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

A defendant was indicted on multiple federal charges, including sex trafficking by force, transporting a victim across state lines with the intent of prostitution, and coercing or enticing a victim to travel interstate for prostitution-related activities. During jury selection, a prospective juror with experience in local law enforcement expressed doubts about her ability to remain impartial, suggesting that cases typically proceed only when there is sufficient evidence. Her comments were made in the presence of other prospective jurors.After this exchange, the defendant moved to strike the entire venire, arguing that the comments had irreparably tainted the panel. The United States District Court for the Northern District of Illinois denied the motion but excused the individual juror for cause. The court reasoned that her experience was limited to a police department unrelated to the case and emphasized that it had already instructed the panel multiple times that an indictment is not evidence of guilt. The defendant was ultimately convicted on all counts, and his motion for a new trial—reiterating his concerns about jury prejudice—was denied by the district court, which found no prejudice resulted from the juror’s comments.On appeal, the United States Court of Appeals for the Seventh Circuit considered whether the district court abused its discretion in refusing to question or strike the rest of the venire and in providing the jury with a redacted copy of the indictment during deliberations. The Seventh Circuit held that the district court acted within its discretion in both respects, noting the low probability of prejudice, the adequacy of curative instructions, and the routine nature of providing indictments with proper safeguards. The court also rejected the argument of cumulative error and affirmed the judgment of the district court. View "USA v Thomas" on Justia Law

Two individuals who held leadership positions at a local public housing authority in South Bend, Indiana, orchestrated a scheme in which they collaborated with several contractors to submit false invoices for maintenance work that was never performed. The contractors cashed checks issued by the housing authority for these fictitious services and shared the proceeds with the two employees. This fraudulent activity came to light after a casino employee observed the pair gambling large amounts of cash and reported the suspicious behavior to law enforcement. Following an investigation, both individuals were indicted on multiple counts, including conspiracy to commit wire and bank fraud, several counts of bank fraud, wire fraud, and federal program theft.The United States District Court for the Northern District of Indiana presided over their trial. After the government presented its case, both defendants moved for judgments of acquittal on the wire fraud charges; the court reserved ruling, and the jury ultimately convicted both individuals on the majority of counts, although one was acquitted on a wire fraud count. The district court denied the motions for acquittal, imposed prison sentences, and ordered substantial restitution. The defendants appealed their convictions and sentences.The United States Court of Appeals for the Seventh Circuit reviewed the appeals. It held that the evidence was insufficient to sustain the bank fraud convictions because the government failed to prove that any false statement was made to a bank, as required by 18 U.S.C. § 1344(2), and therefore reversed those convictions. However, the Seventh Circuit affirmed the wire fraud convictions, finding that a rational jury could conclude the fraudulent scheme furthered the transmission of funds via interstate wire. The court also affirmed one defendant’s sentence enhancement for abuse of a position of trust, finding no clear error or harmless error. The case was remanded solely to correct a clerical error in the restitution order. View "United States v. Smith" on Justia Law

Plaintiffs filed a class action against the Department of Homeland Security and Immigration and Customs Enforcement, alleging that the agencies were arresting noncitizens without a warrant in violation of 8 U.S.C. § 1357(a)(2). After years of litigation, the parties entered into a Consent Decree in 2021, approved by the United States District Court for the Northern District of Illinois in 2022. The Decree required the agencies to issue a policy statement, train officers, and document compliance with § 1357(a)(2). It also outlined procedures for enforcement and modification if violations were alleged.Prior to the Decree’s scheduled expiration in May 2025, Plaintiffs moved to enforce its terms and to extend its duration, asserting substantial noncompliance by Defendants. While these motions were pending, a DHS official declared the Decree terminated. On October 7, 2025, the district court found Defendants had violated the Decree, extended its term by 118 days, and ordered compliance-related relief. Later, Plaintiffs sought release or alternative detention for hundreds of individuals allegedly arrested in violation of the Decree. On November 13, 2025, the district court ordered the release of 13 individuals whom both parties agreed were arrested unlawfully, and additionally ordered release or alternatives for approximately 442 “potential class members,” pending determinations of violation.The United States Court of Appeals for the Seventh Circuit reviewed Defendants’ emergency motion to stay the district court’s October 7 and November 13 orders. The Seventh Circuit denied the request to stay the extension of the Consent Decree, holding that Defendants were unlikely to succeed on the merits of their argument that the extension violated 8 U.S.C. § 1252(f)(1). However, the court granted the stay as to the November 13 release order for those arrested pursuant to I-200 warrants and for “potential class members” pending individualized determinations under the Decree. The ruling sets forth the standards for stays and clarifies the limitations of § 1252(f)(1) in the context of class-wide injunctive relief and consent decree enforcement. View "Castanon Nava v. Department of Homeland Security" on Justia Law

A special agent with Homeland Security Investigations was discovered to have stolen money from criminal targets, embezzled agency funds, and entered into a cash-for-protection arrangement with a confidential source. The agent’s conduct came to light after the confidential source was arrested by the DEA, and text messages between the two were uncovered. Investigators found that the agent deleted incriminating messages, misappropriated cash from drug dealers and agency sources, manipulated controlled buys for personal gain, and protected his source from law enforcement scrutiny. The agent was also shown to have structured cash deposits to evade bank reporting requirements and failed to report significant taxable income.The United States District Court for the Northern District of Illinois, Eastern Division, conducted a thirteen-day jury trial in 2023. The jury found the agent guilty on all counts, including filing false tax returns, structuring cash transactions, and concealing material facts from the government. The district court denied the agent’s post-trial motions for acquittal and a new trial, then imposed sentence. The agent appealed, contesting the sufficiency of the evidence supporting his conviction.The United States Court of Appeals for the Seventh Circuit reviewed the case. Applying the appropriate standards of review, the court held that there was sufficient evidence for a rational jury to convict on all counts. The evidence included direct and indirect proof of unreported income, clear indications of structuring to evade reporting requirements, and material omissions on government forms. The court found no grounds to disturb the jury’s credibility determinations or the district court’s denial of post-trial motions. Accordingly, the Seventh Circuit affirmed the judgment of the district court. View "USA v Sabaini" on Justia Law

Robdarius Williams participated in the robbery of an AT&T store, during which a confederate brandished a rifle at a store employee. Prior to the robbery, law enforcement, as part of an ongoing investigation, installed a GPS tracker on a car registered to Williams’s mother. Surveillance revealed Williams driving the car to pick up his accomplices, including Quintez Tucker, who was seen with a rifle. The group switched license plates and circled a shopping center before Tucker and another man entered the AT&T store, with one carrying the rifle visibly concealed. Inside, the rifle was displayed and pointed at an employee, and instructions were given via speakerphone by someone with a deep voice, which matched Williams’s description. The robbers fled in Williams’s car and were later apprehended.The United States District Court for the Southern District of Indiana tried Williams on charges of Hobbs Act robbery and aiding and abetting the brandishing of a firearm during a crime of violence. A jury convicted Williams on both counts. The district court sentenced him to a total of 114 months, including the mandatory minimum for brandishing. Williams did not move for a judgment of acquittal at trial.On appeal to the United States Court of Appeals for the Seventh Circuit, Williams challenged the sufficiency of the evidence for the aiding and abetting brandishing conviction, arguing the government failed to prove he had advance knowledge that the rifle would be brandished. Applying the plain error standard due to Williams’s failure to seek acquittal below, the Seventh Circuit held that the evidence was sufficient for a rational jury to conclude Williams had the requisite advance knowledge. The court affirmed the conviction, finding no manifest miscarriage of justice. View "USA v Williams" on Justia Law

The petitioner was convicted following a jury trial for filing a fraudulent tax return and theft of government funds, after he submitted a tax form claiming a large refund based on a mistaken belief about a government “trust” linked to Social Security. He received and spent the refund, then requested another, which was denied. The IRS investigated, and he later filed a document stating he was deceased. His defense at trial centered on his claim that he misunderstood tax law due to information from an online forum and advice from an IRS agent.The United States District Court for the Northern District of Indiana oversaw the criminal trial, where the petitioner was represented by attorney John Davis. During trial, Davis pursued motions under Brady v. Maryland, seeking exculpatory evidence, but the motions were denied. After conviction, Davis was removed from the Seventh Circuit Bar for misconduct in an unrelated case. The petitioner then moved for a new trial and, later, for relief under 28 U.S.C. § 2255, arguing ineffective assistance of counsel based on Davis’s disciplinary history and alleged trial errors. The district court denied both motions, finding Davis’s performance did not prejudice the petitioner’s defense and that his disciplinary issues in other cases did not establish ineffectiveness in the present case.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s denial of collateral relief de novo for legal issues and for clear error regarding factual findings. The court held that there is no per se rule that concurrent or subsequent attorney discipline renders counsel ineffective; instead, a petitioner must show specific deficient performance and resulting prejudice under Strickland v. Washington. The petitioner failed to demonstrate that counsel’s alleged errors affected the outcome of the trial. The Seventh Circuit affirmed the district court’s denial of the § 2255 motion. View "Blake v USA" on Justia Law

In this case, federal agents used a confidential informant to conduct two controlled purchases of crack cocaine from a person known as “Black.” The informant, Luis Villegas, met “Black” in a courthouse and later identified him as Antwan Eiland through a driver’s license photograph provided by an ATF agent. Subsequent drug deals were arranged and recorded, but the video evidence did not clearly capture Eiland’s face. Additional testimony came from the informant, the ATF agent, and a woman who drove Eiland to one transaction; all identified Eiland as the dealer. Eiland did not testify and argued at trial that he was not “Black.”A grand jury indicted Eiland on two counts of distributing a controlled substance in violation of 21 U.S.C. § 841(a)(1). After a jury trial in the United States District Court for the Northern District of Illinois, Eastern Division, Eiland was found guilty on both counts. Post-verdict, Eiland moved for acquittal based on insufficient evidence and for a new trial arguing juror bias, citing a juror’s remarks about his silence and mask-wearing. The district court denied both motions, finding the evidence sufficient and the juror’s comment inadmissible under Federal Rule of Evidence 606(b).The United States Court of Appeals for the Seventh Circuit reviewed the case. The appellate court held that the evidence was sufficient for a rational jury to find Eiland guilty beyond a reasonable doubt and declined to reassess witness credibility. It found no plain error in the prosecutor’s rebuttal argument, determining that the comments did not improperly reference Eiland’s silence. The court also ruled that the juror’s post-trial comment was inadmissible and did not justify a new trial or evidentiary hearing. The Seventh Circuit affirmed the district court’s judgment. View "USA v Eiland" on Justia Law

After being convicted in 2012 of drug and firearm offenses, a man was sentenced to 180 months in prison and six years of supervised release. He completed his prison term and began supervised release in 2022, but soon violated several conditions, including failing to notify his probation officer of changes in residence and employment, misrepresenting his place of residence, leaving his job without notice, and failing multiple drug tests. These violations led his probation officer to petition for revocation of his supervised release.The United States District Court for the Northern District of Indiana held a revocation hearing in February 2025, where the defendant admitted to the violations. The court determined that the applicable Sentencing Guidelines range was 18 to 24 months. The government sought 30 months’ imprisonment with additional supervised release, while the defendant requested 18 months without further supervision, arguing that supervision would be futile. The court ultimately revoked supervised release and imposed a 36-month prison sentence, citing the seriousness and number of violations, the defendant’s criminal and personal history, and his stated refusal to comply with supervision, while also noting the need for correctional treatment.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether the district court improperly lengthened the sentence for rehabilitative purposes, which is prohibited under Tapia v. United States, 564 U.S. 319 (2011). The appellate court found that, although the district court mentioned correctional treatment, it had considered multiple proper grounds for the sentence, including accountability and the defendant’s refusal to comply with supervision. The Seventh Circuit held that there was no Tapia error and affirmed the district court’s judgment. View "USA v Richards" on Justia Law

Jerome and Shaun Cohen operated a Ponzi scheme through their companies, EquityBuild, Inc. and EquityBuild Finance, LLC, from 2010 to 2018. They solicited funds from individual investors and institutional lenders, promising high returns secured by real estate, primarily in Chicago. In reality, the Cohens used new investors’ funds to pay earlier investors and overvalued properties to retain excess capital. By 2018, the scheme collapsed, leaving over $75 million in unpaid obligations. The Securities and Exchange Commission intervened, obtaining a temporary restraining order and having a receiver appointed to liquidate assets and distribute proceeds to victims.The United States District Court for the Northern District of Illinois oversaw the receivership and determined how proceeds from the sale of two properties—7749 South Yates and 5450 South Indiana—should be distributed. Both a group of individual investors and Shatar Capital Partners claimed priority to the proceeds, with Shatar arguing its mortgages were recorded before those of the individual investors. The district court found that Shatar was on inquiry notice of the individual investors’ preexisting interests and thus not entitled to priority, limiting all claimants’ recoveries to their contributed principal, minus any amounts previously received.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s distribution order. The appellate court affirmed, holding that under Illinois law, Shatar was on inquiry notice of the individual investors’ interests in both properties at the time it invested, given multiple red flags about the properties’ financing and EquityBuild’s business model. As a result, the individual investors were entitled to priority in the distribution of proceeds. The court also found Shatar’s challenge to the distribution plan moot, as there were insufficient funds to benefit Shatar after satisfying the investors’ claims. View "Securities and Exchange Commission v. Duff" on Justia Law

A Palestinian American tenant displayed a Palestinian flag in her apartment window to express solidarity with her heritage. In response to a complaint from another resident, the property manager, following a building-wide “neutrality” policy regarding the Israel-Palestine conflict, instructed her to remove the flag. The tenant informed management that her actions reflected pride in her heritage, but was told this was “unacceptable” and warned of eviction if she did not comply. After refusing to remove the flag, she received a notice terminating her tenancy, which cited a lease violation for hanging the flag outside the window. The tenant alleged this justification was pretextual, as management had indicated the flag would not be allowed anywhere, even inside the window. She also claimed other tenants displayed flags or decorations in their windows without consequence, but did not specify that any involved the Israel-Palestine conflict.She filed suit in the Circuit Court of Cook County, alleging violations of the Fair Housing Act (FHA) and state laws. The defendants removed the case to the United States District Court for the Northern District of Illinois, Eastern Division, and moved to dismiss most claims. The district court granted the motion, holding that her complaint did not plausibly allege national origin discrimination, as it did not show the policy was motivated by her national origin or that it had a disparate impact on Palestinians.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The Seventh Circuit held that the tenant failed to allege facts showing intentional national origin discrimination or disparate impact under the FHA. The court also found her interference claim under § 3617 of the FHA insufficient, and determined that the district court properly dismissed the state law claims without prejudice after dismissing the federal claims. View "Farhan v. 2715 NMA LLC" on Justia Law