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

The plaintiff, an Illinois prisoner, was involved in a physical altercation with several correctional officers at Stateville Correctional Center. Following the incident, he was transferred to Pontiac Correctional Center, where he received medical treatment. He was issued a disciplinary ticket for a major infraction, which led to an adjustment committee hearing at Pontiac. At the hearing, he was allowed to present his side but was not permitted to call witnesses or view video evidence. The committee recommended several disciplinary measures, including three months of solitary confinement in conditions the plaintiff later described as appalling, with unsanitary and unsafe features.The plaintiff filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, alleging that the disciplinary committee members and the warden violated his Fourteenth Amendment rights by imposing solitary confinement without sufficient procedural protections. The defendants moved for summary judgment, arguing that the plaintiff had not established a protected liberty interest, had not shown inadequate procedures, and that they were entitled to qualified immunity. The district court granted summary judgment for the defendants, finding that three months in segregation, even with harsh conditions, did not amount to a deprivation of a liberty interest protected by due process.On appeal, the United States Court of Appeals for the Seventh Circuit disagreed with the district court’s conclusion regarding the liberty interest, holding that the plaintiff’s evidence of three months in unusually harsh and unsanitary solitary confinement raised a genuine issue of material fact about deprivation of a protected liberty interest. However, the Seventh Circuit affirmed the judgment for the defendants, holding that they were entitled to qualified immunity because the law was not clearly established at the time of the plaintiff’s confinement. The court clarified that, going forward, short terms of solitary confinement combined with comparably harsh conditions will suffice to show a protected liberty interest requiring procedural protections. View "Jackson v. Anastacio" on Justia Law

Frankie Nelson worked at Provident Hospital, part of the Cook County Health and Hospital System, from 1997 until her voluntary retirement in 2010. She held union positions, first as Environmental Services Supervisor and later as Building Custodian I. Between 2002 and 2005, Nelson and a male colleague, Henry White, shared the duties of Acting Assistant Director of Environmental Services, each handling different aspects of the role in addition to their regular jobs. Nelson later alleged that, during this period, she was paid less than similarly situated male employees due to sex discrimination, focusing her claim on the pay disparity between herself and White, as well as two Directors, Nate Gordon and Jerry Brown.The United States District Court for the Northern District of Illinois, Eastern Division, granted summary judgment in favor of Cook County on both Nelson’s Title VII and Equal Pay Act claims. On appeal, Nelson challenged only the summary judgment on her Title VII claim, arguing that the district court failed to apply the correct legal standard and erred in determining that White was not a valid comparator. The district court had found that Nelson did not provide evidence of White’s compensation to support her claim of pay disparity and further concluded that White, Gordon, and Brown were not similarly situated to Nelson due to differences in job duties, qualifications, and supervisory roles.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that the district court applied the correct legal standards, including both the McDonnell Douglas framework and the totality of the evidence approach. The court concluded that Nelson failed to provide sufficient evidence of pay disparity with White and that none of the alleged comparators were similarly situated to her. Therefore, summary judgment for the defendant was properly granted. View "Nelson v County of Cook" on Justia Law

The defendant was charged with making threats against an Assistant United States Attorney (AUSA) in Fort Wayne, Indiana, on two separate occasions: May 20, 2022, and February 15, 2023. The first incident involved in-person threats at the federal courthouse and the Allen County prosecutor’s office, where the defendant made statements suggesting violent intent toward the AUSA. The second incident involved a threatening message sent to the AUSA’s personal Facebook account after she refused to return his calls. The defendant had a history of erratic behavior, including repeated attempts to contact the AUSA, hostile statements to law enforcement, and social media messages referencing the AUSA.The United States District Court for the Northern District of Indiana allowed the government to introduce evidence of the defendant’s other interactions with or about the AUSA under Federal Rule of Evidence 404(b), to show motive, intent, and context. However, the court excluded testimony from mental health professionals who had evaluated the defendant and from police officers who had experienced threats from him, finding that this evidence was not sufficiently probative of his intent or state of mind regarding the charged threats. The court also denied the defendant’s motion for acquittal, rejecting the argument that the Facebook message could not be a threat related to official duties because it was sent to a personal account and received after work hours. The jury convicted the defendant on both counts, though it acquitted him of threatening to murder the AUSA on the first occasion.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the conviction. The court held that the district court did not abuse its discretion in admitting the government’s evidence or excluding the defendant’s proffered testimony. It also found that sufficient evidence supported the jury’s verdict, including the finding that the Facebook message could be intended to interfere with the AUSA’s official duties. View "United States v. Taylor" on Justia Law

Two affiliated freight railroad companies challenged a series of security directives issued by the Transportation Security Administration (TSA) that required certain high-risk and strategically significant railroads to implement extensive cybersecurity measures. These directives, which were updated annually, imposed significant compliance costs and were motivated by ongoing and evolving threats from foreign adversaries such as Russia and China. The railroads argued that the directives should have undergone notice-and-comment rulemaking and that the ongoing nature of the cybersecurity threat did not constitute an “emergency” justifying bypassing those procedures.The petitioners sought direct review in the United States Court of Appeals for the Seventh Circuit, as permitted by statute, after the TSA issued new versions of the directives in May 2024, July 2024, and May 2025. The court consolidated the challenges because the directives were substantively identical. The railroads argued that TSA was required to conduct notice-and-comment rulemaking, perform a cost-benefit analysis, and that TSA lacked statutory authority to issue the directives. They also contended that the directives were arbitrary and capricious.The United States Court of Appeals for the Seventh Circuit denied the petitions. The court held that the ongoing cybersecurity threats described in the directives constituted an emergency within the meaning of 49 U.S.C. § 114(l)(2), allowing TSA to bypass notice-and-comment procedures. The court further held that TSA was not required to conduct a cost-benefit analysis for security directives, as the relevant statutory provision applied only to regulations, not directives. The court also found that TSA had sufficient statutory authority to issue the directives and that the directives were not arbitrary or capricious. The petitions for review were therefore denied. View "Grand Trunk Corp. v. Transportation Security Administration" on Justia Law

Three individuals who worked as precious metals futures traders at major financial institutions were prosecuted for engaging in a market manipulation scheme known as spoofing. This practice involved placing large orders on commodities exchanges with the intent to cancel them before execution, thereby creating a false impression of market supply or demand to benefit their genuine trades. The traders’ conduct was in violation of both exchange rules and their employers’ policies, and the government charged them with various offenses, including wire fraud, commodities fraud, attempted price manipulation, and violating the anti-spoofing provision of the Dodd-Frank Act.The United States District Court for the Northern District of Illinois, Eastern Division, presided over separate trials for the defendants. In the first trial, two defendants were convicted by a jury on all substantive counts except conspiracy, after the court denied their motions for acquittal and a new trial. The third defendant, tried separately, admitted to spoofing but argued he lacked the requisite criminal intent; he was convicted of wire fraud, and his post-trial motions were also denied. The district court made several evidentiary rulings, including admitting lay and investigator testimony, and excluded certain defense exhibits and instructions.The United States Court of Appeals for the Seventh Circuit reviewed the convictions and the district court’s rulings. The appellate court held that spoofing constitutes a scheme to defraud under the federal wire and commodities fraud statutes, and that the anti-spoofing statute is not unconstitutionally vague. The court found sufficient evidence supported all convictions, and that the district court did not abuse its discretion in its evidentiary or jury instruction decisions. The Seventh Circuit affirmed the convictions and the district court’s denial of post-trial motions for all three defendants. View "United States v. Smith" on Justia Law

Charles Christopher, while on supervised release for a prior conviction of attempting to entice a minor, engaged in online communications with someone he believed to be a 15-year-old girl. The individual was actually an undercover law enforcement agent. Christopher made explicit sexual advances, arranged to meet the supposed minor, and brought alcohol to the meeting location, where he was arrested. He was charged with attempted enticement of a minor under 18 U.S.C. § 2422(b) and with committing a felony involving a minor while under a sex offender registration requirement, in violation of 18 U.S.C. § 2260A.After pleading guilty to both counts in the United States District Court for the Central District of Illinois, Christopher was sentenced to consecutive terms totaling 264 months’ imprisonment. He later filed a motion under 28 U.S.C. § 2255, arguing, among other things, that his counsel was ineffective for not challenging the § 2260A charge on the basis that it did not involve a real minor, but rather a government agent. The district court denied the motion without an evidentiary hearing, finding that counsel’s performance was not constitutionally deficient and that Christopher was not entitled to relief.The United States Court of Appeals for the Seventh Circuit reviewed the case, focusing on whether counsel was ineffective for failing to argue that § 2260A requires the involvement of an actual minor. The court assumed, without deciding, that counsel’s performance was deficient, but held that Christopher was not prejudiced because § 2260A applies to predicate offenses under § 2422(b) even when the “minor” is an undercover agent. The court affirmed the district court’s denial of Christopher’s § 2255 petition. View "Christopher v USA" on Justia Law

Fifteen individuals who purchased new motorcycles from a major American manufacturer received a limited warranty with their purchases. The warranty provided for free repair or replacement of defective parts for up to 24 months but excluded coverage for defects or damage caused by non-approved or non-manufacturer parts. The plaintiffs, concerned that using non-manufacturer parts would void their warranties, opted to buy higher-priced parts from the manufacturer. They later alleged that the company’s warranty practices unlawfully conditioned warranty coverage on the exclusive use of its own parts, in violation of the Magnuson-Moss Warranty Act and various state antitrust laws.The United States Judicial Panel on Multidistrict Litigation consolidated the plaintiffs’ lawsuits and transferred them to the United States District Court for the Eastern District of Wisconsin. The district court dismissed the consolidated complaint for failure to state a claim. It found that the limited warranty did not condition benefits on exclusive use of manufacturer parts and that the risk of losing warranty coverage was insufficient to establish an anticompetitive tying arrangement or economic coercion under state antitrust law. The court also dismissed related state law claims premised on the same conduct.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The Seventh Circuit held that the warranty’s terms did not create an express or implied tie prohibited by the Magnuson-Moss Warranty Act, nor did the complaint plausibly allege violations of the Act’s disclosure or pre-sale availability requirements. The court further held that the plaintiffs failed to plausibly allege sufficient market power or anticompetitive effects to support their state antitrust claims, and that the warranty’s terms were available to consumers at the time of purchase, precluding a Kodak-style lock-in theory. The court affirmed dismissal of all claims. View "Heymer v. Harley-Davidson Motor Company Group, LLC" on Justia Law

A high school student sought to establish a pro-life student club at her public high school. The school promptly approved the club after she followed the required procedures, including securing a faculty sponsor and submitting a club questionnaire. The student actively promoted the club at the school’s activities fair, wearing pro-life apparel and displaying related signs. The dispute arose when the student submitted flyers containing political slogans and images for posting on school walls. Administrators instructed her to revise the flyers to comply with the school’s neutral content policy, which limited flyers to the club’s name and meeting details and excluded political content. Instead of revising the flyers, the student and her mother approached another administrator to seek approval, which led the principal to suspend the club’s status for the semester, citing concerns that the club was no longer student-led and that established procedures had been violated. The student was allowed to reapply, and the club was later reinstated.The student and her parents filed suit in the United States District Court for the Southern District of Indiana, alleging violations of the First Amendment and the Equal Access Act, claiming that the rejection of the flyers and the club’s suspension were motivated by hostility to her pro-life views. The district court granted summary judgment to the school district and officials, finding no constitutional or statutory violations.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s judgment. The Seventh Circuit held that the school’s restriction on political content in student club flyers was a reasonable, viewpoint-neutral policy related to legitimate pedagogical concerns under Hazelwood School District v. Kuhlmeier. The court also found that the temporary suspension of the club was based on neutral, conduct-related reasons and not on the student’s viewpoint. The court further held that there was no violation of the Equal Access Act and that the plaintiffs had not preserved a separate claim regarding the flyers under that statute. View "E.D. v Noblesville School District" on Justia Law

A woman and her son fled Honduras in 2016, fearing violence from the former leader of their land cooperative, who had been ousted after allegations of embezzlement and violence against dissenters. The woman had publicly opposed this leader and received threats from his associates, including intimidation outside her home. After arriving in the United States, she learned that other cooperative leaders had been murdered, which she attributed to the same individual. Although her immediate family remained in Honduras without incident, she believed her public opposition made her a unique target if she returned.The Department of Homeland Security initiated removal proceedings against her and her son. She conceded removability but applied for asylum, withholding of removal, and protection under the Convention Against Torture, citing threats and violence linked to the former cooperative leader. An immigration judge found her testimony credible but denied all relief, concluding she had not suffered past persecution and did not have a well-founded fear of future persecution. The judge found that Honduran authorities were able and willing to protect her and that she could reasonably relocate within Honduras. The Board of Immigration Appeals affirmed the denial, relying on the findings regarding government protection and internal relocation.The United States Court of Appeals for the Seventh Circuit reviewed the case, applying a deferential substantial evidence standard to the agency’s factual findings. The court held that substantial evidence supported the agency’s conclusions that Honduran authorities were both willing and able to protect the petitioner and that she could reasonably relocate within Honduras. Because either ground was sufficient to deny relief, the court denied the petition for review. View "Martinez-Martinez v. Bondi" on Justia Law

The petitioner, who entered the United States without authorization in 2006, lived with his wife and three children, all of whom are U.S. citizens. He was the primary financial provider for the family, earning significantly more than his wife and providing health insurance for the household. The family faced removal proceedings after the petitioner was arrested for driving on a suspended license and leaving the scene of an accident. The petitioner argued that his removal would cause his children exceptional and extremely unusual hardship, citing their emotional distress and the family’s financial dependence on him.An immigration judge found that the petitioner met all statutory requirements for cancellation of removal except for the “exceptional and extremely unusual hardship” standard. The judge determined that, while the family would experience financial and emotional difficulties, these did not rise above what is typically expected in removal cases. The petitioner appealed to the Board of Immigration Appeals, which affirmed the immigration judge’s decision, assuming for the sake of argument that all three children were qualifying relatives.The United States Court of Appeals for the Seventh Circuit reviewed the case, holding that it had jurisdiction to consider legal questions related to the application of the hardship standard. The court applied a deferential standard of review, as suggested by recent Supreme Court precedent, and concluded that the immigration judge’s findings were supported by substantial evidence and were not clearly erroneous. The court held that the petitioner had not demonstrated that his removal would result in hardship substantially beyond what is ordinarily expected in such cases. Accordingly, the Seventh Circuit denied the petition for review. View "Santos Mendoza v. Bondi" on Justia Law