction, and resentenced Tyler to 240 months.Tyler appealed his revised sentence, arguing that the district court failed to address his key arguments in mitigation and provided an inadequate explanation for the sentence. The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court held that Tyler waived any procedural objection regarding the court’s failure to consider his arguments in mitigation by confirming that the court had addressed his principal points. Additionally, the appellate court found that the district court adequately explained its reasons for imposing a revised sentence within the guideline range. View "United States v Tyler" on Justia Law

Epic Systems Corporation sued Tata Consultancy Services Limited and Tata America International Corporation for unauthorized use of confidential information. A jury awarded Epic $240 million in compensatory damages and $700 million in punitive damages. The district court reduced these amounts to $140 million and $280 million, respectively, and entered judgment in 2017. The Seventh Circuit affirmed the compensatory damages but limited the punitive damages to $140 million, leading to a new judgment in 2022. Tata agreed to pay postjudgment interest on the compensatory damages from 2017 but argued that interest on the punitive damages should start from 2022. The district court sided with Tata, and Epic appealed.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court noted that both the 2017 and 2022 judgments included $140 million in compensatory damages and at least $140 million in punitive damages. The court referenced the Supreme Court's decision in Kaiser Aluminum & Chemical Corp. v. Bonjorno, which held that postjudgment interest should be based on the date when damages became ascertainable. The Seventh Circuit concluded that the $140 million punitive damages were ascertainable from the 2017 judgment, as neither the district court nor the appellate court had ever deemed this amount excessive.The Seventh Circuit reversed the district court's decision and remanded the case with instructions to award postjudgment interest on the $140 million punitive damages starting from October 3, 2017. View "Epic Systems Corporation v Tata Consultancy Services Limited" on Justia Law