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

Madeline Krasno sued the University of Wisconsin–Madison after her comments on the University's social media posts were hidden and her Instagram account was restricted. Krasno alleged that these actions violated her First Amendment rights, as she was advocating against animal abuse in the University's primate testing facilities. The University defended its actions by claiming that it was hiding "off-topic" comments.The United States District Court for the Western District of Wisconsin granted summary judgment in favor of the University, finding that the University's social media comment threads were nonpublic forums and that the University's moderation decisions were reasonable and viewpoint neutral. The district court also held that Krasno lacked standing to seek an injunction against the University's use of keyword filters.The United States Court of Appeals for the Seventh Circuit disagreed with the district court's findings. The appellate court determined that Krasno had standing to bring her as-applied challenge and concluded that the University's social media comment threads were limited public forums. The court held that the University's off-topic comment rule was neither reasonable nor viewpoint neutral, making it unconstitutional under the First Amendment. The court reversed the district court's summary judgment in favor of the University and remanded the case with instructions to enter judgment for Krasno. View "Krasno v. Mnookin" on Justia Law

In a suburban shopping center parking lot on July 1, 2016, Michael Cokes, Isaiah Stevenson, and Ronald Arrington waited in a car while Jimmie Malone robbed a restaurant manager. After the robbery, the men drove away with Malone, who later took over as the driver. When Illinois state troopers stopped the car, the men refused to exit, and Malone sped off, leading to a high-speed chase. During the chase, Chicago Police Officer Dean Ewing, driving an unmarked car, collided with the Pontiac, resulting in serious injuries to Cokes, Stevenson, and the officers in Ewing’s car, and the deaths of Malone and Arrington.The plaintiffs, including Arrington’s estate, sued the City of Chicago and Officer Ewing, alleging various torts related to the collision. After a nine-day trial, a jury found in favor of the defendants on all claims. The plaintiffs then moved for a new trial, challenging the district court’s decisions on affirmative defenses, jury instructions, and the admissibility of evidence. The district court denied these motions, leading to the current appeal.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 legal error or abuse of discretion in the district court’s handling of the affirmative defenses, jury instructions, and evidentiary rulings. Specifically, the court upheld the district court’s decisions to allow the defendants to plead a joint enterprise theory of contributory negligence, to admit testimony about Arrington’s conduct under Federal Rule of Evidence 601 rather than the Illinois Dead Man’s Act, and to exclude the COPA report under Rule 403. The appellate court concluded that any potential errors did not substantially affect the jury’s verdict. View "Arrington v. City of Chicago" on Justia Law

Mitchell Green was charged with trafficking a child and related offenses in Milwaukee County Circuit Court. During his trial, Green called his cousin, Jonathan Cousin, as a witness, who testified that he, not Green, had driven the minor to a hotel. The state did not initially object to Cousin's testimony but later argued that Green failed to provide pretrial notice as required for a "Denny witness," leading the judge to declare a mistrial. Green, out on bond, argued that a retrial would violate his constitutional right against double jeopardy.The trial court denied Green's motion to dismiss, and the Court of Appeals of Wisconsin held that the mistrial was erroneous. However, the Supreme Court of Wisconsin sided with the trial judge, finding that he exercised sound discretion in declaring a mistrial. Green then filed a collateral attack, and the district court denied relief, leading to this appeal.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that the trial judge's decision to declare a mistrial was based on a mistaken belief that pretrial notice for Denny evidence was required. The court noted that no such requirement existed in Wisconsin law. The trial judge failed to exercise sound discretion by not considering alternatives to a mistrial, such as a continuance. The Seventh Circuit held that there was no manifest necessity for the mistrial, and thus, a retrial would violate the Double Jeopardy Clause. The judgment of the district court was reversed, and the case was remanded with instructions to issue an unconditional writ. View "Green v. Milwaukee County Circuit Court" on Justia Law

Sheldon Morales and Eduardo Santana were surveilled by the DEA after Morales, recently released from prison for drug trafficking, resumed similar activities. Morales coordinated with two incarcerated brokers to arrange drug shipments, which were intercepted by law enforcement. Santana acted as a translator and partner in the operation, discussing plans to expand their drug distribution and defraud suppliers. Morales and Santana were indicted for conspiracy to possess and distribute methamphetamine, fentanyl, and cocaine. Morales faced additional charges for attempting to possess with intent to distribute methamphetamine and fentanyl.In the Northern District of Illinois, Morales requested new counsel multiple times, causing trial delays. His final request for new counsel was partially granted, but the court denied a subsequent motion to replace Joseph Lopez, citing potential further delays. Morales and Santana were convicted by a jury, with Morales found guilty of all charges and Santana convicted of conspiracy to possess with intent to distribute methamphetamine. Post-trial motions for a new trial and acquittal were denied. Santana's request for a minor role reduction at sentencing was also denied, and he was sentenced to 200 months, while Morales received 235 months.The United States Court of Appeals for the Seventh Circuit reviewed the case. Santana's appeal argued insufficient evidence for his conspiracy conviction and error in denying a minor role reduction. The court found ample evidence of Santana's active role in the conspiracy and upheld the district court's sentencing decision. Morales contended the district court erred by not giving a buyer-seller jury instruction and violated his right to counsel of choice. The court found sufficient evidence of a conspiracy with Santana, making the buyer-seller instruction irrelevant, and determined Morales had not properly requested new counsel. The Seventh Circuit affirmed the district court's judgments. View "United States v. Santana" on Justia Law

Chosen Consulting, LLC, doing business as Chosen Healthcare, and other related entities (collectively "Chosen") filed a lawsuit against the Town Council of Highland, Indiana, the Highland Municipal Plan Commission, and the Town of Highland, Indiana (collectively "the Town"). Chosen alleged that the Town discriminated against patients with addiction-related ailments by refusing to provide a letter stating that Chosen’s proposed use of its property complies with local zoning requirements. Chosen claimed this discrimination violated the Americans with Disabilities Act (ADA) and the Rehabilitation Act of 1973, seeking compensatory, injunctive, and declaratory relief.The United States District Court for the Northern District of Indiana granted summary judgment to the Town. The district court held that Chosen's claim for injunctive relief under the ADA and the Rehabilitation Act was not ripe for adjudication because Chosen had not obtained a final decision from the local zoning authorities. The court indicated that Chosen needed to pursue its request for zoning approval through the Board of Zoning Appeals (BZA) and, if necessary, appeal any final decision entered by the BZA to the state courts before seeking an injunction in federal court.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The Seventh Circuit held that Chosen's claim for injunctive relief was not ripe because Chosen had not satisfied the finality requirement set forth in Williamson County Regional Planning Commission v. Hamilton Bank of Johnson City. The court emphasized that Chosen needed to follow the local zoning procedures, including applying for a use variance or seeking a declaratory judgment in state court, to obtain a final decision from the Town. Until Chosen completed these steps, the dispute was not ripe for federal court review. View "Chosen Consulting, LLC v Town Council of Highland" on Justia Law

Jada Padua applied for Social Security benefits, claiming disability due to fibromyalgia, chronic fatigue, depression, and anxiety. An administrative law judge (ALJ) denied her benefits, concluding that she was not disabled as defined by the Social Security Act and that jobs existed in significant numbers in the national economy that she could perform. Padua challenged the agency’s denial in federal court, but the district court upheld the ALJ's decision, finding substantial evidence to support it.Padua filed her disability benefits application in November 2010, initially claiming a disability onset date of July 2008, later amended to November 2010. After an initial denial and a remand by a magistrate judge in February 2016, the ALJ held a second hearing in August 2016. The ALJ determined that Padua was not disabled under the Social Security Act, finding that her impairments did not meet a listing for presumptive disability and that she had the residual functional capacity (RFC) to perform light work with additional limitations. The ALJ discounted Padua’s complaints of extreme pain and fatigue, noting inconsistencies with her daily activities and the overall medical record. The ALJ also gave little weight to the opinions of her treating physicians, Drs. Carpenter and Pendolino, finding them inconsistent with the evidence.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s decision. The court held that the ALJ’s assessment of Padua’s fibromyalgia and the opinions of Drs. Carpenter and Pendolino were supported by substantial evidence. The court found that the ALJ reasonably considered the objective medical evidence, treatment history, and daily activities in determining Padua’s RFC. The court also concluded that the ALJ provided adequate reasons for discounting the treating physicians’ opinions and that the RFC determination was supported by substantial evidence. View "Padua v. Bisignano" on Justia Law

Richard Schneiter, a long-time employee of the Wisconsin Department of Corrections, was terminated after the Milwaukee Journal Sentinel reported that he had posted offensive memes on his private Facebook page. These posts were derogatory towards Muslims, blacks, liberals, and the LGBTQ community. The Department of Corrections initiated an investigation and concluded that Schneiter's posts created security concerns, diminished public trust, and questioned his ability to perform his duties without bias.The United States District Court for the Western District of Wisconsin granted summary judgment in favor of the defendants. The court applied the balancing test from Pickering v. Board of Education and determined that the Department's interests as a public employer outweighed Schneiter's free speech interests. The court also found that Schneiter had received adequate notice and an opportunity to be heard, thus dismissing his due process claim.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the lower court's decision. The appellate court held that the Department's interests in maintaining security, discipline, and public trust in its correctional facilities outweighed Schneiter's interest in posting the memes. The court emphasized the deference given to law enforcement and correctional agencies in assessing the disruptive nature of an employee's speech. Additionally, the court rejected Schneiter's due process claim, stating that public employers are not required to have specific social media policies before disciplining employees for social media activities that interfere with their job duties. Schneiter's argument of bias in the disciplinary process was also dismissed due to lack of evidence. View "Schneiter v. Carr" on Justia Law

Kenin Edwards was sentenced to 21 months’ imprisonment for tax fraud after a series of procedural complications. Edwards, who was represented by four different attorneys throughout the process, delayed his trial multiple times before pleading guilty. After his guilty plea, he fired his final attorney, decided to represent himself, recanted his admission of guilt, sought to vacate his plea, and filed numerous frivolous motions. The government, which had initially agreed to recommend a five-month split sentence, sought a 21-month sentence due to Edwards's conduct.The United States District Court for the Central District of Illinois handled the case. Edwards's initial attorneys withdrew due to a breakdown in strategy, and his subsequent attorney was disqualified due to a conflict of interest. Edwards then retained a fourth attorney, with whom he eventually reached a plea agreement. However, Edwards later discharged this attorney as well and chose to represent himself. The district court conducted a Faretta hearing to ensure Edwards's waiver of counsel was knowing and intelligent. Despite Edwards's numerous pro se filings and attempts to withdraw his guilty plea, the district court denied his motions and sentenced him to 21 months.The United States Court of Appeals for the Seventh Circuit reviewed the case. Edwards argued that his Sixth Amendment rights were violated when the district court disqualified his attorney and allegedly forced him to proceed pro se at sentencing. He also claimed the government breached the plea agreement by recommending a higher sentence. The Seventh Circuit dismissed Edwards's appeal, finding that he had waived his right to appeal in his plea agreement. The court held that Edwards's claims did not fall within the exceptions to the appeal waiver and that the government did not breach the plea agreement. View "United States v. Edwards" on Justia Law

Christian Arnold retained Binder & Binder in April 2018 to represent him in a claim for disability benefits under the Social Security Act. After the Commissioner of Social Security denied his claim, Arnold appealed to the district court, which remanded the case to the agency. An administrative law judge later determined Arnold was entitled to $160,797.10 in past-due benefits. Binder then moved for attorneys' fees under 42 U.S.C. § 406(b), seeking twenty-five percent of the retroactive benefits, amounting to $40,199.27. The district court awarded Binder $16,920, reducing the fee based on an effective hourly rate of $600.The United States District Court for the Central District of Illinois initially awarded Binder $16,920, despite the contingency fee agreement. Binder appealed, and the United States Court of Appeals for the Seventh Circuit held that the district court abused its discretion by not anchoring its reasonableness analysis on the contingency fee agreement. The case was remanded for further proceedings. On remand, the district court again awarded $16,920, maintaining that the contingency fee should be reduced to reflect a more reasonable effective hourly rate. Binder appealed once more.The United States Court of Appeals for the Seventh Circuit reviewed the case and found that the district court abused its discretion by inadequately explaining its decision to reduce Binder’s fees. The appellate court emphasized that the district court must begin with the contingency fee agreement and consider relevant factors, such as the plaintiff’s satisfaction and the attorney’s expertise. The appellate court reversed the district court’s decision and remanded with instructions to order the Social Security Administration to remit attorneys’ fees at Binder’s requested amount of $34,199.27. View "Arnold v. Bisignano" on Justia Law

Univar Solutions USA Inc. entered into a collective bargaining agreement (CBA) with Teamsters Local Union No. 283 in 2016, which required Univar to make pension contributions to a multiemployer pension fund. The CBA included an evergreen clause, automatically renewing the agreement annually unless either party provided notice of termination. In 2020, the parties extended the CBA by one year. Before the new expiration date, Univar sent a notice proposing modification or termination of the agreement and later entered a successor agreement allowing it to withdraw from the Fund and cease contributions. The Fund sued, claiming Univar's notice was too ambiguous to terminate the agreement.The United States District Court for the Northern District of Illinois ruled in favor of the Fund, finding that the 2020 extension did not prevent the CBA from automatically renewing under the evergreen clause. The court also found Univar's January 2021 letter insufficient to terminate the agreement, concluding that the CBA remained in effect through March 28, 2022. Consequently, the court granted summary judgment to the Fund, ordering Univar to pay the requested contributions and the Fund's legal fees.The United States Court of Appeals for the Seventh Circuit reviewed the case and disagreed with the district court's findings. The appellate court held that the 2020 extension did not nullify the evergreen clause and that Univar's January 2021 letter provided clear notice of its desire to terminate the CBA. The court concluded that Univar properly terminated the CBA before its expiration date, allowing it to cease contributions as per the successor agreement. The appellate court reversed the district court's summary judgment in favor of the Fund, vacated the award of attorneys' fees, and remanded the case. View "Central States Southeast and Southwest Areas Pensi v Univar Solutions USA Inc." on Justia Law