U.S. Court of Appeals for the Seventh Circuit - Justia Case Law Summaries

Spengler v Cooperative Educational Service Agency 7

2026-07-08T08:30:47-08:00

A special education administrator was employed by a Wisconsin state agency that facilitated educational services across multiple school districts. After a couple years, her supervisors, following directives from the Wisconsin Department of Public Instruction, pushed staff to adopt an “equity mindset,” which involved examining personal biases and working to disrupt systems influenced by white supremacy. The administrator disagreed with the perceived ideological requirements and refused to fully embrace the equity mindset, leading to concerns from the Department of Public Instruction, pressure on the agency, and her eventual demotion to a lower-paying job. The administrator filed suit in the United States District Court for the Eastern District of Wisconsin, alleging violations of Title VII and the Equal Protection Clause, claiming discrimination and retaliation based on her race. She also asserted a First Amendment claim, alleging retaliation based on her speech and beliefs. The district court granted summary judgment to the defendants on the Title VII and Equal Protection claims, finding no evidence that race was a motivating factor in her demotion, as the ideological requirements were applied to employees of all races. The court rejected her First Amendment claims regarding her speech and insufficiently pleaded her beliefs-based claim. The United States Court of Appeals for the Seventh Circuit reviewed the case. It affirmed the district court’s summary judgment on the Title VII and Equal Protection claims, holding that no reasonable jury could find her race was the cause of her demotion and that she did not engage in an objectively reasonable protected activity for retaliation purposes. However, the Seventh Circuit determined she adequately pleaded a First Amendment claim based on retaliation for her beliefs and remanded that claim for further proceedings. View "Spengler v Cooperative Educational Service Agency 7" on Justia Law

Boldt Company v Black & Veatch Construction, Inc.

2026-07-08T07:30:46-08:00

Black & Veatch Construction, Inc. contracted The Boldt Company as a subcontractor for the assembly of a windfarm in Illinois. The project quickly encountered delays due to late delivery of turbine parts, unsuitable site conditions, and issues with equipment, for which Boldt provided several written notices to Black & Veatch. Despite these notices, Black & Veatch issued multiple default warnings and ultimately terminated Boldt for cause, taking over the remaining work. Boldt sued, claiming wrongful termination and seeking payment for completed work, while Black & Veatch counterclaimed that Boldt breached by failing to perform on time. The United States District Court for the Northern District of Illinois granted summary judgment in favor of Black & Veatch, ruling that Boldt defaulted by failing to perform on schedule and that Black & Veatch properly terminated the subcontract. At trial, the jury was tasked only with determining damages and awarded Black & Veatch nominal damages of $1. Both parties filed post-trial motions, which the district court denied. Upon appeal, the United States Court of Appeals for the Seventh Circuit affirmed the jury’s nominal damages verdict, finding no reversible error in the district court’s evidentiary rulings or jury instructions. The appellate court also affirmed the district court’s grant of summary judgment as to Boldt’s claims for payment for completed work and for Black & Veatch’s alleged failure to provide adequate construction works. However, the Seventh Circuit reversed the grant of summary judgment on the wrongful termination claim, finding the subcontract ambiguous about whether Boldt was responsible for delays absent specific notice and that material factual disputes remained. The case was remanded for further proceedings on the wrongful termination claim. View "Boldt Company v Black & Veatch Construction, Inc." on Justia Law

USA v. Martinez

2026-07-07T08:30:47-08:00

A semi-truck driver was stopped in Illinois after state police received a tip from another law enforcement agency that the truck was carrying a large amount of narcotics. Two K9 troopers, not on routine patrol, waited on the side of the highway in the early morning hours to intercept the vehicle. The stated purpose for the stop was to conduct an administrative Level 3 inspection under Illinois’s commercial trucking regulatory scheme, involving checks of driver and vehicle documents. During the stop, the trooper noticed several signs he considered suspicious, including an odor of air freshener and irregularities with the driver’s route and cargo. A dog sniff of the truck led to the discovery of narcotics, and the driver was arrested. The United States District Court for the Central District of Illinois heard the defendant’s suppression motion, in which he argued the stop was a pretextual administrative inspection aimed solely at investigating criminal activity, thus violating the Fourth Amendment. The district court denied the motion, reasoning that the officer’s subjective intent was irrelevant so long as the stop was authorized under Illinois’s regulatory scheme. On appeal, the United States Court of Appeals for the Seventh Circuit held that, in the context of administrative inspections, an officer’s actual motivation for conducting the stop is relevant. The court found that the evidence showed the stop was undertaken solely to further a criminal investigation, not to enforce administrative regulations. It further held that the government had failed to demonstrate the stop was justified in its inception under the administrative inspection exception to the warrant requirement. The court concluded that the evidence obtained as a result of the stop must be suppressed and that the good faith exception to the exclusionary rule did not apply. The Seventh Circuit reversed the district court’s denial of the suppression motion and remanded for further proceedings. View "USA v. Martinez" on Justia Law

E.E.V. v. Blanche

2026-07-06T14:00:47-08:00

Two noncitizens, E.E.V. and M.C.C.-G., challenged orders that would remove them from the United States to their native countries, where they claimed they would face persecution or torture. E.E.V., a citizen of El Salvador, was previously removed under an expedited removal order, reentered the U.S., and was then subject to a reinstatement order in 2015. She expressed fear of returning, was found to have a reasonable fear by an asylum officer, and was referred to withholding-only proceedings before an immigration judge, which remained pending. M.C.C.-G., a Mexican citizen, was issued a final administrative removal order in 2025 after a criminal conviction. She also expressed fear of return, was initially found not to have a reasonable fear, but that determination was vacated, and she was placed in withholding-only proceedings, which were still pending when these petitions were filed. Previously, under Seventh Circuit precedent, noncitizens like the petitioners were required to wait until all administrative proceedings—including withholding-only proceedings—were completed before seeking judicial review. However, after the Supreme Court’s decision in Riley v. Bondi, the statutory thirty-day deadline to file a petition for review was held to run from the issuance of a final administrative removal order, regardless of the status of withholding-only proceedings. The United States Court of Appeals for the Seventh Circuit considered the government’s motions to dismiss the petitions as untimely, as they were filed more than thirty days after the final removal orders, and also raised new jurisdictional arguments. The Seventh Circuit rejected arguments that reinstatement orders are not subject to judicial review and that the petitions were unripe. The court held that the thirty-day deadline is subject to equitable tolling due to petitioners’ reliance on the prior binding precedent, making these petitions timely. The court denied the motions to dismiss and to transfer venue, holding the petitions in abeyance pending completion of agency proceedings. View "E.E.V. v. Blanche" on Justia Law

Liapis v Bisignano

2026-07-06T12:00:46-08:00

The plaintiff, who has a history of bipolar disorder, chronic pain due to orthopedic injuries, and an ear injury, applied for disability benefits in July 2020, alleging an inability to work since December 2019. Several consultative medical examiners assessed the plaintiff’s physical and mental impairments. While most concluded that the plaintiff was capable of routine, unskilled work, one psychologist, Dr. Pushkash, found that the plaintiff’s ability to concentrate and persist on tasks was markedly impaired due to chronic pain and psychological symptoms, though his cognitive abilities were otherwise unremarkable. After his claim was denied by Wisconsin’s disability agency, both initially and on reconsideration, the plaintiff requested a hearing before an Administrative Law Judge (ALJ). The ALJ found the plaintiff was not disabled, deeming Dr. Pushkash’s opinion “generally unpersuasive” for reasons including the one-time nature of the evaluation and the psychologist’s comments on physical pain. The Appeals Council denied review, making the ALJ’s decision final. The plaintiff then sought review in the United States District Court for the Western District of Wisconsin, which affirmed the ALJ’s decision, focusing on the ALJ’s treatment of Dr. Pushkash’s opinion. On appeal, the United States Court of Appeals for the Seventh Circuit held that while the ALJ’s analysis of Dr. Pushkash’s opinion contained several legal errors—such as failing to properly address required regulatory factors and inconsistently assessing medical opinions—these errors were harmless. The court concluded that, even if Dr. Pushkash’s opinion were fully credited, the plaintiff would not meet the regulatory criteria for disability, as he did not have the requisite number of “marked” or “extreme” limitations in areas of mental functioning. Therefore, the Seventh Circuit affirmed the judgment of the district court. View "Liapis v Bisignano" on Justia Law

USA v Eta

2026-07-06T06:00:46-08:00

Federal authorities were investigating an individual suspected of orchestrating transnational cyber fraud and money laundering schemes originating in Nigeria and targeting U.S. nationals. Information from two sources, including a co-conspirator, implicated him as a leader of fraudulent operations. Investigators gathered corroborating evidence, such as suspicious messages, unusually high activity on messaging apps, and bank records showing millions in transactions with no apparent legitimate source. When authorities learned he would return to the U.S. from Nigeria, they requested a manual search of his electronic devices upon arrival at Atlanta’s international airport. Customs officers searched his phones, found evidence of criminal activity, and subsequently seized the devices for forensic imaging. Two days later, law enforcement obtained search warrants for the phones and their extracted data. The United States District Court for the Northern District of Illinois, Eastern Division, reviewed the defendant’s motion to suppress evidence from the warrantless border search of his cell phones, which he argued violated his Fourth Amendment rights. After an evidentiary hearing, the district court found law enforcement witnesses credible and denied the motion, concluding that the manual search at the border was justified under the border search doctrine. The defendant then entered a conditional guilty plea to wire fraud, preserving his right to appeal the suppression ruling. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s denial de novo. The court reaffirmed that routine, manual searches of electronic devices at the border do not require a warrant or individualized suspicion under circuit precedent, specifically United States v. Mendez, and Supreme Court precedent. The court held that the search was routine, reasonable, and justified by the border search exception. Even if a Fourth Amendment violation occurred, the good-faith exception would preclude suppression. The judgment of the district court was affirmed. View "USA v Eta" on Justia Law

City of Hammond v Lake County Board of Elections

2026-07-02T12:00:46-08:00

In this case, the City of Hammond and three individual voters challenged Indiana’s use of the “Missouri Plan”—a system in which the governor appoints superior court judges from a list of nominees vetted by a nonpartisan commission, followed by periodic retention elections—in Lake County. They argued that, unlike most other Indiana counties where superior court judges are chosen in open elections, the Missouri Plan in Lake County gives minority voters, who make up over 40% of the voting-age population there, less opportunity than white voters elsewhere in the state to select judges of their choice. Plaintiffs relied on demographic disparities and asserted that the system violated Section 2 of the Voting Rights Act. The United States District Court for the Northern District of Indiana, Hammond Division, entered summary judgment for the defendants. The district court found that Seventh Circuit precedent, specifically Quinn v. Illinois, foreclosed the plaintiffs’ claim, holding that Section 2 does not require any particular office to be filled by election rather than appointment. The district judge also noted contrary circuit precedent in Bradley v. Work, which addressed similar facts, but concluded that Quinn was controlling. On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The court concluded that, under the Supreme Court’s intervening decision in Louisiana v. Callais, Section 2 liability attaches only where circumstances strongly suggest intentional discrimination. The appellate court found no evidence that Indiana’s use of the Missouri Plan in Lake County was motivated by racial discrimination, as the change was prompted by concerns over partisanship and inefficiency in the courts rather than race. The court thus held that Section 2 could not impose liability under these facts and affirmed the summary judgment for the defendants. View "City of Hammond v Lake County Board of Elections" on Justia Law

USA v Rose

2026-07-02T09:01:19-08:00

In 2009, Jonathan Rose was involuntarily committed to a mental institution in Indiana due to a psychiatric disorder, though the specific diagnosis and its severity were not detailed in the record. He was released in early 2010 and has not been recommitted since. In 2022, Rose successfully purchased multiple firearms, though he was denied others after background checks revealed his prior commitment. In 2023, he was indicted under federal law for possessing firearms as a person previously committed to a mental institution and for making false statements to firearms dealers by denying his commitment history. The United States District Court for the Northern District of Indiana reviewed Rose’s case and dismissed the counts related to possession of firearms by a previously committed person under 18 U.S.C. §922(g)(4). The district court reasoned that this statute, as applied to someone no longer suffering from mental illness, was inconsistent with the Second Amendment, particularly in light of recent Supreme Court decisions emphasizing individualized assessments of current danger rather than permanent disabilities based on past conditions. The United States Court of Appeals for the Seventh Circuit considered the government’s appeal. The court determined that the district court should not have dismissed the indictment without an evidentiary hearing to assess Rose’s current mental health and dangerousness. The Seventh Circuit held that, after recent Supreme Court decisions, the constitutionality of §922(g)(4) as applied depends on whether the defendant currently poses a credible threat to the safety of others. Because the record lacked evidence concerning Rose’s present mental condition, the appellate court vacated the district court’s order and remanded for further proceedings to develop the necessary facts. View "USA v Rose" on Justia Law

USA v. Adefusi

2026-07-02T06:30:59-08:00

Babajide Adefusi entered a plea agreement with the United States Attorney’s Office for the Southern District of Texas in 2018, pleading guilty to aiding and abetting passport fraud. The scheme involved using counterfeit passports with Adefusi’s photo and false identity information to open bank accounts, into which funds from internet scam victims were wired. The total loss from the passport fraud scheme was approximately $2.2 million. The plea agreement included a promise by the “United States” not to pursue additional charges arising out of the scheme alleged in the charging document. The agreement, however, specified that it bound only the U.S. Attorney’s Office for the Southern District of Texas and not any other U.S. Attorney. After completing his sentence, Adefusi was indicted by a federal grand jury in the Central District of Illinois in 2023 for conspiring to commit wire fraud related to a scheme defrauding E-MedRx, a pharmacy billing company. Adefusi moved to dismiss the indictment, arguing that the earlier plea agreement barred the Central District of Illinois from prosecuting him due to factual overlap between the two schemes. The United States District Court for the Central District of Illinois denied the motion, finding the plea agreement unambiguously bound only the Southern District of Texas office. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s denial of Adefusi’s motion to dismiss. Applying principles of contract interpretation to the plea agreement, the Seventh Circuit held that the agreement unambiguously bound only the U.S. Attorney’s Office for the Southern District of Texas and not other U.S. Attorney’s Offices. Thus, the Central District of Illinois was not barred from prosecuting Adefusi for wire fraud conspiracy. The Seventh Circuit affirmed the district court’s decision. View "USA v. Adefusi" on Justia Law

Andric v. Blanche

2026-07-01T11:30:47-08:00

A Serbian professional soccer player entered the United States on a visitor visa and sought asylum, claiming past persecution due to his membership in a group he defined as “Serbian soccer players who are victims of violence from soccer hooligans,” as well as persecution based on an imputed political opinion. He described being assaulted by soccer hooligans after a game, suffering moderate injuries, and receiving subsequent threats. He did not report these incidents to police, fearing connections between the hooligans and law enforcement, and argued that relocation within Serbia would not protect him because of the reach of these groups. An immigration judge found the applicant credible but ruled that the harm he suffered did not amount to past persecution, as it was based on a single incident without lasting impairments and was motivated by personal dissatisfaction with his performance rather than a protected ground. The judge held that being a soccer player was not an immutable characteristic and that the proposed social group lacked particularity and specificity. Furthermore, the judge found no evidence of government unwillingness or inability to protect him, nor of an objectively reasonable fear of future persecution. The judge denied asylum as well as withholding of removal and protection under the Convention Against Torture, which the applicant did not appeal. The Board of Immigration Appeals affirmed the judge’s decision, finding that the revised social group definition was waived and agreeing that the applicant failed to establish a nexus to a protected ground. The United States Court of Appeals for the Seventh Circuit reviewed the agency’s conclusions for substantial evidence and held that the applicant’s harm did not occur on account of a protected ground, and that neither of his proposed social groups was cognizable under the law. The court denied the petition for review. View "Andric v. Blanche" on Justia Law

USA v. Espanola

2026-07-01T07:30:46-08:00

A contractor for the City of Moline, Illinois, discovered in early 2021 that city payments totaling over $420,000 had been diverted to a fraudulent bank account at Washington Federal Bank. That account belonged to Luisito Espanola, who had opened it under the name GS International, LLC, which he controlled. Investigators found that Espanola quickly moved the stolen funds by depositing checks to a Citibank account, purchasing cryptocurrency, and sending money to other entities. Digital evidence, including WhatsApp messages between Espanola and a co-conspirator, detailed their planning and execution of the fraud. The United States District Court for the Central District of Illinois tried Espanola on two counts of wire fraud and two counts of money laundering. During discovery, Espanola produced a WhatsApp chat log as a defense exhibit; the government then moved to admit the chat log in its case-in-chief. The district court admitted the messages, relying on their distinctive characteristics and Espanola’s production of them under Rule 16(b)(1)(A). The jury convicted Espanola on all counts, and the district court sentenced him to 32 months in prison. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether the district court’s reliance on Espanola’s production of the messages as a basis for authentication under Federal Rule of Evidence 901(b)(4) violated his right to testify. The court held that it did not, as the admission of government evidence does not infringe upon the defendant’s right to testify, which is implicated only by the exclusion of defense evidence. The Seventh Circuit further held that, regardless of circumstances of discovery, the WhatsApp messages were authenticated by their content and corroborating records. The court affirmed the district court’s judgment. View "USA v. Espanola" on Justia Law

USA v. Banks

2026-06-30T06:31:05-08:00

A man was stopped by police late at night after an officer observed him allegedly fail to signal 100 feet before making a left turn, as required by Illinois law. After he parked in a strip mall lot, officers initiated a traffic stop and asked for his license and proof of insurance. The driver’s insurance card was expired, prompting him to exit the car to call someone for updated proof. While the stop was ongoing, another officer arrived with a drug-sniffing dog, which alerted to narcotics outside the vehicle. Police then searched the car and found a handgun hidden in the center console, but no drugs. The driver was arrested and charged with being a felon in possession of a firearm. The United States District Court for the Central District of Illinois denied the defendant’s motion to suppress the handgun, finding the officer’s testimony credible enough to establish reasonable suspicion for the traffic stop and that the stop was not impermissibly prolonged. It also found the dog’s alert provided probable cause to search the vehicle. At trial, the court denied the defendant’s motion for a directed verdict, ruling there was sufficient evidence for the jury to convict him. The defendant’s post-trial motion for a new trial was also denied. The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s rulings. The appellate court held that the district court did not clearly err in crediting the officer’s testimony about the traffic violation, that the duration of the stop was not unreasonably extended, and that the dog’s alert provided probable cause for the search. The court also found that there was sufficient evidence to support the conviction for knowing possession of a firearm by a felon. The judgment was affirmed. View "USA v. Banks" on Justia Law

Creason v Elanco US Inc.

2026-06-29T10:00:53-08:00

Clayton Creason worked as an engineer for Elanco US from November 2017 to November 2021. During his employment, Elanco offered a standard paid vacation benefit and an optional “vacation buy” program that allowed employees to purchase an extra week of paid leave by accepting a reduction in weekly salary. Creason participated in this program, reducing his pay by approximately $84 per week for the additional vacation week. After resigning, he filed suit under the Indiana Wage Payment Statute, claiming Elanco owed him the amount of the salary reduction, arguing the program required a written assignment of wages with notice of the right to rescind, as specified by Indiana law. The suit was initially filed in Indiana state court, with Creason seeking class certification for similarly situated employees. Elanco removed the case to the United States District Court for the Southern District of Indiana under the Class Action Fairness Act. The district court denied Creason’s belated motion to remand, finding his delay in seeking remand unreasonable after substantial progress in federal court. The court then dismissed some claims on the pleadings and granted summary judgment to Elanco on the remaining issues, concluding the vacation buy program did not constitute an assignment of wages and that Elanco’s policies concerning unused pandemic-related vacation hours did not violate Indiana law. The United States Court of Appeals for the Seventh Circuit reviewed the case. It held that the district court acted within its discretion in denying the remand request due to Creason’s unreasonable delay. On the merits, the Seventh Circuit affirmed that the vacation buy program was not an assignment of wages under Indiana law and that Elanco was not obligated to pay out unused COVID-related vacation hours. The district court’s decision was affirmed. View "Creason v Elanco US Inc." on Justia Law

Pavlovich v. Gaiman

2026-06-29T08:30:54-08:00

The plaintiff, a New Zealand citizen who currently resides in Scotland, alleged that the defendant, a United Kingdom citizen and lawful permanent resident of Wisconsin, repeatedly sexually assaulted her while she was employed as a live-in nanny for the defendant’s family in New Zealand. The plaintiff claimed she was economically distressed and intermittently unhoused at the time, and accepted the job for secure employment and housing. She brought federal claims under the Trafficking Victims Protection Act and Wisconsin common law claims, seeking damages for the alleged assaults and related harms. After the plaintiff filed suit in the United States District Court for the Western District of Wisconsin, the defendant moved to dismiss the case on two grounds: forum non conveniens, arguing that New Zealand was a more appropriate forum, and failure to state a federal claim, contending the civil-remedy provision of the Act does not apply extraterritorially. The district court granted the motion to dismiss under forum non conveniens, finding that New Zealand was an available, adequate, and more convenient forum with a stronger connection to the dispute. The district court did not address the extraterritoriality issue. The plaintiff appealed the dismissal to the United States Court of Appeals for the Seventh Circuit. The United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal under forum non conveniens. The appellate court concluded there was no abuse of discretion in the district court’s findings that New Zealand was both an available and adequate forum, and it properly balanced public and private interest factors. The Seventh Circuit held that New Zealand’s connection to the dispute was stronger than that of the United States and that international comity concerns supported dismissal. The judgment was affirmed and the action dismissed without prejudice. View "Pavlovich v. Gaiman" on Justia Law

USA v. Turner

2026-06-29T08:00:45-08:00

Malaia Turner was indicted for conspiring to distribute 500 grams or more of methamphetamine. Evidence at trial showed that Turner and Marcus Posey operated a methamphetamine transportation and distribution scheme between California and Illinois, beginning in 2019. Turner was involved in purchasing, packaging, and shipping methamphetamine, recruiting couriers, and handling transactions. She and Marcus expanded their operations to include other individuals as couriers and negotiated deals for others. Turner also enforced payments from customers and handled large transactions herself. The evidence indicated that Turner and Marcus eventually split proceeds and consulted on pricing. The United States District Court for the Central District of Illinois conducted Turner’s jury trial, which resulted in her conviction. Prior to sentencing, the probation officer prepared a Presentence Investigation Report (PSR) recommending a two-level leader-organizer enhancement under U.S.S.G. § 3B1.1(c) and attributing substantial drug quantities to Turner. Turner objected to the drug amounts and the role enhancement in a sentencing memorandum. At the sentencing hearing, the district court overruled Turner’s objections to the PSR’s drug quantity calculations and the leader-organizer enhancement, adopted the factual findings, and sentenced Turner to 324 months’ imprisonment. Turner appealed, arguing procedural errors in the sentencing process and improper application of the enhancement. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s factual findings for clear error and legal conclusions de novo. The Seventh Circuit held that the district court properly applied the two-level leader-organizer enhancement based on Turner’s supervisory role and involvement in the conspiracy. The court also found no error in the adoption of drug quantities, concluding that any procedural error was harmless because the sentence would not have been affected. The Seventh Circuit affirmed the district court’s judgment. View "USA v. Turner" on Justia Law

USA v. Johnson

2026-06-26T07:30:46-08:00

Brian Johnson orchestrated a fraudulent scheme from 2010 onward, in which he posed as both the CEO and an employee of a fictitious adult film, photography, and art studio. He posted advertisements online, soliciting women to audition for purported modeling or adult film opportunities, promising substantial compensation and future work. Johnson required in-person meetings, during which he took nude photographs and videos, gave the women alcohol, and engaged in sexual acts with them. He falsely claimed their images needed to be reshot for a distributor and threatened to post the images online if they refused further participation. One victim, who was sixteen at the time, eventually revealed her true age and provided proof, but Johnson continued to possess and distribute her images. The United States District Court for the Northern District of Illinois, Eastern Division, conducted the trial. A jury convicted Johnson on seven counts of sex trafficking and three counts of child pornography. Johnson moved for acquittal post-trial; the district court denied his request regarding the sex trafficking convictions but granted acquittal on the child pornography convictions. Johnson was sentenced to 420 months in prison. Both Johnson and the government appealed: Johnson challenged his convictions and sentence, while the government cross-appealed the acquittal on the child pornography counts. The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s denial of Johnson’s motion for acquittal on the sex trafficking convictions, holding that fraudulent promises of future compensation and work opportunities can constitute “things of value” under 18 U.S.C. § 1591(e)(3) when the victims subjectively believe in their value. The court found the sentence substantively reasonable. However, it reversed the district court’s acquittal on the child pornography convictions, concluding that sufficient evidence supported the jury’s findings regarding Johnson’s knowledge of the victim’s age. The court vacated the sentence and remanded for reinstatement of the child pornography convictions and resentencing. View "USA v. Johnson" on Justia Law

USA v Morgan

2026-06-25T12:30:56-08:00

James Morgan was investigated by law enforcement for several years due to his online activity, which included posting instructions for making dangerous homemade weapons and advocating for violence against government officials and minority groups. His posts, while often protected speech, were accompanied by demonstrations of weapons such as pipe bombs, acid sprayers, and flamethrowers. In late 2023, federal agents sought and obtained a search warrant from a magistrate judge in the Eastern District of Wisconsin to search Morgan’s property, including a trailer parked in the Western District, based on an affidavit detailing his conduct and apparent intent to commit acts dangerous to human life. After executing the warrant, agents found pipe bombs in Morgan’s trailer. He was indicted by a grand jury in the Western District of Wisconsin for possession of unregistered destructive devices under 26 U.S.C. § 5861(d). Morgan moved in the United States District Court for the Western District of Wisconsin to suppress the evidence, arguing the magistrate lacked authority to issue an extra-district warrant under Federal Rule of Criminal Procedure 41(b), and to dismiss the indictment, claiming the statute exceeded Congress’s taxing power. The district court denied both motions, finding the affidavit provided probable cause that Morgan’s activities constituted domestic terrorism under Rule 41(b)(3) and that established precedent foreclosed his constitutional challenge. Morgan entered a conditional guilty plea, reserving his right to appeal. The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s rulings. The court held the affidavit supplied probable cause that Morgan’s activities met the statutory definition of domestic terrorism, authorizing the magistrate’s extra-district warrant under Rule 41(b)(3). It also concluded that Morgan’s constitutional challenge to 26 U.S.C. § 5861(d) was foreclosed by Supreme Court and Seventh Circuit precedent, upholding the statute as a valid exercise of Congress’s taxing power. View "USA v Morgan" on Justia Law

Certain Underwriters at Lloyd's v CSX Transportation, Inc.

2026-06-25T09:31:27-08:00

National Railway Equipment sought to deliver four rebuilt locomotives from Illinois to North Carolina for export. The company’s logistics manager used online systems to contract with two rail carriers: Evansville Western Railway for the Illinois-to-Indiana leg, and CSX Transportation for the Indiana-to-North Carolina leg. For each shipment, the manager selected a standard transportation commodity code and accepted the carriers’ publicly available rates, which included liability limits per locomotive. The manager could have selected higher rates for greater carrier liability but opted not to, as National Railway Equipment carried its own insurance for losses. After the locomotives were destroyed in a derailment during Hurricane Florence while in CSX’s possession, the company’s insurer, Certain Underwriters at Lloyd’s, paid the claim and pursued reimbursement from the carriers under the Carmack Amendment. Evansville Western Railway moved for summary judgment, arguing liability was contractually capped, while CSX went to trial on similar terms. The United States District Court for the Southern District of Illinois found for Evansville Western on summary judgment, concluding the liability cap applied, and the jury found for CSX, also applying the contractual cap. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether the carriers’ liability was properly limited under the Carmack Amendment. The court held that where a shipper knowingly selects a carrier’s rate that includes a liability cap, and the contractual documents (here, the bills of lading with the standard code) reflect this agreement, the limitation is enforceable—even if the cap is not stated verbatim in the bill of lading. The Seventh Circuit affirmed the district court’s summary judgment for Evansville Western and denial of judgment as a matter of law against CSX, upholding the application of the contractual liability limits. View "Certain Underwriters at Lloyd's v CSX Transportation, Inc." on Justia Law

Brown v Chicago Transit Authority

2026-06-24T14:00:46-08:00

An employee of the Chicago Transit Authority (CTA), represented by a union, was terminated after repeatedly failing to follow the proper procedure for reporting Family and Medical Leave Act (FMLA) absences. The CTA required employees to notify a third-party administrator, ReedGroup, as well as their work location, when taking FMLA leave. The employee, who is transgender and had previously advocated for workplace accommodations and insurance coverage related to his transition, applied for intermittent FMLA leave for back pain, but his application was denied after he failed to complete the required process for obtaining a third medical opinion. Despite the denial, he continued to report absences as FMLA leave only to his work location, not ReedGroup, resulting in his termination for falsification of leave. After his discharge, the employee sought the union’s assistance in contesting his termination and pursued the available grievance and arbitration procedures. He also filed charges with the Equal Employment Opportunity Commission, then sued both the CTA and the union in the United States District Court for the Northern District of Illinois, Eastern Division. He asserted claims of transgender discrimination and retaliation under Title VII, as well as FMLA interference and retaliation against the CTA, and a municipal liability claim. The district court granted summary judgment in favor of the CTA and the union, concluding that the employee had failed to produce evidence that would allow a reasonable jury to find in his favor. On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The court held that the employee failed to provide sufficient evidence that similarly situated non-transgender employees were treated more favorably, or that the CTA or the union’s actions were pretextual or motivated by discriminatory or retaliatory animus. The court also found no error in the exclusion of evidence and upheld the dismissal of the FMLA claims. The summary judgment for both defendants was affirmed. View "Brown v Chicago Transit Authority" on Justia Law

Jezior v City of Chicago

2026-06-24T13:30:46-08:00

Michael Jezior worked as an engineer-paramedic for the Chicago Fire Department until a stroke in 2013 left him with limited mobility. Unable to perform his original duties, Jezior was reassigned to a procurement position at O’Hare Airport. In 2021, Jezior became eligible for promotion to lieutenant. However, the Department informed him that all available lieutenant positions at the airport required active firefighting, which he could not perform due to his disability. Jezior was offered the option to seek an accommodation for a different lieutenant position or to remain in his current role without promotion. He declined to pursue the accommodation process, fearing it could result in medical disqualification and early retirement, and chose to stay in his current position. Jezior then sued the City of Chicago under the Americans with Disabilities Act (ADA), claiming denial of a reasonable accommodation and disability discrimination. The United States District Court for the Northern District of Illinois, Eastern Division, granted summary judgment for the City. The court found that Jezior was not a “qualified individual” for the lieutenant position at the airport because he could not perform the essential firefighting functions. It further held that the ADA does not require an employer to create a new position or provide the employee’s preferred accommodation. On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The Seventh Circuit held that Jezior was not qualified for the requested promotion because he could not meet the essential job requirements. The court also determined that the City was not obligated to provide Jezior his preferred accommodation or to promote him in place. Additionally, the court found no evidence of pretext or disparate treatment compared to similarly situated employees. The judgment for the City was affirmed. View "Jezior v City of Chicago" on Justia Law

Hossfeld v Allstate Insurance Co.

2026-06-24T13:00:47-08:00

Robert Hossfeld received twelve telemarketing calls advertising Allstate Insurance products, despite having previously requested that Allstate not contact him. The calls were made by Atlantic Telemarketing Center, which had been subcontracted by Transfer Kings, a company retained by Allstate’s insurance agents, Fleming and Gilmond. Allstate’s internal do-not-call list included Hossfeld’s number months before the calls occurred. Neither Allstate nor its agents were aware that Atlantic was involved in marketing Allstate insurance until after Hossfeld initiated his lawsuit. Hossfeld sued Allstate in the United States District Court for the Northern District of Illinois, alleging violations of the Telephone Consumer Protection Act (TCPA) because Allstate failed to maintain an adequate do-not-call policy and permitted calls to be made to him after his request. He also sought class certification for other similarly affected individuals. The district court denied class certification, finding Hossfeld had not demonstrated that the proposed class was sufficiently numerous. On cross-motions for summary judgment, the district court ruled in Hossfeld’s favor, holding Allstate vicariously liable for Atlantic’s calls under agency law and awarding treble damages for willful violations. The United States Court of Appeals for the Seventh Circuit reviewed the case. The appellate court affirmed the denial of class certification, agreeing that Hossfeld failed to prove numerosity and impracticability of joinder. However, it reversed the district court’s summary judgment on liability, concluding that Hossfeld failed to show Allstate was liable for Atlantic’s calls under any theory of agency law, including subagency, apparent authority, or ratification. The Seventh Circuit clarified that the willfulness standard under the TCPA requires reckless or knowing conduct, not merely volitional acts. The court affirmed in part and reversed in part, directing judgment for Allstate. View "Hossfeld v Allstate Insurance Co." on Justia Law

Jeffboat, Inc. v Director, OWCP

2026-06-23T12:00:45-08:00

The case concerns a worker who was employed as a ship painter at a shipyard in Indiana for twelve years. After being laid off in 2017, he filed a claim for workers’ compensation under the Longshore and Harbor Workers’ Compensation Act, alleging that he experienced breathing difficulties due to prolonged exposure to various lung irritants during his employment, including fumes from paints, paint thinners, sandblasting materials, and other chemicals. He had a history of health issues, including asthma, COPD, and emphysema, and was a longtime smoker who switched to vaping in 2015. Medical evidence was presented by both the claimant and the employer, with dueling expert reports on whether workplace exposures contributed to his lung conditions. The Department of Labor administrative law judge (ALJ) conducted a formal hearing. The ALJ found the claimant had suffered harm and that workplace conditions could have caused it, entitling him to a statutory presumption of causation. The employer rebutted this presumption, but after considering the evidence, the ALJ credited the claimant’s expert and concluded that workplace exposures contributed to his lung impairment. The ALJ awarded permanent partial disability benefits and medical expenses. The Office of the District Director later granted a reduced attorney’s fee award. The Benefits Review Board affirmed both the ALJ’s decision and the fee award, finding the factual and legal conclusions rational and supported by substantial evidence. The United States Court of Appeals for the Seventh Circuit reviewed the ALJ and District Director’s decisions directly. Applying the substantial evidence standard, the court held that the ALJ’s findings and conclusions regarding disability, causation, and the extent of impairment were supported by the record and consistent with applicable law. The court also found the employer’s challenge to the fee award waived for lack of record support and legal citation. The petition for review was denied, affirming the Board’s decision. View "Jeffboat, Inc. v Director, OWCP" on Justia Law

American Academy of Pediatrics v Uthmeier

2026-06-22T13:00:46-08:00

The case centers on a lawsuit filed by the Attorney General of Florida against the American Academy of Pediatrics (AAP) and other organizations, alleging that their advocacy for gender-affirming care violated several Florida statutes, including the state's Deceptive and Unfair Trade Practices Act, RICO Act, and antitrust law. The Florida enforcement action targeted AAP's policy statements and legal filings that supported access to gender-affirming care for transgender youth, with the Attorney General seeking significant monetary penalties and organizational restrictions. Although the lawsuit was publicized, there was a three-month delay before the organizations were served. Following the initiation of the Florida state court action, AAP, an Illinois nonprofit, filed a separate suit in the United States District Court for the Northern District of Illinois. AAP claimed that the Florida enforcement proceeding was brought in bad faith to retaliate against its First Amendment–protected advocacy. The district court granted a preliminary injunction to prevent the Florida Attorney General from pursuing the enforcement action against AAP and denied the Attorney General’s motion to dismiss, finding that personal jurisdiction and venue in Illinois were supported, and that the facts suggested the Florida action was brought in bad faith. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed only whether to stay the district court’s injunction during the expedited appeal. The Seventh Circuit denied the motion for a stay, holding that the Attorney General did not make a strong showing of likely success on the merits or irreparable harm. The court found that the bad-faith exception to Younger abstention applied based on the district court’s factual findings, and that jurisdiction and venue in Illinois were appropriate given the circumstances. The injunction against the Florida enforcement action remains in effect pending appeal. View "American Academy of Pediatrics v Uthmeier" on Justia Law

USA v Broadfield

2026-06-22T12:01:04-08:00

After serving a prison sentence for conspiracy to manufacture methamphetamine, the defendant began a term of supervised release, which included a condition that he refrain from any use of alcohol. The defendant, who is a practicing Messianic Jew, asked the court to modify this condition to allow him to drink a glass of wine during religious ceremonies on his Sabbath, arguing that the complete alcohol ban violated his rights under the Religious Freedom Restoration Act (RFRA) and imposed a greater deprivation of liberty than necessary under 18 U.S.C. § 3553(a). The defendant had a lengthy history of alcohol abuse intertwined with criminal behavior, including prior convictions related to intoxication and repeated violations of probation and supervised release conditions. Medical reports and court findings noted his inability to control alcohol consumption and recommended complete abstinence. The United States District Court for the Central District of Illinois denied the defendant’s motion to modify the supervised release condition. The court found that the government had a compelling interest in prohibiting the defendant from consuming alcohol entirely, given his history of rapid escalation from initial drinking to dangerous behavior. The court also found that alternatives—such as monitoring with breathalyzers—were not feasible for ensuring compliance and public safety, and therefore, a total ban was the least restrictive means to further the government’s interests. Reviewing the case, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The Seventh Circuit held that, under RFRA, the complete alcohol ban was the least restrictive means to further the government’s compelling interests in public safety, rehabilitation, and preventing recidivism, given the defendant’s history. The court also held that the condition did not involve a greater deprivation of liberty than necessary under § 3553(a). The district court’s denial of the motion to modify supervised release was affirmed. View "USA v Broadfield" on Justia Law

Stevens v. ICE

2026-06-22T09:31:02-08:00

A university professor submitted requests under the Freedom of Information Act (FOIA) to a federal agency, seeking the files of three named immigration detainees. The agency was slow to respond, leading the professor to file a lawsuit in the United States District Court for the Northern District of Illinois. Over the course of the litigation, the agency provided some documents but was criticized for delays and for the quality of its responses, particularly concerning certain categories of records like grievances, commissary accounts, and work program participation. The agency’s explanations for its searches and redactions—detailed in a Vaughn index—were found lacking by the district judge, who was especially critical of redactions that seemed baseless or were applied to information already in the public domain. The judge questioned the good faith of the agency and its FOIA director, ordered all contested pages released without redaction, and required additional searches and explanations. After the agency appealed, the district judge entered an injunction intended to require release of the records, but the injunction was vague and did not specify precisely what documents had to be produced or by whom they were identified. This lack of clarity made enforcement problematic. The United States Court of Appeals for the Seventh Circuit reviewed the case. It held that while sanctions against the agency for its mishandling of the FOIA requests may be justified, the district court abused its discretion by ordering wholesale release of all documents, including information potentially affecting third parties and law enforcement interests, without adequate explanation or consideration of less drastic alternatives. The appellate court vacated the injunction for lack of sufficient detail and remanded the case with instructions to reconsider the sanction and limit disclosures to information about the agency’s own operations or privileges that the agency itself could waive. View "Stevens v. ICE" on Justia Law

USA v. Jackson

2026-06-22T07:30:45-08:00

Cornelius M. Jackson was investigated after Milwaukee police responded to reports involving a woman, AV-4, who initially denied any wrongdoing but later disclosed that Jackson had choked her, threatened her, and forced her into commercial sex work. AV-4 described Jackson’s control over her activities and earnings, and her account was corroborated by pole camera footage and a bystander’s report. Based on AV-4’s statements, Waukesha police sought and received a search warrant for Jackson’s residence, where they recovered multiple electronic devices and evidence linking him to sex trafficking. Jackson was indicted for four counts of sex trafficking by force, fraud, or coercion, and one count of conspiracy to engage in sex trafficking. In the United States District Court for the Eastern District of Wisconsin, Jackson moved to suppress evidence from his electronic devices, asserting the search warrant lacked probable cause and that the supporting affidavit omitted material facts, entitling him to a Franks hearing. He also objected to the admission of expert testimony regarding sex trafficking dynamics. The district court denied Jackson’s motions, found probable cause for the warrant, determined the omissions were not material, and permitted the expert to testify with limitations. After a jury convicted Jackson on all counts, he was sentenced to concurrent terms totaling 30 years’ imprisonment. On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The court held that the warrant affidavit established probable cause, the omitted facts were not material enough to require a Franks hearing, and the district court did not abuse its discretion in admitting the government’s expert witness under Daubert and Rule 702. The judgment of conviction and sentence was thus affirmed. View "USA v. Jackson" on Justia Law

Craig v City of Richmond

2026-06-18T13:00:56-08:00

An industrial facility in Richmond, Indiana, owned by both private parties and the City of Richmond, caught fire in April 2023 and burned for more than a week. The fire caused the evacuation of nearby residents and allegedly released hazardous substances that damaged hundreds of properties and caused various injuries. Plaintiffs—both individuals and businesses—claimed that the private property owners’ failure to maintain the site and the City’s failure to remediate hazardous conditions after acquiring part of the property led to the fire. The lawsuit sought compensatory and punitive damages under several tort theories, including negligence, nuisance, trespass, and emotional distress. The plaintiffs initially filed their suit in the Wayne County, Indiana Circuit Court, but the defendants removed the action to the United States District Court for the Southern District of Indiana, arguing it qualified as a “mass action” under the Class Action Fairness Act (CAFA), and thus belonged in federal court. The district court, after briefing on whether the action fell within the CAFA “local event or occurrence” exception, concluded that the exception applied. The court found that all claims arose from the single fire event, which occurred in Indiana, and remanded the case to state court for lack of federal subject matter jurisdiction. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s remand order. The court held that the local event or occurrence exception in CAFA is jurisdictional, meaning it can be raised at any time and by the court sua sponte. The appellate court determined that all claims indeed arose from the single fire event and that the exception applied. Therefore, federal jurisdiction was lacking under CAFA. The Seventh Circuit affirmed the district court’s order remanding the case to state court. View "Craig v City of Richmond" on Justia Law

Office of the Special Deputy Receiver v Hartford Fire Insurance Company

2026-06-18T12:30:47-08:00

The Office of the Special Deputy Receiver (OSD), an Illinois non-profit that manages receiverships for insolvent insurance companies, purchased a Financial Institution Bond from Hartford Fire Insurance Company. The bond included coverage for computer systems fraud and for electronic mail initiated transfer fraud, subject to certain exclusions. Hackers infiltrated OSD’s Chief Financial Officer’s email account via a spear phishing attack, impersonated the CFO, and sent fraudulent instructions to other OSD employees, resulting in unauthorized wire transfers and a loss of nearly $4 million. OSD filed claims with both Hartford and another insurer. Hartford denied coverage, asserting that an exclusion in the bond applied to the loss. OSD sued both insurers in the United States District Court for the Northern District of Illinois, seeking declaratory relief and alleging breach of contract. The district court granted Hartford’s motion to dismiss under Rule 12(b)(6), finding that the policy’s exclusion for losses resulting from fraudulent instructions sent to OSD by email applied, and denied the other insurer’s motion. OSD later voluntarily dismissed its claims against the second company, and judgment was entered. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the dismissal de novo. The court held that the exclusion in Rider 17 of the Hartford bond unambiguously barred coverage for losses resulting from fraudulent email instructions sent to OSD—even if the sender was impersonating an internal employee—because the exclusion focused on the recipient, not the sender. The court found no ambiguity or conflict between the exclusion and other coverage provisions, and concluded that OSD’s losses fell outside the scope of coverage. The Seventh Circuit affirmed the district court’s dismissal of OSD’s claims against Hartford. View "Office of the Special Deputy Receiver v Hartford Fire Insurance Company" on Justia Law

Peters Broadcast Engineering, Inc. v PEM Consulting Group, LLC

2026-06-17T11:30:47-08:00

A small Indiana telecommunications engineering company entered into a master services agreement with a larger firm, Crown Castle, for potential construction work on cell tower sites. The agreement did not guarantee specific work or payment, and required approval of any subcontractors. Before the agreement was signed, the company began discussions with a group including the defendants about subcontracting the construction work because it lacked sufficient resources. Communications between the parties included a draft proposal but no finalized agreement. Nevertheless, work commenced, with the defendants providing crews, equipment, and funding, and the plaintiff company also supplying resources and covering expenses. Throughout the project, both parties disputed their responsibilities, and payments were made and later charged back. Eventually, the defendants contacted Crown Castle directly seeking payment, and the project ended with Crown Castle terminating its contract with the plaintiff due to poor work quality. The United States District Court for the Northern District of Indiana granted summary judgment for all defendants. The court found there was no enforceable contract, as both sides admitted no final agreement was reached and essential terms were missing. The court also rejected the plaintiff’s claims for fraudulent inducement, fraud, and negligent misrepresentation, finding no actionable reliance or advisory relationship. The claim for unjust enrichment failed because no benefit was conferred that would make retention unjust. The claim of tortious interference with business relations was dismissed because the defendants’ actions were justified by their legitimate interest in payment. The district court accordingly granted summary judgment to the insurers as well. The United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The appellate court held there was no enforceable contract, no actionable fraud or misrepresentation, no unjust enrichment, and no tortious interference, and upheld summary judgment for all defendants. View "Peters Broadcast Engineering, Inc. v PEM Consulting Group, LLC" on Justia Law

Zurbriggen v Twin Hill Acquisition, Inc.

2026-06-16T10:01:02-08:00

American Airlines contracted with a uniform manufacturer to provide new apparel for its employees. After distribution, many employees reported health issues, including skin and respiratory symptoms, allegedly connected to wearing or being near the uniforms. The airline allowed employees to stop wearing the uniforms, ultimately replacing them. Laboratory and government testing found low levels of chemicals in the uniforms but concluded these were unlikely to cause the reported symptoms. Multiple alternative causes were identified, and the scientific evidence did not support the employees' claims. A group of employees sued American Airlines, the manufacturer, and others in the United States District Court for the Northern District of Illinois, initially seeking class certification under the Class Action Fairness Act (CAFA). After several amended complaints and significant discovery disputes, the plaintiffs dropped their request for class certification, briefly raising questions about the court’s subject matter jurisdiction under CAFA. They later re-pled their class allegations in a fourth amended complaint, and the district court determined it retained jurisdiction. The defendants moved for summary judgment and to exclude the plaintiffs’ expert witnesses, arguing these experts were essential to prove defect and causation. The United States Court of Appeals for the Seventh Circuit reviewed the case. It held that the district court properly retained jurisdiction under CAFA after plaintiffs reasserted class claims. The Seventh Circuit affirmed the exclusion of the plaintiffs’ experts due to unreliable methodologies. It further held that, without expert evidence, the plaintiffs could not establish a defect or causation under strict or negligent products liability. The court also held that neither the Tweedy doctrine nor res ipsa loquitur provided an evidentiary shortcut under the case facts, since the alleged injuries did not inherently indicate a product defect or negligence. The judgment for the defendants was affirmed. View "Zurbriggen v Twin Hill Acquisition, Inc." on Justia Law

Echevarria v. Jackson

2026-06-16T07:30:48-08:00

A man was reported by a caller to have exposed himself in a public area of the Forest Preserve. The caller provided a description of the suspect and his vehicle. Officer Jackson responded, met the complainant at the scene, and was told the suspect was still present. Officer Jackson then located the plaintiff, who substantially matched the description and was driving the specified vehicle. The plaintiff was detained, cited for public indecency, and his vehicle was authorized to be towed. The plaintiff exhibited signs of distress and told the officer he suffered from PTSD. The complainant later left the scene, so the only evidence of the alleged offense was the initial call. The citation was dismissed for lack of evidence. The plaintiff brought suit in the United States District Court for the Northern District of Illinois, Eastern Division, alleging Fourth Amendment violations for unreasonable seizure of his person and property, a Monell claim against the Forest Preserve, intentional infliction of emotional distress, and malicious prosecution under Illinois law. The district court granted summary judgment to the defendants on all counts. The court deemed the defendants’ statements of fact admitted because the plaintiff failed to properly respond under Local Rule 56.1, and found that probable cause existed for the detention and vehicle seizure. The court also held the officer’s comments did not rise to the level of extreme and outrageous conduct required for an emotional distress claim. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s grant of summary judgment de novo, accepting the defendants’ facts as admitted. The Seventh Circuit held that probable cause existed to detain the plaintiff and seize his vehicle under the applicable ordinance, defeating the Fourth Amendment and malicious prosecution claims. The court also found no basis for intentional infliction of emotional distress under Illinois law. The judgment was affirmed. View "Echevarria v. Jackson" on Justia Law

USA v Pramaggiore

2026-06-15T12:30:50-08:00

The case centers on two former executives, one the CEO of an Illinois utility company and the other a lobbyist, who were involved in a series of transactions with the Speaker of the Illinois House of Representatives and his associates. These transactions included setting up contracts, some of which were for no-show jobs, that funneled over $1.3 million to the Speaker's associates over several years. The prosecution alleged that these payments were made in exchange for favorable legislative actions, and that the defendants falsified corporate books and records to conceal these arrangements, in violation of federal statutes including the Foreign Corrupt Practices Act. In the United States District Court for the Northern District of Illinois, Eastern Division, the jury convicted both defendants on all counts, including conspiracy, bribery under 18 U.S.C. § 666, and falsification of books and records. The jury’s verdict was general, without specifying which object of the conspiracy formed the basis for conviction. After the trial, but before sentencing, the Supreme Court decided Snyder v. United States, which limited the scope of § 666 to quid pro quo bribery, excluding illegal gratuities. Based on Snyder, the district court vacated the § 666 convictions and denied the defendants' motions for acquittal or a new trial on the remaining conspiracy and FCPA counts. The United States Court of Appeals for the Seventh Circuit reviewed the case and vacated the conspiracy and FCPA convictions. The court held that because the jury instructions allowed conviction based on legally invalid objects (now invalid under Snyder), and it was unclear on which theory the jury relied, the convictions could not stand. The court further rejected the argument that recent case law required acquittal on the FCPA counts, finding sufficient evidence for a properly instructed jury to convict. The court remanded for possible retrial at the government’s discretion. View "USA v Pramaggiore" on Justia Law

Betts v Boone County

2026-06-15T11:30:55-08:00

In 1977, Louise Betts was kidnapped, raped, and murdered in Boone County, Illinois. The county coroner, Wesley Hyland, conducted an autopsy and returned her body to her family for burial. Decades later, it was revealed that Hyland had secretly kept Louise’s skull, along with the skulls of other deceased individuals, as macabre trophies. In 2022, after Hyland’s death, the coroner’s office notified Louise’s brothers, Gary and Earl, of the skull’s existence, which led the family to exhume her casket to reunite her remains. The Betts brothers filed a lawsuit in the United States District Court for the Northern District of Illinois, Western Division, against Boone County and the current coroner, alleging that the county, through Hyland’s actions, violated their Fourteenth Amendment due process rights by retaining Louise’s skull without notice. They pursued their claim under 42 U.S.C. § 1983, arguing that Hyland’s conduct constituted an official county policy of unconstitutionally retaining property. The district court allowed them to amend their complaint several times but ultimately dismissed the case for failure to state a claim, concluding that Hyland’s actions did not represent official county policy under Monell v. Department of Social Services of City of New York. Upon review, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The Seventh Circuit held that the county was not liable under Monell because Illinois law expressly requires coroners to return all bodily remains to the next of kin. Hyland’s actions were contrary to, rather than representative of, official county policy. The court concluded that a municipality cannot be held liable under § 1983 when its official acts in direct violation of state law, and thus, no official policy of unconstitutional retention was established by Hyland’s conduct. View "Betts v Boone County" on Justia Law

USA v Bolden

2026-06-12T09:01:45-08:00

Police in Milwaukee received information from a confidential informant identifying a drug dealer known as “Blessed,” who was described as armed and driving a red BMW. Investigation linked the BMW to Latia Johnson at a residence on North 42nd Street, and records showed Johnson was the girlfriend of Fernando Bolden, whom the informant identified as “Blessed.” Surveillance video captured Bolden arriving at the residence with a gun and entering the house. A few days later, police obtained a warrant to search the residence, finding firearms, ammunition, large amounts of cash, fentanyl, and other drugs. Bolden was initially prosecuted in Wisconsin state court, but after it was discovered he continued drug activity while on bail, a federal grand jury indicted him on multiple drug and firearm charges. He moved to suppress the evidence from the search, arguing that the affidavit for the warrant did not establish sufficient ties between him and the residence and contained material misrepresentations or omissions. A magistrate judge in the United States District Court for the Eastern District of Wisconsin concluded that the affidavit established probable cause or, at a minimum, that the officers acted in good faith reliance on the warrant. The district court found the affidavit lacking in probable cause but still denied the suppression motion, applying the good-faith exception, and also denied Bolden’s request for a Franks hearing. Bolden then entered a conditional guilty plea, reserving his right to appeal. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s denial of the suppression motion de novo, and its factual findings for clear error. The court held that, even if probable cause was lacking, the good-faith exception applied because the officers reasonably relied on the warrant and there was no evidence of deliberate or reckless misrepresentation or omission in the affidavit. The court affirmed Bolden’s convictions. View "USA v Bolden" on Justia Law

Khouri v Highland Park CVS, L.L.C.

2026-06-11T08:30:46-08:00

A customer was injured at a retail pharmacy when numerous beverage bottles fell from a cooler shelf, striking him and causing him to fall. The coolers in the store were stocked by both employees and independent beverage vendors, with vendors responsible for the majority of products and annual “resets” involving shelf removal and cleaning. Employees did not oversee these resets or move shelves due to their weight, and had limited interaction with the shelves apart from maintaining CVS products and general cleaning. On the day of the incident, the customer saw nothing unusual about the cooler shelf, but when he removed a bottle, many others fell, resulting in his injuries. Store staff responded promptly, but neither had ever seen such an incident or received reports of defective shelves. The customer filed a negligence claim in the Cook County Circuit Court, alleging the pharmacy was responsible for his injuries. The case was removed to the United States District Court for the Northern District of Illinois based on diversity jurisdiction. Following discovery, including expert testimony limitations, the district court held a bench trial. The court found the plaintiff failed to prove negligence under the doctrine of res ipsa loquitur because the evidence did not establish that the pharmacy had exclusive control over the cooler shelves, given the substantial involvement of third-party vendors. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s legal conclusions de novo and factual findings for clear error. The appellate court affirmed the district court’s judgment, holding that res ipsa loquitur did not apply since the plaintiff did not show that the defendant was more likely than not responsible for the injury. The court also found no abuse of discretion in the district court’s evidentiary rulings and limitations on expert testimony. View "Khouri v Highland Park CVS, L.L.C." on Justia Law

Revolinsky v Bayer Corporation

2026-06-10T12:31:15-08:00

This appeal concerns attorney fee allocation following the settlement of multidistrict litigation related to alleged injuries caused by Seresto flea and tick collars. Plaintiffs across the country, including Laura Revolinsky, brought class actions against Bayer and Elanco, claiming the products harmed their pets. Revolinsky’s attorneys sought to have these cases consolidated in New Jersey, while other plaintiffs’ counsel advocated for centralization in Missouri. The Judicial Panel on Multidistrict Litigation ultimately transferred the cases to the Northern District of Illinois, where the district court appointed lead and liaison counsel, but did not appoint Revolinsky’s attorneys to leadership positions. The court entered a case management order requiring counsel to seek advance approval for compensable work and to submit monthly reports; it generally limited compensation to work performed after leadership was appointed, though it allowed lead counsel some discretion to compensate earlier work if it benefited the class. After settlement was reached and a fund established, lead counsel applied for attorney fees, excluding pre-transfer and untimely work by Revolinsky’s attorneys. The district court approved the settlement and fee allocation, and Revolinsky’s attorneys later discovered their compensation was much less than anticipated. They did not timely object to the allocation or procedures. Instead, months after the deadline, they filed a separate motion seeking additional compensation for pre-transfer and untimely work. The United States Court of Appeals for the Seventh Circuit reviewed only the denial of this later motion. The court held that the district court did not abuse its discretion in denying the untimely motion because the procedures and deadlines for fee submissions were clear and had been reasonably enforced. The court affirmed the district court’s order, emphasizing that objections to fee allocations must be raised in a timely manner under court-established protocols. View "Revolinsky v Bayer Corporation" on Justia Law

City of Chicago v Falkner

2026-06-10T12:01:25-08:00

Two individuals filed Chapter 13 bankruptcy petitions, each proposing repayment plans that prioritized payment of their attorneys’ fees before distributing funds to nonpriority unsecured creditors, such as the City of Chicago. Both debtors had below-median incomes and lived in Illinois. One plan proposed to pay secured and priority creditors, the trustee, and attorneys’ fees, with any leftover funds distributed pro rata to nonpriority unsecured creditors. The other plan left no remaining funds for nonpriority unsecured creditors after paying attorneys’ fees. The City of Chicago objected to both plans in the United States Bankruptcy Court for the Northern District of Illinois. The City argued that these plans violated 11 U.S.C. § 1325(b)(1)(B) because they allocated projected disposable income to attorneys’ fees, claiming that bankruptcy attorneys are not unsecured creditors, and thus should not receive such payments. Alternatively, the City argued that even if attorneys are unsecured creditors, they were ineligible for payment because they had not filed proofs of claim. The bankruptcy court overruled the City’s objections, confirming both plans. The court adopted its reasoning from previous cases, finding that attorneys’ fees could be paid during the commitment period and that attorneys did not need to file proofs of claim for payment. On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the bankruptcy court’s decision. The Seventh Circuit held that Chapter 13 plans may provide for the payment of attorneys’ fees before or at the same time as payments to nonpriority unsecured creditors during the commitment period, as required by other sections of the Bankruptcy Code. The court also held that bankruptcy attorneys, as holders of administrative priority claims, are not required to file proofs of claim to receive payment under the plan. View "City of Chicago v Falkner" on Justia Law

Jewel Sanitary Napkins, LLC v Busy Beaver Publications, LLC

2026-06-10T11:30:47-08:00

Jewel Sanitary Napkins, a Georgia-based company, sells feminine hygiene products that it claims provide health benefits, including products containing graphene. The company developed a market among the Amish community and advertised its products through Busy Beaver Publications, which circulates regional advertising papers to that community. In August 2022, Busy Beaver published an ad submitted by a reader, Betty Lantz, that questioned the safety of Jewel's products, suggesting that graphene could attract electrical waves or radiation and pose health risks. The ad was published anonymously at Lantz’s request. Jewel asserted that the ad contained false statements and damaged its reputation. After the ad’s publication, Jewel contacted Busy Beaver to request a retraction, but Busy Beaver instead offered free advertising, consistent with its policy of not issuing retractions. Jewel declined and sued in the United States District Court for the Western District of Wisconsin for libel and trade libel. During discovery, Jewel sought the original ad submission. Busy Beaver initially believed the form had been destroyed per company practice, but later obtained it from Lantz and provided it to Jewel. Jewel withdrew a related spoliation motion but then sought sanctions over the delay. The district court denied Jewel’s motions, including a request to reopen summary judgment briefing, and granted summary judgment to Busy Beaver. The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. It held that, under Wisconsin law and the First Amendment standard for public figures, Jewel failed to present evidence that Busy Beaver acted with actual malice when publishing the ad. The appellate court also found no abuse of discretion in denying sanctions against Busy Beaver. The court affirmed the district court’s judgment in favor of Busy Beaver. View "Jewel Sanitary Napkins, LLC v Busy Beaver Publications, LLC" on Justia Law

United States v. Schatz

2026-06-09T13:00:46-08:00

Joshua Schatz was charged with possessing child pornography in violation of federal law and pled guilty, reserving his right to appeal the application of a statutory enhanced mandatory minimum sentence. The enhancement applies to defendants with a prior state conviction “relating to aggravated sexual abuse, sexual abuse, or abusive sexual conduct involving a minor or ward.” Schatz’s prior conviction was for child molesting under Indiana Code § 35-42-4-3(b), which prohibits sexual contact with children under fourteen. He argued that Indiana’s statute, protecting victims up to fourteen years old and lacking certain federal requirements (like an age-difference between offender and victim), was not sufficiently congruent with federal sex-abuse statutes, which generally protect children under twelve absent an age difference. The U.S. District Court for the Southern District of Indiana applied recent Seventh Circuit precedent, including United States v. Liestman and United States v. Kraemer, which interpreted “relating to” in the enhancement provision broadly. The district court found that the Indiana statute triggered the enhancement, holding that differences in victim ages and other elements were immaterial under a broad reading of “relating to.” Schatz was sentenced to the mandatory minimum of ten years’ imprisonment, which was higher than the guidelines range he would have faced without the enhancement. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the statutory interpretation de novo. Applying the categorical approach and following its prior decision in Liestman, the court held that “relating to” should be read broadly, so Indiana’s child molesting statute categorically relates to the conduct described in the federal enhancement provision. The court affirmed the district court’s judgment, ruling that the enhancement was properly applied to Schatz’s sentence. View "United States v. Schatz" on Justia Law

United States v Washington

2026-06-09T12:30:57-08:00

Frank Washington, III, was convicted after pleading guilty to possessing a firearm as a convicted felon, in violation of 18 U.S.C. § 922(g)(1). During sentencing, his presentence report calculated a guideline range of 70 to 87 months’ imprisonment. Washington requested a 57-month sentence, arguing primarily that his health issues—including high blood pressure, diabetes, and a recent heart attack—increased his vulnerability in prison. He also pointed to other mitigating factors, such as his lack of disciplinary problems in pretrial detention, no substance abuse history, his family relationships, and his acceptance of responsibility. The United States District Court for the Northern District of Indiana, Hammond Division, sentenced Washington to 70 months, at the bottom of the guideline range. The court stated that it had considered all relevant materials and recited several statutory sentencing factors, but it did not specifically address Washington’s mitigation arguments or explain how it weighed those factors in determining the sentence’s length. The court did recommend, at Washington’s request, that he be placed in a facility that could address his cardiac health needs. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether the district court provided an adequate explanation for the sentence imposed. The Seventh Circuit held that the district court’s explanation—consisting of a rote recitation of the statutory sentencing factors without individualized reasoning or discussion of Washington’s specific mitigation arguments—was insufficient under governing precedent. The appellate court vacated Washington’s sentence and remanded the case for resentencing, requiring the district court to articulate an individualized assessment that explains the chosen sentence in light of the arguments and facts presented. View "United States v Washington" on Justia Law

Johnson v Amazon.com Services LLC

2026-06-09T09:03:51-08:00

Two hourly warehouse employees for a large national retailer, on behalf of a putative class, sought compensation for overtime hours spent undergoing mandatory pre-shift COVID-19 health screenings at their workplace during the pandemic. These screenings, lasting roughly 10 to 15 minutes per shift, were required before employees could clock in and begin paid work. The employees asserted that, over time, these unpaid screenings amounted to significant uncompensated overtime in violation of the Illinois Minimum Wage Law (IMWL). The United States District Court for the Northern District of Illinois dismissed their claim, agreeing with the employer’s argument that the IMWL incorporated the federal Portal-to-Portal Act of 1947, which excludes preliminary activities, such as pre-shift screenings, from compensable work. On appeal, the United States Court of Appeals for the Seventh Circuit certified to the Illinois Supreme Court the question of whether the IMWL in fact incorporates these federal exclusions. The Illinois Supreme Court held that the IMWL does not incorporate the Portal-to-Portal Act’s preliminary activities exclusion and that the relevant state regulations define compensable “hours worked” more broadly, including all time an employee is required to be on the employer’s premises. Upon receiving this answer, the Seventh Circuit reversed the district court’s judgment. The appellate court held that the IMWL does not adopt either the preliminary activities exclusion of the Portal-to-Portal Act or the “benefit of the employer” test derived from federal law, except in two specific contexts outlined in state regulations (meal periods and travel). The case was remanded for further proceedings consistent with these interpretations. View "Johnson v Amazon.com Services LLC" on Justia Law

Hundley v. Brookhart

2026-06-09T08:31:17-08:00

A group of correctional officers was terminated by the Illinois Department of Corrections after an incident involving a wheelchair-dependent inmate who refused to comply with orders to place his hands through a cuffing port for removal of handcuffs. Instead of following certain established protocols, the lead officer decided not to activate the tactical team or notify a supervisor, but instead assembled additional officers to enter the inmate’s cell. The officers attempted to remove the handcuffs, leading to a physical altercation in which the inmate resisted, was dragged out of his cell, sprayed with pepper spray, and then left tethered in a shower area for two hours. Incident reports filed by the officers failed to accurately describe the use of force, omitting details such as dragging the inmate. Following an internal investigation, administrative hearings, and review by the Illinois Civil Service Commission, the officers were discharged for violating rules that require force to be used only as a last resort and for submitting false reports. The Commission found that the officers had other options available, had sufficient time to consider alternatives, and that the use of force was not justified as a first response. The Commission also concluded that the failure to report the incident accurately was egregious. The officers filed suit in the United States District Court for the Central District of Illinois, contending that the Department’s use-of-force rules were unconstitutionally vague and thus their termination violated their Fourteenth Amendment due process rights. The district court granted summary judgment to the defendants, finding the rules were sufficiently clear. The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. It held that the “force as a last resort” rule was not unconstitutionally vague as applied to the officers, providing fair warning of prohibited conduct, and that the truthful reporting requirements were also sufficiently clear. The grant of summary judgment for the defendants was affirmed. View "Hundley v. Brookhart" on Justia Law

Arcidiacono v Whitehorn

2026-06-08T12:31:36-08:00

Four individuals who were Medicaid beneficiaries in Illinois were admitted to long-term care facilities between 2018 and 2023. The facilities submitted required electronic admission packets to the Illinois Department of Healthcare and Family Services so that the cost of care could be reimbursed by Medicaid. In each case, the Department either rejected or mishandled these admission packets, resulting in the facilities not being reimbursed for all or part of the care provided. Despite regulations prohibiting providers from billing Medicaid beneficiaries for unreimbursed care, the facilities sent bills to the plaintiffs. The plaintiffs, however, did not pay these bills, nor did they suffer any loss of benefits or interruption in care. The plaintiffs filed a proposed class action in the United States District Court for the Northern District of Illinois against state officials responsible for Medicaid administration. They alleged violations of due process and the Medicaid Act, and requested only injunctive relief to require systemic changes in the admission packet review process. The defendants moved to dismiss, arguing both lack of standing and failure to state a claim. The district court found that the plaintiffs had standing because they received bills, but it dismissed the case for failure to state a claim, reasoning that the plaintiffs were not denied benefits or services and no statutory or constitutional rights were violated. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed only standing. The appellate court held that the plaintiffs lacked standing for injunctive relief because they did not allege a real and immediate threat of repeated injury. The prior receipt of bills did not amount to legal harm, as the plaintiffs had no obligation to pay. The court modified the district court’s judgment to reflect a jurisdictional dismissal for lack of standing and affirmed the judgment as modified. View "Arcidiacono v Whitehorn" on Justia Law

Strickland v City of Markham

2026-06-08T12:00:46-08:00

An African American firefighter was terminated from his position with a municipal fire department after he participated in an Equal Employment Opportunity Commission interview regarding alleged workplace discrimination. Following the interview, he claimed the fire chief and department retaliated against him through discipline and denial of promotion. The administrative board charged him, and after hearings, terminated his employment, citing dishonesty and endangering coworkers during the pandemic. He challenged the administrative termination in the Circuit Court of Cook County, which remanded the matter for further proceedings but retained jurisdiction. After the board reaffirmed his termination, he voluntarily dismissed his state-court suit without seeking further judicial review. Meanwhile, he filed a separate federal lawsuit in the United States District Court for the Northern District of Illinois, alleging violations of Title VII, the Fourteenth Amendment, and Illinois ethics law. The defendants moved for summary judgment, arguing that claim preclusion barred his federal claims based on the prior administrative decision and state-court activity. The district court agreed and granted summary judgment to the defendants on all claims. On appeal, the United States Court of Appeals for the Seventh Circuit determined that the district court erred by treating the unreviewed administrative decision as having claim-preclusive effect over the Title VII claims. Relying on Supreme Court precedent, the Seventh Circuit held that unreviewed state administrative decisions do not preclude federal Title VII claims, although they may preclude § 1983 and similar state law claims if the administrative process was judicial in nature and not reviewed in state court. The court vacated the judgment on the Title VII claims, affirmed as to the other claims, and remanded for further proceedings. View "Strickland v City of Markham" on Justia Law

Ruderman v Kenosha County

2026-06-05T13:00:47-08:00

Three civil immigration detainees housed in a county jail claimed they were forced to perform unpaid custodial work such as cleaning and sweeping. The jail allegedly threatened to discipline those who refused with loss of privileges or solitary confinement for up to ten days. These detainees had not been convicted of any crimes and were being held pending immigration hearings or removal. They filed suit under 18 U.S.C. §1589, which prohibits forced labor and provides a civil remedy under 18 U.S.C. §1595. The United States District Court for the Eastern District of Wisconsin dismissed the suit at the pleadings stage. The district judge reasoned that §1589 applies only to situations involving human trafficking, and concluded that discipline imposed during lawful custody for civil detainees does not constitute trafficking or forced labor as defined by the statute. The district court based its decision mainly on the title and perceived purpose of the larger legislative act containing §1589, the Trafficking Victims Protection Act of 2000, rather than on the specific language of §1589 itself. The United States Court of Appeals for the Seventh Circuit reviewed the case and disagreed with the district court’s interpretation. The appellate court held that the plain language of §1589 is not limited to human trafficking and applies to forced labor imposed on civil detainees, including those held in county jails. The court specifically found that counties are included within the statute’s reference to “whoever,” and that threats such as solitary confinement to compel unpaid labor violate §1589. The Seventh Circuit vacated the district court’s dismissal and remanded the case for further proceedings, including consideration of whether the statute is unconstitutionally vague. View "Ruderman v Kenosha County" on Justia Law

Unite Here Local 1 v Magnificent Mile Hotel Management, LLC

2026-06-05T13:00:46-08:00

An employee at a hotel was terminated after he displayed a knife in the workplace, prompting another employee to feel threatened. The worker’s union filed a grievance under the collective bargaining agreement, which specified that arbitration disputes would be resolved by an arbitrator chosen at random from a list of nine individuals. The union used a random selection website to designate an arbitrator, but the hotel objected, arguing the selected arbitrator was already handling another dispute between the parties and that the usual practice was to mutually agree on an arbitrator or strike names from the list. The United States District Court for the Northern District of Illinois, Eastern Division, first ordered the hotel to proceed with arbitration using the contractually specified method. The arbitrator chosen by the union determined that the employee’s conduct warranted a suspension without pay but did not justify termination, ordering the employee’s reinstatement with back pay minus ten days’ wages. When the hotel refused to comply, the district court, upon the union’s motion, ordered the hotel to abide by the arbitrator’s ruling. The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the collective bargaining agreement’s method of selecting an arbitrator must be followed unless there was a demonstrable lapse in the process, which was not present here. The court also held that the arbitrator’s factual findings regarding the absence of workplace violence were binding and that Illinois public policy did not prohibit the remedy imposed. The Seventh Circuit affirmed the district court’s judgment confirming the arbitrator’s award, finding no error in either the selection of the arbitrator or the substance of his decision. View "Unite Here Local 1 v Magnificent Mile Hotel Management, LLC" on Justia Law

Liu v Mullin

2026-06-05T10:00:47-08:00

An American citizen married to a Chinese national with valid H-1B status sought to have his spouse classified as an immediate relative under immigration law, the first step for her to obtain permanent residency. The citizen had a prior conviction for aggravated criminal sexual abuse involving a minor, which triggered application of the Adam Walsh Child Protection and Safety Act. Under this Act, a U.S. citizen with such a conviction can only sponsor an immediate-relative petition if the Secretary of Homeland Security, in “sole and unreviewable discretion,” determines the citizen poses no risk to the beneficiary. The United States Citizenship and Immigration Services (USCIS) denied both of the citizen’s petitions, finding he failed to show he posed no risk to his spouse. The plaintiffs filed suit in the United States District Court for the Northern District of Illinois, raising statutory and constitutional challenges to the USCIS decisions. The district court dismissed all but one statutory claim for lack of jurisdiction, relying on the Act’s jurisdiction-stripping provisions and the “sole and unreviewable discretion” language. The remaining statutory claim was dismissed for failure to state a claim, with the district court finding that the Adam Walsh Act applies to beneficiaries of any age, not just minors. On appeal, the United States Court of Appeals for the Seventh Circuit agreed with the district court. The court held that it lacked jurisdiction to review statutory and constitutional claims attacking the USCIS’s denial and the processes used, as Congress clearly barred judicial review of both the decision and the methods for reaching it. The court further held that the one statutory claim they could review failed because the Act unambiguously applies to beneficiaries of any age. The court affirmed dismissal of all claims, either for lack of jurisdiction or for failure to state a claim. View "Liu v Mullin" on Justia Law

Associated Press v Neal

2026-06-05T08:30:46-08:00

Several media organizations challenged an Indiana policy that restricts attendance at state executions to a limited set of individuals, including prison officials, spiritual advisors, a small number of people invited by the inmate, and immediate family members of the victim. The policy does not allow members of the press or the general public to attend executions unless they are specifically invited by the inmate. While the guidelines permit media representatives to be present outside the execution chamber and to report freely on the event, they cannot witness the execution itself unless included on the inmate’s guest list. After filing suit under 42 U.S.C. § 1983 in the United States District Court for the Southern District of Indiana, the plaintiffs alleged that Indiana’s policy violated their First Amendment rights—specifically, the qualified right of access to certain government proceedings and the Press Clause. They sought declaratory and injunctive relief and soon requested a preliminary injunction to prevent enforcement of the state’s attendance restrictions for upcoming executions. The district court denied their motion, finding that the plaintiffs were unlikely to succeed on the merits. The court concluded that Supreme Court precedent on public access to criminal proceedings did not extend to executions and that Indiana’s rules did not discriminate against the press because they were treated the same as the public. On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The appellate court held that executions have not historically been open to the press or the general public, so no qualified First Amendment right of access attaches. The court also determined that Indiana’s policy is generally applicable and does not target the press for unfavorable treatment in violation of the Press Clause. Accordingly, the denial of the preliminary injunction was affirmed. View "Associated Press v Neal" on Justia Law

USA v Mickles

2026-06-04T12:30:46-08:00

During a traffic stop in July 2020, Jesse Mickles was pulled over by an Indiana state trooper. Mickles admitted to the trooper that he was a felon and that he had a firearm in his car, which was found under the driver's seat. Two weeks later, a grand jury indicted Mickles for violating 18 U.S.C. § 922(g)(1), which prohibits felons from possessing firearms. Mickles entered a plea agreement that stipulated these facts as the basis for his guilty plea. He also submitted an affidavit stating he was returning the firearm to its owner, but at the change-of-plea hearing, Mickles confirmed his understanding of the charge and agreed with the stipulated facts. The United States District Court for the Southern District of Indiana reviewed Mickles’s plea at a change-of-plea hearing. The court confirmed that Mickles understood the charge and its elements, that he had reviewed the plea agreement thoroughly with his attorney, and that the factual basis reflected his conduct. The court determined that Mickles’s plea was knowing, voluntary, and supported by an adequate factual basis, and accepted his guilty plea. On appeal before the United States Court of Appeals for the Seventh Circuit, Mickles argued that the district court plainly erred by accepting his plea without sufficient factual basis for knowing possession, as required under § 922(g)(1). The Seventh Circuit reviewed for plain error and found overwhelming evidence of constructive possession, including Mickles’s exclusive control of the vehicle, proximity to the firearm, and his admissions. The court held that the factual basis was more than adequate and rejected Mickles’s argument regarding intent. The Seventh Circuit affirmed the judgment of the district court. View "USA v Mickles" on Justia Law

USA v Whitesides

2026-06-03T13:30:46-08:00

Police in Terre Haute, Indiana, began investigating Maurice Whitesides after receiving a tip that he was distributing drugs. During a traffic stop, officers seized over $14,000 from Whitesides, who admitted he was en route to purchase methamphetamine. That same day, police searched a residence Whitesides rented on Spruce Street, recovering over 420 grams of pure methamphetamine, two digital scales, an empty box of sandwich baggies, and a loaded handgun. A separate search of his girlfriend’s home yielded additional methamphetamine, scales, and firearms. Officers also found messages on Whitesides’s cellphone in which he provided the addresses of both residences to suspected drug customers. Although only one sale at the Spruce Street home was confirmed, the evidence suggested ongoing drug distribution activity. A grand jury indicted Whitesides for possession with intent to distribute methamphetamine and for unlawful possession of a firearm by a convicted felon. He pleaded guilty to both charges in the United States District Court for the Southern District of Indiana. At sentencing, the district court applied a two-level enhancement under U.S.S.G. § 2D1.1(b)(12) for maintaining a drug premises, based on evidence found at the Spruce Street home and Whitesides’s use of the address in drug transactions. Whitesides objected, arguing the enhancement was improper and that the district court made certain factual misstatements. The district court overruled his objection and imposed a sentence of 188 months, noting it would have imposed the same sentence regardless. The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the district court properly applied the premises enhancement, finding sufficient evidence that drug distribution was a primary use of the Spruce Street home. The appellate court also determined that any minor factual errors made by the district court were harmless and did not affect the sentencing outcome. The judgment was affirmed. View "USA v Whitesides" on Justia Law

USA v Hawkins

2026-06-02T10:02:17-08:00

Thomas Hawkins, while on federal supervised release for earlier federal robbery convictions, committed two additional armed robberies in Rockford, Illinois. He also participated in an armed home invasion, though the state did not charge him for that offense. Hawkins pleaded guilty to the two new robberies, which led the government to seek revocation of his supervised release. The United States District Court for the Northern District of Illinois, Western Division, held a combined hearing for Hawkins’ new criminal sentences and the supervised release revocation. For the new robberies, the court imposed a sentence of 135 months’ imprisonment and three years of supervised release, referencing the sentencing factors from 18 U.S.C. § 3553(a), including retribution. For the supervised release violations, after Hawkins admitted the violations, the court revoked his release and imposed a 108-month sentence, the statutory maximum under 18 U.S.C. § 3583(e)(3). The court noted the need to protect the public as the dominant consideration and listed relevant factors under § 3583(e), deliberately omitting retribution. On appeal to the United States Court of Appeals for the Seventh Circuit, Hawkins argued that the district court impermissibly considered retribution in the revocation sentence and that the sentence was both excessive and disparate relative to similar cases. The Seventh Circuit held that the district court did not consider retribution in imposing the revocation sentence, finding that its reasoning focused on public safety and conformed to the statutory limits of § 3583(e). The court also rejected arguments regarding unwarranted disparity and substantive unreasonableness, concluding the 108-month revocation sentence was not plainly unreasonable. Accordingly, the Seventh Circuit affirmed the district court’s judgment. View "USA v Hawkins" on Justia Law

Perez-Castillo v Blanche

2026-06-01T14:01:45-08:00

A Mexican national who had lived in the United States without legal status since infancy faced removal proceedings after being convicted of battery under Illinois law for a violent altercation involving his mother and siblings. He conceded his removability but sought cancellation of removal, arguing that his removal would cause his U.S. citizen wife exceptional and extremely unusual hardship. The record showed his wife had health problems and relied on him financially, but she also had support from nearby family members. An Immigration Judge denied his application, finding him categorically ineligible for cancellation of removal because his battery conviction qualified as a “crime of domestic violence” and because his wife’s hardships, while significant, did not meet the statutory threshold. The Board of Immigration Appeals affirmed, agreeing that the conviction rendered him ineligible and holding that he had waived any challenge to the hardship determination by failing to raise it. He petitioned the United States Court of Appeals for the Seventh Circuit for review. The Seventh Circuit applied a highly deferential “substantial evidence” standard to the agency’s factual findings and found no error. The court held that the petitioner’s challenge to the hardship finding was waived and, in any event, the record did not compel a contrary result. The court also held that his conviction for battery under Illinois law, with family members as victims, rendered him ineligible for cancellation of removal as a matter of law. In addition to denying the petition for review, the Seventh Circuit imposed a $5,000 sanction on his counsel for submitting briefs containing numerous fabricated citations and factual misrepresentations produced by AI tools, and referred a second attorney involved to the Illinois disciplinary authorities for further investigation. View "Perez-Castillo v Blanche" on Justia Law

Barnes v Wexford Health Sources, Inc.

2026-06-01T12:00:45-08:00

The plaintiff, an inmate in Illinois Department of Corrections custody, suffered from internal prolapsed hemorrhoids while housed at two correctional facilities. He received medical attention from onsite physicians, including fiber supplements and referrals for further evaluation and treatment. After a series of appointments, diagnostic tests, and pelvic floor therapy, the plaintiff ultimately underwent a hemorrhoidectomy. He alleged that delays in his treatment, specifically in obtaining surgery, were caused by the actions or inactions of two doctors, as well as the referral and collegial review processes overseen by the contracted medical provider. The United States District Court for the Northern District of Illinois, Eastern Division, granted summary judgment to all defendants. The district court found that the plaintiff failed to submit sufficient evidence to establish deliberate indifference by either doctor, including a lack of verifying medical evidence that any delay caused him harm. The court also ruled that the plaintiff’s Monell claim against the medical provider failed because there was no evidence that its policies were the moving force behind a constitutional violation. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s grant of summary judgment de novo. The court held that the plaintiff did not provide evidence that either doctor was deliberately indifferent to his serious medical condition, as both exercised professional medical judgment and responded reasonably to his needs. The court also found that the plaintiff did not submit verifying medical evidence that any delay caused him additional harm. Additionally, the court determined that the Monell claim could not succeed absent an underlying constitutional violation. The Seventh Circuit affirmed the district court’s grant of summary judgment for all defendants. View "Barnes v Wexford Health Sources, Inc." on Justia Law

Wenzler v Coast Guard

2026-06-01T09:01:43-08:00

James Wenzler, a long-serving member of the Coast Guard Auxiliary, was depicted in uniform on his LinkedIn profile and listed as a Branch Chief for Human Resources. In May 2022, after a public complaint about several of his LinkedIn posts—including accusations against Supreme Court Justices and a disparaging comment about the Girl Scouts—the Auxiliary investigated. Wenzler was directed to remove references to his position and uniform from social media. He refused to comply, responding with accusations of racism against the District Commodore who issued the directive. Despite further warnings, Wenzler continued to display his affiliation and make additional insensitive posts, prompting public concern about his suitability for leadership. After Wenzler persisted in disregarding the Auxiliary’s directives, he was suspended and then disenrolled following a formal disciplinary process. He unsuccessfully pursued administrative appeals and then filed suit in the United States District Court for the Western District of Wisconsin. He claimed that his removal constituted retaliation in violation of his First Amendment right to free speech. The district court granted summary judgment for the Coast Guard, finding that even if Wenzler’s posts addressed matters of public concern, the Coast Guard’s interest in maintaining effective and efficient service outweighed his interest in the speech. 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 Coast Guard Auxiliary is entitled to deference in assessing and responding to members’ public speech when they represent themselves as members in uniform. The court concluded that the Auxiliary’s interests in discipline, harmony, and maintaining public confidence justified Wenzler’s separation, and thus, his First Amendment rights were not violated under the Connick/Pickering balancing test. View "Wenzler v Coast Guard" on Justia Law

Watts v Jones

2026-05-29T12:01:16-08:00

David Watts, an inmate at the Wisconsin Secure Program Facility, sent letters indicating he possessed information relevant to a murder investigation. Two detectives sought to interview him, but Watts declined, fearing that the inmate under investigation would discover his cooperation. Watts alleged that, despite his refusal, the detectives’ attempt to speak with him at his cell and reference to his letter exposed him to risk from other inmates. He claimed to have suffered threats and harassment, but not physical injury. The United States District Court for the Western District of Wisconsin largely granted Watts’s request to conduct the litigation under seal, and many filings were redacted. The district court denied the detectives’ motion for summary judgment based on qualified immunity, concluding that while Watts had not suffered physical harm, he could recover nominal and possibly punitive damages for emotional injury. The court relied in part on prior decisions suggesting that exposing a prisoner as an informant creates a constitutional risk, although no express promise of confidentiality had been made to Watts. The United States Court of Appeals for the Seventh Circuit reviewed the case. The appellate court found that Watts had not identified any law clearly establishing a constitutional right to recover damages for exposure to risk of harm that does not result in physical injury. The court distinguished the cited precedents, noting that they involved actual harm. The Seventh Circuit held that, absent a clearly established constitutional right, the detectives were entitled to qualified immunity, and thus to summary judgment. The court reversed the district court’s decision and ordered the case to proceed under the parties’ real names, finding anonymity unjustified. View "Watts v Jones" on Justia Law

Penske Truck Leasing, LP v. Central States Southeast and Southwest Areas Pensi

2026-05-29T08:30:45-08:00

A company operating a nationwide truck leasing business contributed to a multiemployer pension plan on behalf of employees in several bargaining units, including a group in Dallas, Texas (Local 745). After the company and Local 745 negotiated a one-year extension to their collective-bargaining agreement, the pension plan’s trustees rejected the extension, citing concerns that the company was aligning expiration dates to minimize future withdrawal liability. The plan subsequently notified the company that unless it agreed to treat any 2022 withdrawal of Local 745 as a 2021 withdrawal, the participation of Local 745 would be terminated. The company did not accept, and the trustees voted to terminate Local 745’s participation effective December 25, 2021. The company filed suit in the United States District Court for the Northern District of Illinois, seeking to enjoin the expulsion of Local 745 and arguing that the trustees lacked authority under the plan’s Trust Agreement. The district court initially granted a temporary restraining order but later vacated it and denied a preliminary injunction. After discovery, the district court granted summary judgment to the pension plan, finding the plan’s trustees had the authority to expel Local 745 and had not acted arbitrarily or capriciously. The district court also dismissed the plan’s counterclaim seeking a judicial declaration of Local 745’s withdrawal date, holding that this issue must first be resolved through mandatory arbitration under federal law. On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s rulings. The appellate court held that the Trust Agreement granted the trustees discretionary authority to interpret plan provisions, and their decision to expel Local 745 was reasonable and not arbitrary or capricious. The court also affirmed the dismissal of the counterclaim, holding that disputes over withdrawal liability and related determinations must proceed to arbitration before judicial review. The case was remanded for further proceedings on attorney fees. View "Penske Truck Leasing, LP v. Central States Southeast and Southwest Areas Pensi" on Justia Law

Kangol LLC v Hangzhou Chuanyue Silk Import & Export Co., Ltd.

2026-05-29T07:30:45-08:00

A clothing company filed a lawsuit against multiple e-commerce vendors, including a Chinese company, alleging trademark infringement, counterfeiting, unfair competition, and related claims under the Lanham Act. The defendants were identified in a document attached to the complaint. Because the defendants were primarily Chinese entities operating online, the plaintiff asserted it was difficult to determine their exact identities and addresses. The plaintiff sought and was granted permission by the United States District Court for the Northern District of Illinois to serve the defendants by email, which included sending a link to the complaint and other documents. The defendant, Hangzhou, engaged in settlement discussions but did not appear in court, leading to a default judgment. The court’s order also allowed the plaintiff to collect funds from third parties, including from Hangzhou’s Amazon account. After the plaintiff collected a portion of the judgment, Hangzhou appeared and moved to vacate the default judgment, primarily arguing that service by email in China was prohibited under the Hague Service Convention and thus the judgment was void for lack of proper service. The district court denied this motion, concluding that the Convention permits email service in China, and rejected other arguments related to Illinois post-judgment procedures. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s rulings. The appellate court held that the Hague Service Convention prohibits service by email in China, contrary to the district court’s conclusion. However, the appellate court determined that the district court must first decide whether the Convention applies to this case, specifically whether the defendant’s address was “not known,” which would render the Convention inapplicable. The Seventh Circuit therefore reversed the district court’s decision denying the motion to vacate the default judgment and remanded the case for further proceedings to resolve this threshold issue. View "Kangol LLC v Hangzhou Chuanyue Silk Import & Export Co., Ltd." on Justia Law

Jackson v City of Madison

2026-05-28T11:00:45-08:00

A man visited the home of his estranged wife, became intoxicated, and after an altercation with a neighbor, was the subject of a 911 call reporting possible gunshots. Multiple police officers responded, believing they heard gunshots from the direction of the house. After attempts to contact the man inside the home over several hours failed, and learning that he had a history with weapons, the police treated the situation as a barricaded person incident and called in the full SWAT team. To gain compliance, officers broke windows and the door, then shot the man with non-lethal foam rounds as he refused commands and yelled at officers, eventually arresting him after further use of force. The United States District Court for the Western District of Wisconsin reviewed the man’s claims under 42 U.S.C. § 1983, which included allegations of excessive force, failure to intervene, warrantless arrest, and property damage. The district court granted summary judgment to the defendants. It found that exigent circumstances justified the warrantless arrest, no named defendant was responsible for the property damage, and the officers were entitled to qualified immunity on the excessive force and failure to intervene claims. The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The appellate court held that the officers had probable cause for arrest and that exigent circumstances justified the warrantless entry. It determined that the officers were entitled to qualified immunity because the law was not clearly established that their actions during the prolonged standoff violated the Fourth Amendment. The court also found that the failure to intervene and property damage claims were waived due to insufficient argument or standing. The court concluded that, under the facts, the use of non-lethal force did not violate clearly established law, affirming the grant of summary judgment for all defendants. View "Jackson v City of Madison" on Justia Law

Hayes v Board of Education of the City of Chicago

2026-05-28T09:04:20-08:00

Kathleen Hayes worked as an administrator at Northwestern University, responsible for placing student teachers in Chicago Public Schools. During her employment, Hayes made several public social media posts criticizing the school district and its leadership. These posts were seen by at least one Chicago Public School principal, who shared them with Matthew Lyons, the district’s Chief Talent Officer. Lyons then contacted Hayes’s supervisors at Northwestern, expressing concerns about the impact of her comments on the partnership between CPS and Northwestern, but stated he would leave the matter to their discretion and did not recommend termination. Hayes’s direct supervisor soon sought and received permission to terminate her employment, citing the negative effects of her posts on the partnership. Hayes, whose job performance had previously been rated highly, was terminated, and her supervisor later informed Lyons of the action. Hayes filed suit in the United States District Court for the Northern District of Illinois against Lyons and the Board of Education of the City of Chicago. She brought several claims, including First Amendment retaliation, conspiracy, and tortious interference. The district court granted summary judgment to the defendants on all but the First Amendment retaliation claim. It denied summary judgment on that claim, reasoning that Lyons’s communication could constitute an actionable threat and that Lyons was not entitled to qualified immunity because the law was clearly established. The United States Court of Appeals for the Seventh Circuit reviewed only the denial of qualified immunity to Lyons. The court held that even assuming Lyons’s actions violated Hayes’s First Amendment rights, no sufficiently analogous precedent put Lyons on notice that his conduct was unconstitutional. Therefore, Lyons was entitled to qualified immunity and judgment as a matter of law. The Board was dismissed from the appeal, and Hayes’s request for sanctions was denied. The district court’s denial of summary judgment to Lyons was reversed and remanded. View "Hayes v Board of Education of the City of Chicago" on Justia Law

Saslow v. Bankers Standard Insurance

2026-05-28T08:30:46-08:00

After being injured in a car accident, Ronald Saslow and his passenger sought recovery under auto and umbrella insurance policies issued by Bankers Standard Insurance. The Saslows’ policies provided coverage for medical expenses and uninsured/underinsured motorist (UM/UIM) damages, with specific coverage limits outlined per accident or occurrence. The Saslows insured five vehicles and paid separate premiums for each one. Following the accident, they received $879,832 from the other driver’s insurer, and Bankers Standard paid $100,000 under the medical expenses coverage and $1 million under the umbrella policy’s UM/UIM coverage. The Saslows then sought additional payments, arguing they should be allowed to "stack" the coverage limits due to multiple vehicles, premiums, and insured persons, and also claimed entitlement to penalties and fees for delayed payment. The United States District Court for the Northern District of Illinois, Eastern Division, granted summary judgment to Bankers Standard. The district court determined that the insurance policies contained unambiguous anti-stacking provisions, limiting recovery to the stated coverage limits for each occurrence regardless of the number of vehicles, premiums, or insured persons. The court also found that Bankers Standard’s payment delays, although resulting in a two-month late payment, did not amount to vexatious or unreasonable conduct under Illinois law, and therefore did not warrant statutory penalties or attorney fees. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision de novo. The appellate court affirmed the district court’s judgment, holding that the language in both the auto and umbrella policies unambiguously prohibited stacking of coverage limits. The court also concluded that Bankers Standard’s conduct was not vexatious or unreasonable and that no additional payments or statutory penalties were owed to the Saslows. View "Saslow v. Bankers Standard Insurance" on Justia Law

Aberdeen Developers, LLC v Wells Fargo Bank, N.A.

2026-05-28T07:01:22-08:00

Aberdeen Developers, LLC obtained a $41 million loan secured by a mixed-use building in Chicago. The loan was governed by two agreements: a Loan Agreement and a Cash Management Agreement (CMA). During the COVID-19 pandemic, a major tenant filed for bankruptcy, which under the CMA allowed the loan servicer, LNR Partners, LLC, to trigger a Cash Sweep Event Period. As a result, building income was redirected to a special account controlled by LNR Partners. The dispute arose over how long LNR Partners could retain the excess revenue (Excess Cash Flow) in this account: Aberdeen Developers argued for monthly disbursement, while LNR Partners asserted that it could hold the funds until a specific cure event occurred, which had not and might never happen. The case was initially filed by Aberdeen Developers in Illinois state court, alleging breach of contract. The defendants removed the case to the United States District Court for the Northern District of Illinois. The district court concluded that the relevant agreements unambiguously allowed LNR Partners to retain the Excess Cash Flow until the end of the contract term and dismissed the complaint under Rule 12(b)(6). Upon appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s dismissal de novo. The Seventh Circuit determined that the language in the Loan Agreement and CMA was ambiguous because both parties’ interpretations were reasonable. The court held that ambiguity in the contract meant the case could not be resolved on a motion to dismiss and factual development was required to determine the parties’ intent. The Seventh Circuit therefore reversed the district court’s dismissal and remanded the case for further proceedings. View "Aberdeen Developers, LLC v Wells Fargo Bank, N.A." on Justia Law

Wilson v AIM Specialty Health

2026-05-27T14:00:46-08:00

Kellie Wilson, a Black woman, began working at AIM Specialty Health as a contractor and later became a full-time Business Analyst II, receiving regular merit raises but waiting eight years before being promoted. Wilson observed that some non-Black colleagues started at higher salaries and were promoted more quickly. She believed that she was unfairly denied promotions and raises, and after filing a charge with the EEOC and complaining internally, she was eventually promoted. Wilson alleged that AIM’s pay and promotion practices were discriminatory, pointing to specific colleagues’ faster advancement and to actions by her supervisor that she believed evidenced bias. The United States District Court for the Northern District of Illinois, Eastern Division, granted summary judgment in favor of AIM. The court limited Wilson’s claims to those arising on or after April 12, 2017, due to the statute of limitations. The district court found that Wilson had not provided evidence of non-Black comparators who received better treatment and, even if she had, failed to show that AIM’s stated reasons for pay and promotion decisions were pretextual. The court applied the McDonnell Douglas burden-shifting framework in its analysis and concluded that Wilson did not meet her burden. The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court’s grant of summary judgment. The Seventh Circuit held that, regardless of the framework applied, Wilson failed to present evidence from which a reasonable jury could infer that AIM’s justifications for its pay and promotion decisions were pretexts for racial discrimination. The court also found that any misstatement of the causation standard by the district court did not merit reversal, as Wilson’s claims lacked sufficient evidence of pretext. The judgment of the district court was affirmed. View "Wilson v AIM Specialty Health" on Justia Law

Sanchez v. El Milagro, Inc.

2026-05-27T09:04:06-08:00

The plaintiff began working in the production department of a tortilla factory owned by the defendant in July 2019. Due to a disability, she was reassigned from her initial position to a role known as “free person,” which involved substituting on the production line and performing cleaning duties. Several coworkers expressed dissatisfaction with her accommodation, and at one point, there was an attempt to petition for her termination. Over the course of the following year, she alleged that a coworker, Gutierrez, sexually harassed her on three separate occasions by inappropriately touching her buttocks, including one instance involving his genitals. The timing and details of her allegations varied between her written statements, complaint, and deposition. She asserted that she reported the incidents, or at least some of them, to her supervisor, but the record was ambiguous as to whether she identified Gutierrez or characterized the conduct as intentional at the time. After the third incident, she made a formal report to Human Resources, which initiated an investigation. The United States District Court for the Northern District of Illinois, Eastern Division, granted summary judgment in favor of the defendant. The district court found that while the plaintiff subjectively perceived her work environment as abusive, she did not provide her employer with sufficient notice of the alleged harassment prior to her formal report. The court also concluded that, upon receiving clear notice, the employer responded promptly with an investigation and corrective measures. On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The appellate court held that, although a reasonable jury could find the alleged conduct to constitute a hostile work environment, no reasonable jury could conclude that the defendant was negligent in responding to the plaintiff’s complaints. The court found that the employer acted promptly and appropriately once given adequate notice. The judgment was affirmed. View "Sanchez v. El Milagro, Inc." on Justia Law

USA v Coleman

2026-05-26T13:30:47-08:00

Clifton Coleman participated in a drug trafficking organization operating in Chicago between 2019 and 2020. He supplied heroin to three managers, who then cut, mixed, and packaged the drugs for distribution. Coleman also owned an apartment used for these activities, which he rented to one of the managers. Over the course of the operation, Coleman provided at least 25 kilograms of heroin and 40 grams of fentanyl. Law enforcement intercepted wiretapped conversations revealing Coleman’s involvement in decision-making and personnel management within the organization. The United States District Court for the Northern District of Illinois, Eastern Division, sentenced Coleman after he pled guilty to conspiracy to possess with intent to distribute a controlled substance. The court applied two sentencing enhancements: a four-level increase for being a leader under U.S.S.G. § 3B1.1(a), and a two-level increase for maintaining a drug premises under U.S.S.G. § 2D1.1(b)(12). Probation’s recommendation was based on charging documents, Coleman’s plea, and summaries of co-defendants’ post-arrest interviews. Coleman objected, arguing the government withheld recordings that could undermine his leadership status and that he did not maintain the apartment for drug distribution. The United States Court of Appeals for the Seventh Circuit reviewed Coleman’s claims. Applying plain error review for the Brady claim, the Court found that transcript summaries provided sufficient information and that the district court relied primarily on wiretap evidence rather than the disputed agent’s statement. For the drug premises enhancement, the Seventh Circuit concluded that Coleman’s ownership, control, and participation in drug activities at the apartment justified the enhancement, distinguishing the case from prior precedents. The Court affirmed the district court’s judgment. View "USA v Coleman" on Justia Law

USA v Fillyaw

2026-05-26T13:30:47-08:00

Law enforcement officers arrested an individual in a public parking lot while he was carrying a backpack. The arrest was pursuant to a warrant based on allegations of arson. After detaining him, officers seized the backpack and searched it a few minutes later, discovering a loaded handgun and drugs inside. The individual was subsequently charged with federal offenses. The defendant filed a motion in the United States District Court for the Northern District of Illinois, Eastern Division, seeking to suppress the evidence found in the backpack. He argued that the search violated the Fourth Amendment. The district court denied the motion, holding that the search was permissible under the inventory search exception to the warrant requirement. The defendant then pleaded guilty, reserving his right to appeal the suppression ruling. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether the search of the backpack was lawful. The court held that law enforcement may take custody of an arrestee’s personal property when the arrest occurs in a public place, and that an inventory search conducted according to established procedures is lawful. The court found that, although there were minor deviations from departmental policy in the way the search was conducted and documented, these did not render the search unreasonable. The court also rejected the defendant’s argument that officers acted in bad faith, finding no evidence to support this claim. Additionally, the court declined to consider a Fourth Amendment challenge to law enforcement’s use of a license plate reader database because the defendant forfeited the issue by not raising it earlier. Accordingly, the Seventh Circuit affirmed the district court’s denial of the suppression motion. View "USA v Fillyaw" on Justia Law

Hinkes v Reddy

2026-05-22T12:31:36-08:00

Sarah Hinkes brought a lawsuit against her employer and two individual employees, alleging discrimination in violation of federal statutes. The dispute was stayed pending arbitration, as required under federal law. After the arbitrator ruled in favor of the employer, Hinkes sought to have the arbitration award set aside in the United States District Court for the Northern District of Illinois. The district judge confirmed the award, and Hinkes appealed that decision. On appeal, subject-matter jurisdiction was challenged due to lack of diversity between the parties, as both Hinkes and one defendant, Ravi Reddy, were citizens of Illinois. Although Hinkes attempted to argue that Reddy should be disregarded because she was not seeking relief against him, the court noted that Reddy remained a party to the action. Hinkes later asked for the appeal to be dismissed, but Sunera Technologies, the employer, argued for federal-question jurisdiction under 28 U.S.C. §1331. The Seventh Circuit identified that the original suit arose under federal law, and, following recent precedent from Kinsella v. Baker Hughes Oilfield Operations, LLC and Jules v. Andre Balazs Properties, concluded that federal-question jurisdiction continued to support the district court’s confirmation of the arbitration award. The United States Court of Appeals for the Seventh Circuit reviewed Hinkes’s challenges to the arbitration award, which centered on procedural objections and alleged misconduct under 9 U.S.C. §10(a)(3). The court determined that Hinkes had not shown arbitrator misconduct warranting vacatur, as the arbitrator did not improperly refuse to hear evidence and was not bound by federal evidentiary or discovery rules. Finding no misbehavior or prejudice, the Seventh Circuit affirmed the district court’s confirmation of the arbitration award. View "Hinkes v Reddy" on Justia Law

Burton v Will County Sheriff's Merit Commission

2026-05-22T12:01:17-08:00

An applicant for a deputy sheriff position in Will County, Illinois, underwent a rigorous merit-selection process that included a background check. The applicant, who was working as a railroad signalman at the time, received a highly unfavorable employment reference from his supervisor, stating he was not dependable, did not work well with others, would not be rehired, and was not recommended for law enforcement employment. Based on this negative reference, the Will County Sheriff’s Merit Commission removed him from further consideration for certification as a deputy sheriff. The applicant, who is Black, alleged that his removal was based on racial discrimination. After his removal, the applicant filed a lawsuit in the United States District Court for the Northern District of Illinois, Eastern Division, against the Merit Commission, the Sheriff’s Office, and Will County. The defendants moved for summary judgment, arguing that the Commission was too small to be a Title VII employer and that the Sheriff’s Office and County were not involved in the certification decision. The district judge did not resolve the Title VII coverage issue but granted summary judgment on the merits, finding that the applicant failed to produce evidence that race was a motivating factor in the Commission’s decision or that the stated reason was a pretext for discrimination. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the summary judgment order de novo. The Seventh Circuit affirmed the district court's decision, holding that there was no evidence that race played any role in the Merit Commission’s decision. The court found the negative employment reference to be a legitimate, nondiscriminatory reason for removal, with no support in the record for an inference of pretext or racial animus. The judgment for the defendants was affirmed. View "Burton v Will County Sheriff's Merit Commission" on Justia Law

USA v. McKay

2026-05-20T12:31:18-08:00

Dennis McKay pled guilty to three counts of Hobbs Act robbery affecting commerce and one count of discharging a firearm in connection with a crime of violence. In his plea agreement, he also admitted to four additional robberies and to possessing a firearm as a felon. The U.S. Probation Office prepared a Presentence Investigation Report recommending, among other terms, Special Condition 13 for supervised release, which would require McKay to notify third parties of any “risk” he posed, as determined by a probation officer. McKay submitted written objections to two other conditions but did not object in writing to Special Condition 13. At sentencing, defense counsel did not initially object but, when specifically asked by the district judge, argued that the condition was unwarranted because McKay’s history did not show a persistent threat of violence. The United States District Court for the Northern District of Illinois, Eastern Division, imposed Special Condition 13 despite defense counsel’s oral objection, noting the lack of an initial objection but allowing the defense to respond after hearing from probation and the government. The district judge stated that she would reconsider the condition if there were evidence of it being abused in the future. McKay then appealed, challenging only Special Condition 13. The United States Court of Appeals for the Seventh Circuit reviewed whether McKay’s objection was waived and found that his oral objection at sentencing was sufficient to preserve the issue for appeal, even though his arguments on appeal were broader than those made at sentencing. On the merits, the Seventh Circuit held that Special Condition 13 was impermissibly vague, following its own precedents, and vacated the condition. The case was remanded to the district court for further proceedings to clarify or modify the condition. View "USA v. McKay" on Justia Law

D'Ambrosio v Meta Platforms, Inc.

2026-05-15T12:31:15-08:00

The case concerns a man who sued several parties after negative posts about him appeared in a large Chicago-based Facebook group where women share experiences about local men. The posts, made in late 2023, included a woman he briefly dated recounting her unpleasant experiences, attaching a screenshot of a profane text message he sent her after their breakup. Other posts by unidentified users included supportive comments and, in one instance, a link to a news article about a criminal case involving someone with a different name and appearance. The plaintiff alleged these posts caused him reputational, economic, and emotional harm. In the United States District Court for the Northern District of Illinois, the defendants—including the former date, her parents (for allegedly allowing use of their internet connection), the group’s administrators, and Meta Platforms—moved to dismiss the complaint for failure to state a claim. The court granted the motions, finding the claims legally insufficient and dismissing the case with prejudice. The plaintiff appealed and voluntarily dismissed claims against unidentified “Jane Doe” defendants to preserve diversity jurisdiction. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s dismissal. The appellate court affirmed, holding that the plaintiff failed to state plausible claims under the Illinois Right of Publicity Act because none of the defendants used his likeness for a commercial purpose. The court also found the “doxing” claim insufficient, as there were no plausible allegations of intent or recklessness regarding harm or stalking. Defamation and related claims failed because the allegedly defamatory material could be innocently interpreted or lacked special damages. The court also concluded that the appeal as to the woman and her parents was frivolous and ordered the plaintiff and his attorneys to show cause why sanctions should not be imposed for bringing a meritless appeal and for submitting briefs containing fictitious quotations and misstatements of law. The court awarded costs to other appellees and referred attorney conduct to state disciplinary authorities. View "D'Ambrosio v Meta Platforms, Inc." on Justia Law

Tire Town Auto LLC v Wood County

2026-05-12T12:01:08-08:00

Tire Town Auto LLC, a towing service based in Marshfield, Wisconsin, operated for years on a list maintained by Wood County for dispatching towing companies to remove disabled vehicles from public roads. Wood County required businesses on the list to comply with a set of minimum standards, including 24/7 availability, liability insurance, and rules such as the use of reflective vests. After complaints about noncompliance with these standards—including failure to wear vests and alleged overcharging—Wood County removed Tire Town from the rotation list. Tire Town filed suit three years later, alleging that its removal violated its procedural due process rights under the Fourteenth Amendment. The United States District Court for the Western District of Wisconsin dismissed Tire Town’s amended complaint, finding that Tire Town had not plausibly alleged deprivation of a property interest protected by due process. The court determined that neither Wisconsin law nor any contract, statute, or ordinance guaranteed Tire Town a spot on the towing rotation list. The Minimum Standards policy explicitly stated it was not a contract and gave the county broad discretion to remove companies from the list. The United States Court of Appeals for the Seventh Circuit reviewed the dismissal de novo. The appellate court affirmed the district court’s judgment, holding that Tire Town had not plausibly alleged a protected property interest in remaining on the towing rotation list. The court concluded that the Minimum Standards policy did not restrict the county’s discretion sufficiently to create a legitimate claim of entitlement, and Tire Town could not reasonably rely on the policy as a source of property rights. The court rejected arguments based on unwritten “mutually explicit understandings,” finding no basis in law or contract for a protected property interest. View "Tire Town Auto LLC v Wood County" on Justia Law

Lee v Milwaukee County, Wisconsin

2026-05-07T09:02:59-08:00

The plaintiff, a pretrial detainee, was incarcerated for two and a half years in a county jail operated by Milwaukee County, which contracted with Wellpath, LLC to provide medical and mental-health services. Upon arrival, the plaintiff disclosed a history of traumatic brain injury and post-traumatic stress disorder, as well as other ailments, and claimed he was actively being treated before detention. The record lacks medical documentation from either before or during detention and contains limited information on his evaluation or treatment in the jail. During the COVID-19 pandemic, detainees, including the plaintiff, were subjected to frequent and lengthy lockdowns, which sometimes involved disabling toilets in cell blocks due to flooding. The plaintiff consistently filed grievances regarding inadequate mental-health care, lack of veteran services, physical pain, and unsanitary conditions within the facility. The plaintiff initiated a pro se lawsuit under 42 U.S.C. § 1983 against the county, alleging unconstitutional conditions of confinement and inadequate medical care. The United States District Court for the Eastern District of Wisconsin, after screening the complaint, allowed several claims to proceed but ultimately granted summary judgment in favor of the county. The magistrate judge concluded that the plaintiff had not shown the lockdown policies were unconstitutionally excessive, that the cited unsanitary conditions were objectively serious or pervasive, or that the medical care provided was constitutionally deficient or attributable to a county policy or practice under Monell v. Department of Social Services. The United States Court of Appeals for the Seventh Circuit reviewed the grant of summary judgment de novo. The court held that, despite serious allegations and the plaintiff's challenging circumstances, the evidence in the record did not raise a triable issue of material fact as to whether any of the alleged conditions or medical care rose to the level of a constitutional violation. Therefore, the Seventh Circuit affirmed the district court’s grant of summary judgment in favor of Milwaukee County. View "Lee v Milwaukee County, Wisconsin" on Justia Law

N. T. v Galesburg Community Unit School District No. 205

2026-05-06T12:30:40-08:00

A young elementary school student with disabilities was placed by agreement of his parents and local school district in a special education classroom at his neighborhood school due to behavioral struggles. Three weeks after this placement, the school district proposed an Individualized Education Plan (IEP) that would move the student to a private therapeutic day school in another district, requiring lengthy daily bus rides and removing him from his local environment and peers. The parents objected, believing that this more restrictive placement violated their son’s rights under the Individuals with Disabilities Education Act (IDEA), and requested a due process hearing. An independent hearing officer conducted several days of hearings and found in favor of the school district, concluding that the district had complied with the IDEA and that the proposed placement at the therapeutic day school was appropriate. The parents then sought judicial review in the United States District Court for the Central District of Illinois. At a bench trial, the district court considered new evidence, including testimony about the student's progress and potential benefits of additional supports in his current classroom. The district court found that the student had made significant progress and would benefit from a one-on-one aide, and concluded that the school district’s proposed placement would violate his right to an education in the least restrictive environment under the IDEA. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court's decision for clear error, giving due weight to the administrative record but acknowledging the significance of new evidence introduced at trial. The Seventh Circuit held that the district court did not make mistakes of law or clearly err in finding that the student could receive a satisfactory education in his local special education classroom with additional supports, and affirmed the district court’s order requiring the school district to create an appropriate IEP for that placement. View "N. T. v Galesburg Community Unit School District No. 205" on Justia Law

Mohammed v Blanche

2026-05-05T14:00:40-08:00

The petitioner, a Muslim from India, managed a family slaughterhouse business that became a target for hostility from local Hindus affiliated with the Bharatiya Janata Party, who viewed cows as sacred. In May 2016, he and his mother were attacked by a group who demanded that the slaughterhouse be closed; the incident resulted in minor injuries and police intervention. Shortly after, he entered the United States on a visitor visa but overstayed. He did not apply for asylum until January 2019, well past the one-year statutory deadline. Following his application, the U.S. Citizenship and Immigration Services rejected it as untimely. Removal proceedings were initiated, and the immigration judge found no extraordinary circumstances excusing the late filing, denying his asylum application as untimely. The judge also denied requests for withholding of removal and protection under the Convention Against Torture, finding insufficient evidence of past or future persecution. The Board of Immigration Appeals reviewed and affirmed these decisions, dismissing his appeal. The United States Court of Appeals for the Seventh Circuit reviewed his petition. Relying on existing circuit precedent, the court held it lacked jurisdiction to review the immigration judge’s determination that the asylum application was untimely, as the petitioner did not present arguments addressing the jurisdictional issue and the challenge involved factual rather than legal questions. On the merits of withholding of removal, the court applied the substantial evidence standard and concluded that the record did not compel a finding of past persecution or a likelihood of future persecution, given the limited harm suffered, the lack of government complicity, and the petitioner's ability to relocate within India. The court dismissed the petition regarding asylum for lack of jurisdiction and denied it in all other respects. View "Mohammed v Blanche" on Justia Law

Shiba v Mullin

2026-05-05T11:31:12-08:00

After suffering a workplace injury just two months into his role as an immigration officer at the United States Citizenship and Immigration Services (USCIS), the plaintiff took medical leave and received workers’ compensation for more than three years. When it became clear that he could not return to work, the agency terminated his employment. He challenged this decision before the Merit Systems Protection Board (MSPB), which ordered his reinstatement based on new medical opinions indicating he could return with restrictions. However, his attempt to resume work was unsuccessful due to worsening symptoms, and he quickly returned to medical leave. During his extended absence, the Office of Inspector General investigated his freelance activities, ultimately concluding that he had misused his federal position. The agency terminated him again. The plaintiff then filed complaints with the USCIS Office of Equal Opportunity and Inclusion and the Equal Employment Opportunity Commission (EEOC), alleging disability discrimination, failure to accommodate, a hostile work environment, and retaliation under the Rehabilitation Act. After EEOC proceedings concluded against him, he filed suit in the United States District Court for the Northern District of Illinois. The district court entered summary judgment for the Secretary of Homeland Security, finding that most of the claims were unexhausted because the plaintiff did not timely pursue administrative remedies. The court also found that, on the merits, he was not a “qualified individual” under the Rehabilitation Act because he could not perform the essential functions of his job, and that there was insufficient evidence of a hostile work environment or retaliation. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed only the accommodation and hostile-workplace claims. The court held that both claims were barred for failure to timely exhaust administrative remedies. Alternatively, the court held that the claims also failed on the merits. The judgment of the district court was affirmed. View "Shiba v Mullin" on Justia Law

USA v. Blocker

2026-05-05T07:30:40-08:00

Adam Blocker used Dropbox, a cloud storage service, to share files, some of which contained child pornography. Dropbox detected these illegal files through its own monitoring, as permitted by its terms of service, and reported them to the National Center for Missing and Exploited Children (NCMEC). Following this report, NCMEC notified federal authorities, which led the FBI to obtain a search warrant for Blocker’s digital storage. The subsequent search uncovered additional illegal images. Blocker pleaded guilty to two counts related to possession and distribution of child pornography, but reserved the right to appeal the denial of his motion to suppress the evidence obtained from Dropbox and his devices. In the United States District Court for the Northern District of Illinois, Eastern Division, Judge Lee denied Blocker’s suppression motion. The court concluded that Blocker had consented to Dropbox’s search and disclosure of his files by agreeing to its terms of service. Blocker argued that the terms were not specific or clear enough to constitute voluntary consent, especially because NCMEC is a government-affiliated entity. After Judge Lee’s elevation to the appellate court, the case was transferred to Chief Judge Kendall, who oversaw Blocker’s sentencing. The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s decision. The court held that Blocker’s acceptance of Dropbox’s terms of service constituted effective consent for Dropbox to scan his files and disclose them for certain purposes, including reporting to authorities. The court rejected Blocker’s argument that the consent was invalid because the terms did not obligate Dropbox to search every file or regularly disclose information. The Seventh Circuit found no clear error in the district court’s finding of consent, and thus upheld the denial of the motion to suppress. View "USA v. Blocker" on Justia Law

Bernal v Kohl's Corporation

2026-05-01T09:04:03-08:00

A group of consumers residing in California purchased products online from a national retailer’s website between 2020 and 2022. To complete their purchases, they were required to agree to the retailer’s Terms and Conditions, which included an arbitration clause mandating that any disputes be resolved through arbitration before the American Arbitration Association (AAA) and that certain pre-arbitration steps be followed. When the consumers later believed that the retailer had engaged in false and deceptive marketing, they followed the pre-arbitration process as outlined, served notices of dispute, attempted mediation, and, after those efforts failed, filed demands for arbitration with the AAA and paid all required fees. After the consumers initiated arbitration, the AAA notified the parties that the retailer had not filed its arbitration agreement with the AAA as required by AAA rules. The AAA requested compliance, but the retailer refused to register its agreement. As a result, the AAA, following its Consumer Arbitration Rules, terminated the arbitration proceedings and closed the consumers’ cases. The consumers then filed a petition in the United States District Court for the Eastern District of Wisconsin seeking to compel arbitration, arguing that the retailer’s refusal to register the agreement and pay related fees constituted a refusal to arbitrate under the Federal Arbitration Act. The district court denied the petition, relying on precedent which holds that, when arbitration proceeds and ends in accordance with the agreed rules—even if terminated by the arbitral forum for procedural reasons—a court may not intervene to compel further arbitration. The United States Court of Appeals for the Seventh Circuit affirmed, holding that because the parties’ agreement delegated procedural questions to the AAA and the AAA exercised its discretion under its rules in terminating the proceedings, there was no refusal to arbitrate that would justify judicial intervention under the Act. View "Bernal v Kohl's Corporation" on Justia Law

Coatl-Chiquito v Blanche

2026-04-30T13:30:41-08:00

The petitioner, a noncitizen, entered the United States without inspection in 2004 and, after surviving a car accident and being detained, was served with a notice to appear at a Chicago immigration hearing. The notice did not specify the date and time of the hearing; a later notice with that information was sent to an Indiana address provided by the petitioner during her detention. The petitioner claims she never lived at that address, having moved to Ohio after the accident. She failed to appear at the hearing and was ordered removed in absentia. No action was taken on the removal order for sixteen years. Years later, the petitioner filed a motion to reopen her removal proceedings, citing the Supreme Court’s decisions in Pereira v. Sessions and Niz-Chavez v. Garland, which clarified notice requirements for removal hearings. She argued these decisions should allow equitable tolling of the deadline to reopen her case and render her eligible for cancellation of removal. The Immigration Judge denied her motion, finding no basis for equitable tolling and declining to reopen sua sponte. While her appeal to the Board of Immigration Appeals was pending, she filed a second motion to reopen, arguing for the first time that she had not received proper notice of the hearing. The Board found this second motion was numerically barred and rejected her lack-of-notice claim. The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that Niz-Chavez does not equitably toll the statutory deadline to reopen a final order of removal when the claimed defect could have been raised earlier with diligence. It also held that the petitioner’s second motion was properly denied as numerically barred. The court further dismissed, for lack of jurisdiction, the claim that the Board erred by declining to reopen the case sua sponte, as no constitutional or legal error was identified. The petition for review was denied in part and dismissed in part. View "Coatl-Chiquito v Blanche" on Justia Law

USA v Wooden

2026-04-30T12:01:09-08:00

Glenn Wooden was caught selling nearly 100 grams of methamphetamine to confidential informants in a series of controlled buys organized by the West Central Illinois Task Force. Police obtained audio and video evidence of the transactions, searched Wooden’s apartment, and found an additional 222 grams of methamphetamine packaged for distribution, along with proceeds from the sales. After his arrest, Wooden confessed on video to distributing methamphetamine, describing the substance as “hot”—slang for illegal. He was indicted on three counts of distributing and one count of possessing methamphetamine. At trial in the United States District Court for the Central District of Illinois, Wooden represented himself. He did not dispute the facts but argued that the government failed to prove the methamphetamine involved was the specific “optical isomer” form that is illegal under federal law, asserting that not all methamphetamine is criminalized by the Controlled Substances Act. He raised this defense throughout trial and in a post-trial motion. The district court rejected his argument, instructed the jury using the Seventh Circuit’s pattern instructions that treat “methamphetamine” as a generic term, and clarified to the jury that all methamphetamine is illegal. Wooden was convicted on all counts and sentenced to 25 years in prison. The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and held that the Controlled Substances Act criminalizes the possession and distribution of methamphetamine generically, not limited to specific isomers. The court affirmed the district court’s instructions and found the government’s evidence sufficient. The Seventh Circuit also found no error in allowing testimony from a DEA chemist and declined to adopt Wooden’s narrow statutory interpretation. The district court’s judgment was affirmed. View "USA v Wooden" on Justia Law

Nimaga v. Blanche

2026-04-29T21:03:01-08:00

A native of Ivory Coast and citizen of Mali entered the United States as a student in 2000. The Department of Homeland Security initiated removal proceedings against him in 2010 for failing to maintain his student status. He admitted the allegations and conceded removability. While his removal case was pending, he was a victim of domestic violence by his U.S. citizen spouse, leading to her criminal conviction and their eventual divorce. He applied for a U visa and for cancellation of removal as a victim of domestic violence. His attorney withdrew from representation in June 2019. Before his scheduled October 2019 immigration hearing in Chicago, the petitioner was robbed, losing his savings and becoming destitute. He was unable to secure transportation to the hearing after his friend failed to provide a ride and he lacked funds for a bus ticket. He did not contact the Immigration Court to explain his absence. The Immigration Judge ordered him removed in absentia. After the Immigration Judge denied his motion to reopen and rescind the removal order—finding he failed to show "exceptional circumstances" for missing the hearing—the petitioner appealed to the Board of Immigration Appeals. The Board agreed, reasoning that his financial hardship and failed transportation arrangements did not amount to exceptional circumstances because he had not demonstrated that these events prevented him from notifying the court in advance. The United States Court of Appeals for the Seventh Circuit reviewed the Board’s decision for abuse of discretion. The Seventh Circuit held that the Board did not abuse its discretion in denying the motion to reopen. The court found that, although the petitioner faced significant hardships, his failure to notify the court of his predicament undermined his claim of exceptional circumstances. The petition for review was denied. View "Nimaga v. Blanche" on Justia Law

Ballard v Ameren Illinois Company

2026-04-28T10:00:40-08:00

The plaintiff, Kimberly Ballard, worked for Ameren Illinois Company and was terminated from her position in February 2018. She alleged that her dismissal, as well as other adverse actions at work, stemmed from discrimination and retaliation based on her physical disability. After her termination, Ballard submitted a Complainant Information Sheet (CIS) to the Illinois Department of Human Rights (IDHR) within 300 days, as required for federal discrimination claims, and later engaged in further correspondence with the agency. Ultimately, the IDHR finalized a formal charge of discrimination more than 300 days after her termination, which led to her receiving a right-to-sue letter from the Equal Employment Opportunity Commission (EEOC). The United States District Court for the Central District of Illinois dismissed Ballard’s lawsuit, concluding that her CIS did not qualify as a “charge” of discrimination under the Americans with Disabilities Act (ADA) because it did not include a request for remedial action, and thus she failed to meet the statutory 300-day filing requirement. The district court further denied Ballard’s motion for reconsideration, which argued that either her CIS was sufficient under Supreme Court precedent or, alternatively, that equitable tolling should apply due to confusing communications from the IDHR. The district court did not address her equitable tolling argument. The United States Court of Appeals for the Seventh Circuit reviewed the case. The appellate court affirmed that, under its precedent, a CIS is not a “charge” for ADA purposes and upheld the district court’s dismissal on that ground. However, the court found that Ballard’s equitable tolling argument warranted consideration due to possible misleading conduct by the IDHR and an incomplete record. The Seventh Circuit vacated the district court’s judgment and remanded the case for further proceedings regarding equitable tolling. View "Ballard v Ameren Illinois Company" on Justia Law

USA v. Madigan

2026-04-27T21:03:47-08:00

A longtime Speaker of the Illinois House of Representatives was prosecuted in federal court for engaging in extensive bribery schemes. The first involved a major utility company, Commonwealth Edison (ComEd), which, facing financial difficulties, funneled more than $3 million to the defendant’s political associates through intermediaries and sham contracts in exchange for the defendant’s legislative support of ComEd’s agenda over several years. The government presented evidence that these payments resulted in concrete legislative actions by the defendant that benefitted ComEd, including support for specific bills and regulatory changes. The second scheme involved the defendant’s agreement to recommend a Chicago alderman for a state board appointment in exchange for business referrals and benefits to the defendant’s family. Following a lengthy trial in the United States District Court for the Northern District of Illinois, the jury convicted the defendant on several counts, including conspiracy, federal-program bribery, honest-services wire fraud, and Travel Act violations. The jury acquitted him on some counts and was deadlocked on others. The district court denied the defendant’s motions for acquittal and for a new trial, then imposed a sentence of imprisonment and a substantial fine. On appeal to the United States Court of Appeals for the Seventh Circuit, the defendant challenged the sufficiency of the evidence and the adequacy of the jury instructions. The Court of Appeals held that sufficient evidence supported each conviction and found no prejudicial error in the jury instructions, including those related to the definition of “official act,” “corruptly,” and the intent elements of bribery. The court also concluded that any potential instructional error regarding state law bribery under the Travel Act was harmless beyond a reasonable doubt. The convictions and sentence were affirmed. View "USA v. Madigan" on Justia Law

USA v. Corruthers

2026-04-27T08:30:40-08:00

The case centers on Ashantae Corruthers, who, at the request of her friend Regina Lewis, agreed to purchase a firearm for Lewis’s cousin, Darrion Lafayette, in exchange for money. In November 2020, the group traveled from Illinois to Indiana, where Corruthers bought a Glock 48 pistol and ammunition for Lafayette, falsely certifying on the ATF purchase form that she was the true buyer. The firearm was later used by Lafayette in multiple incidents, including the fatal shooting of a police officer in Champaign, Illinois. Afterward, Corruthers falsely reported the firearm as stolen and made misleading statements to federal agents regarding her involvement. A federal grand jury indicted Corruthers and Lewis for conspiracy to illegally purchase and transfer a firearm and conspiracy to engage in misleading conduct. Lewis pled guilty and was sentenced to 60 months’ imprisonment on the firearm charge and 102 months on the misleading conduct charge, to run concurrently. Corruthers also pled guilty. In her case, the United States District Court for the Central District of Illinois calculated her guidelines range at 21 to 27 months but imposed an above-guidelines sentence of 48 months, citing the seriousness and consequences of her conduct. The court rejected the government’s argument to apply the higher offense level for obstruction of a murder investigation, finding that the post-shooting inquiry was not a murder investigation. The United States Court of Appeals for the Seventh Circuit reviewed both Corruthers’s appeal of her sentence and the government’s cross-appeal. The court held that the district court did not abuse its discretion by imposing an above-guidelines sentence, as it fully considered the relevant factors and provided adequate justification. It also affirmed the district court’s refusal to apply the higher guidelines for obstruction, finding no clear error in its determination of the investigation’s scope. The sentence was affirmed. View "USA v. Corruthers" on Justia Law

USA v Melega

2026-04-24T06:30:41-08:00

Mitchell Melega, serving as the financial controller for two companies owned by Erik Jones, participated in a scheme to defraud two regional banks. The companies, involved in vehicle sales and property management, submitted false promises and forged documents to secure loan advances for nonexistent projects or vehicles. Melega played a central role in submitting fraudulent documents, directing employees to hide the scheme, and helping divert the funds for unauthorized purposes. The fraudulent activities spanned over a year and caused more than $7,000,000 in losses to the banks. Both Melega and Jones were indicted on multiple counts, but while Jones entered a plea agreement with a set sentencing range and received 54 months' imprisonment, Melega entered an open plea and proceeded to sentencing without a stipulated range. The United States District Court for the Central District of Illinois calculated Melega’s sentencing range using the 2023 U.S. Sentencing Guidelines, applying a two-level enhancement for the use of sophisticated means and another two-level enhancement for his role as a supervisor in the offense. The court found Melega directly engaged in complex concealment and management of the fraudulent scheme, including instructing others to provide false information. After considering these enhancements and mitigation evidence, the court sentenced Melega to 75 months, a term below the advisory guideline range. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether the enhancements were properly applied, whether the court relied on unreliable facts, and whether there was an unwarranted sentencing disparity compared to Jones. The Seventh Circuit held that the district court did not clearly err in applying either enhancement, did not rely on inaccurate or unreliable information, and provided a reasonable basis for the sentencing disparity. The appellate court affirmed Melega’s sentence. View "USA v Melega" on Justia Law

Shiba v Mullin

2026-04-23T21:03:31-08:00

An individual applied for a position as a citizenship and immigration assistant with the United States Citizenship and Immigration Services (USCIS), which required a security clearance. After being tentatively selected, the applicant’s background investigation revealed concerns that led to a prolonged delay. When the security issues remained unresolved for over a year, the agency rescinded the job offer. The applicant alleged that the delay and ultimate rescission were not due to genuine security concerns but were instead a pretext for retaliation based on prior complaints and litigation against the Department of Homeland Security (DHS) for disability discrimination. Previously, the applicant had been terminated from a different DHS position following a work-related injury and a subsequent Inspector General investigation, which substantiated some misconduct but not the most serious allegations. After several unsuccessful attempts to regain federal employment, and following additional administrative complaints, the applicant filed suit in the United States District Court for the Northern District of Illinois, asserting retaliation under the Rehabilitation Act. The Secretary of Homeland Security moved to dismiss, relying on Department of the Navy v. Egan, which bars judicial review of security-clearance decisions. The district court dismissed the case for lack of subject-matter jurisdiction. The United States Court of Appeals for the Seventh Circuit reviewed the case and clarified that Egan’s rule is not jurisdictional but is instead a merits-based limitation, mandating judicial deference to executive security-clearance decisions. The appellate court held that the applicant’s retaliation claim required impermissible judicial scrutiny of the agency’s security-clearance reasoning and thus fell squarely within Egan’s bar. The court modified the district court’s dismissal to reflect a merits-based dismissal (for failure to state a claim) rather than a jurisdictional one and affirmed the judgment as modified. View "Shiba v Mullin" on Justia Law

Lincoln v. Bisignano

2026-04-23T06:31:15-08:00

Michael Lincoln applied for disability insurance benefits and supplemental security income, alleging that his ability to work was limited due to conditions including prostate cancer, for which he received treatment beginning in late 2019. His treatment concluded in mid-2020, and his cancer entered remission. Lincoln continued to experience symptoms such as fatigue and reported using a cane at times, but also engaged in various daily activities. He claimed an inability to work beginning in October 2019. An administrative law judge (ALJ) held a hearing in May 2022 and, in August 2022, concluded that Lincoln was not disabled. The ALJ determined that Lincoln had the residual functional capacity to perform “light work” with certain postural limitations, and specifically found that Lincoln could perform his past work as a school bus driver. In reaching this conclusion, the ALJ found that Lincoln’s subjective complaints regarding fatigue and cane use were not entirely consistent with the medical evidence and daily activities. The ALJ also found the opinions of state agency medical consultants more persuasive than that of Lincoln’s treating nurse practitioner. The Appeals Council denied further review, making the ALJ’s decision final. The United States District Court for the Central District of Illinois affirmed the ALJ’s decision. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the ALJ’s findings, applying a deferential “substantial evidence” standard. The court held that substantial evidence supported the ALJ’s determination regarding Lincoln’s residual functional capacity, including the findings related to Lincoln’s fatigue, cane use, and the persuasiveness of medical opinions. Accordingly, the court affirmed the judgment of the district court, upholding the denial of benefits. View "Lincoln v. Bisignano" on Justia Law

Lewis v Indiana Department of Transportation

2026-04-22T21:03:36-08:00

Keisha Lewis worked for the Indiana Department of Transportation, handling federal relocation claim vouchers for those displaced by highway projects. After receiving a remote-work accommodation due to a kidney condition, Lewis began experiencing conflicts with her supervisors over her work responsibilities, performance, and compliance with job duties. Issues escalated when she refused to process certain vouchers and failed to comply with supervisor instructions, resulting in a backlog of over 400 parcels. Despite being warned that failure to perform her job duties would be considered insubordination, Lewis continued to dispute her work obligations and was eventually terminated for poor performance and insubordination. After her dismissal, Lewis filed suit against the Department and two supervisors, asserting claims of disability discrimination and retaliation under the Rehabilitation Act, as well as race discrimination and retaliation under Title VII and 42 U.S.C. § 1981. Some claims were voluntarily dismissed, and the United States District Court for the Southern District of Indiana granted summary judgment for the defendants on the remaining claims, concluding that no reasonable jury could find in Lewis’s favor. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s summary judgment ruling de novo. The appellate court held that the Rehabilitation Act requires plaintiffs to show that disability was the sole cause of an adverse employment action, a standard Lewis did not meet. The court further found no evidence of pretext or retaliatory intent in her termination, and that her race discrimination and retaliation claims failed due to lack of supporting evidence and waiver of arguments. The Seventh Circuit affirmed the district court’s grant of summary judgment for the defendants. View "Lewis v Indiana Department of Transportation" on Justia Law

Hyatt Hotels Corporation & Subsidiaries v. CIR

2026-04-22T08:00:41-08:00

Hyatt Hotels Corporation managed a loyalty program for guests, which was funded by contributions from both Hyatt-owned and third-party-owned Hyatt-branded hotels. These contributions, along with income from direct sales of points and investment returns, were held in a centralized fund managed by Hyatt. When members redeemed points, funds were used to compensate hotels and pay for program-related expenses. The Internal Revenue Service (IRS) asserted that income flowing into this fund from third-party sources, direct sales, and investments should be treated as Hyatt’s income for tax purposes. The United States Tax Court reviewed the IRS’s notice of deficiency and Hyatt’s petition challenging it. Hyatt argued that the fund’s income was not its own under the claim of right and trust fund doctrines, and, alternatively, that if it was, Hyatt should be allowed to use the trading stamp method of accounting to offset the income with estimated costs. The Tax Court rejected both arguments, holding that Hyatt’s benefit from the fund made the income taxable to Hyatt and that the trading stamp method was unavailable because the rewards were not tangible property. On appeal, the United States Court of Appeals for the Seventh Circuit found that the Tax Court’s analysis was incomplete. Specifically, the appellate court held that the Tax Court erred by failing to consider whether the claim of right doctrine provided an independent basis for excluding the fund’s income from Hyatt’s taxable income. The Seventh Circuit clarified that the claim of right doctrine is broader than the trust fund doctrine and may permit exclusion even when the trust fund doctrine does not apply. The court vacated the Tax Court’s decision and remanded the case for further proceedings to determine whether the fund’s income was Hyatt’s under the claim of right doctrine. View "Hyatt Hotels Corporation & Subsidiaries v. CIR" on Justia Law

Wisconsinites for Alternatives to Smoking v. Casey

2026-04-21T21:02:54-08:00

A Wisconsin statute enacted in 2023 required that electronic nicotine delivery systems (such as vapes and e-cigarettes) could only be sold in the state if they had received premarket authorization from the Food and Drug Administration (FDA), were pending FDA review as of specified dates, or did not contain nicotine. The law also imposed financial penalties and authorized private lawsuits against violators. Several businesses and consumers involved in the manufacture, distribution, retail, and use of these products challenged the statute, arguing that federal law granting the FDA authority over tobacco products preempted the Wisconsin statute. They also asserted that the law violated the Equal Protection Clause, and sought preliminary and permanent injunctions to prevent enforcement. The United States District Court for the Western District of Wisconsin denied the motion for a preliminary injunction. The district court found that the Wisconsin law was not preempted by federal statutes, specifically the Federal Food, Drug, and Cosmetic Act (FDCA) and the Family Smoking Prevention and Tobacco Control Act (TCA). The court concluded that Congress had not intended to preempt states from imposing additional or more stringent requirements on the sale of tobacco products, and that the plaintiffs had not shown a likelihood of success on the merits or that the balance of equities favored an injunction. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision. The Seventh Circuit held that the text and structure of the relevant federal statutes, including the TCA’s preservation and savings clauses, demonstrated that Congress did not preempt state authority to regulate, or even prohibit, the sale of tobacco products. The court affirmed the district court’s denial of a preliminary injunction, holding that the plaintiffs had failed to show a reasonable likelihood of success on the merits of their preemption claim. View "Wisconsinites for Alternatives to Smoking v. Casey" on Justia Law

Smiley v. Jenner

2026-04-21T07:30:40-08:00

A teacher in Indiana, who was preparing to begin teaching grades 1–3, filed a lawsuit challenging a new state statute that prohibits public schools and teachers from providing “instruction” on “human sexuality” to students in prekindergarten through third grade. While the law allows teachers to answer students’ questions and to teach academic subjects and child abuse prevention, it does not define the key terms “instruction” or “human sexuality.” The teacher argued that the statute would chill or restrict her protected speech, such as including certain books in her classroom library, displaying pro-LGBTQ+ stickers, and addressing students’ use of pejorative language related to sexual identity. She also claimed the law is unconstitutionally vague, fearing she might inadvertently violate it and risk losing her teaching license. The United States District Court for the Southern District of Indiana denied her request for a preliminary injunction. The district court concluded that the teacher had not shown a likelihood of success on the merits of her First Amendment and Fourteenth Amendment claims. The court reasoned that most of the speech affected by the statute—classroom instruction and related communications—was official speech not protected by the First Amendment, and that any protected speech affected was not substantial enough to make the law overbroad. It also found that the terms “instruction” and “human sexuality” had a discernible core of meaning, so the law was not unconstitutionally vague. 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 the teacher had not demonstrated that the statute prohibits a substantial amount of protected speech or is impermissibly vague. The court concluded that any ambiguity at the margins does not render the statute facially invalid and emphasized that challenges to specific applications of the law could be brought in the future if necessary. View "Smiley v. Jenner" on Justia Law

Carter v SP Plus Corp.

2026-04-15T13:30:42-08:00

Rashaan Carter brought a lawsuit against SP Plus Corporation, his employer, alleging violations of state and federal minimum wage laws. During Carter’s onboarding, the employer claimed that he had agreed to arbitrate all claims by electronically checking a box and providing an electronic signature. However, Carter later submitted an affidavit stating that an employee from SP Plus’s human resources staff completed and signed the forms on his behalf, without explaining the documents or allowing Carter to view or decline them. The United States District Court for the Northern District of Illinois initially granted SP Plus's motion to stay the litigation in favor of arbitration, relying on the onboarding records. After Carter presented his affidavit challenging the validity of his assent to arbitration, the district judge reconsidered, lifted the stay, and denied SP Plus’s motion. The district court explained that, based on the record, it could not find that a valid arbitration agreement had been formed. The judge also noted that neither party had been given the required notice or an opportunity for a hearing to determine whether Carter had personally agreed to arbitration. SP Plus appealed to the United States Court of Appeals for the Seventh Circuit, arguing that the order was appealable and that the district court should have compelled arbitration. The Seventh Circuit held that, because SP Plus failed to request an evidentiary hearing or present evidence to dispute Carter’s affidavit in the district court, it forfeited any right to such a hearing. The appellate court further concluded that the district court’s order was a final denial of the request to compel arbitration and found no clear error in the district court’s determination that Carter did not agree to arbitrate. The Seventh Circuit affirmed the district court’s order. View "Carter v SP Plus Corp." on Justia Law

United States v Andrews

2026-04-15T12:00:41-08:00

Law enforcement suspected the defendant of supplying drugs to a gang in Illinois and, after conducting several controlled purchases, arrested him. During his arrest, officers found multiple small bags of drugs in his possession. A search of an apartment he shared with family members revealed additional drugs, items associated with drug trafficking, and four firearms. While in custody, the defendant made a recorded call to his parents referencing the firearms found in the apartment. He was indicted on seven counts, including distribution of controlled substances and possession of a firearm in furtherance of a drug trafficking crime. He pleaded guilty to the distribution counts and went to trial on the remaining counts. The United States District Court for the Northern District of Illinois, Eastern Division, presided over the trial. The government called a fingerprint analyst who testified that two of the firearms bore fingerprints matching the defendant’s. The defense challenged the analyst’s methodology but was permitted to present its own expert, despite late disclosure. The jury found the defendant guilty on both remaining counts, concluding he possessed all four firearms. The district court denied the defendant’s post-trial motions for acquittal and a new trial, and sentenced him to 123 months in prison. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether there was sufficient evidence to support the firearm conviction and whether the district court erred in admitting the expert fingerprint testimony. The appellate court held that the evidence—including the recorded phone call and fingerprint analysis—was sufficient for a rational jury to find constructive possession of the firearms. The court also concluded the district court properly applied Rule 702 and Daubert in admitting the expert testimony. The judgment of the district court was affirmed. View "United States v Andrews" on Justia Law

Doe v. Sloan

2026-04-14T12:00:42-08:00

Law enforcement in Toulon, Illinois investigated a collection of sexually explicit images of underage girls discovered in an online file-sharing service. The Sheriff assigned the case to a deputy, who involved Jason Musselman, an auxiliary police officer and IT specialist, to help identify the victims. Musselman, though not formally trained for such investigations, was given access to the images. While he assisted with identifications, he also kept the images for personal use without the knowledge of other officers. Years later, Musselman was investigated and convicted on separate child pornography charges, and authorities discovered he had retained the images from the original investigation. The victims brought civil actions against Musselman and separately sued two local police officers, the Sheriff, the City, and the County. Their claims included state law torts and, relevant here, claims under 42 U.S.C. § 1983, alleging that the officers violated their substantive due process rights under the Fourteenth Amendment by allowing Musselman access to the images. The United States District Court for the Central District of Illinois dismissed the § 1983 claims, finding that the plaintiffs failed to allege the violation of a recognized constitutional right, and that any such right was not clearly established for the purposes of qualified immunity. The court dismissed some related state law claims but allowed others to proceed. On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The Seventh Circuit held that the plaintiffs did not allege a violation of a fundamental right protected by substantive due process. The court declined to recognize a new constitutional right in these circumstances, emphasizing that the Due Process Clause does not cover every wrong committed by a state actor. The dismissal of the § 1983 claims was affirmed. View "Doe v. Sloan" on Justia Law

Petrov v Blanche

2026-04-14T07:30:43-08:00

A stateless individual born in Germany entered the United States illegally as a child and lived in the country for decades, marrying a U.S. citizen and raising three children who are also U.S. citizens. After his application for asylum was denied, the Department of Homeland Security initiated removal proceedings based on his lack of legal entry. He conceded removability and sought cancellation of removal, asserting that his deportation would cause exceptional and extremely unusual hardship to his qualifying relatives, including his wife, children, and father, all U.S. citizens. During removal proceedings, he and his wife testified primarily about their financial dependence on him, their close-knit family, and concerns about discrimination against gypsies in Europe. An Immigration Judge denied his application, finding insufficient evidence to meet the hardship standard. The Board of Immigration Appeals affirmed the decision, largely adopting the Immigration Judge’s reasoning. Later, the petitioner moved to reopen the proceedings, presenting new evidence about his wife’s mental health diagnoses, a past miscarriage, family members’ medical conditions, and reports of discrimination and poor economic conditions in Germany. The Board denied this motion, concluding that much of the new evidence could have been previously presented and that, even considered collectively, the evidence did not establish prima facie eligibility for cancellation of removal. The United States Court of Appeals for the Seventh Circuit reviewed both the denial of cancellation of removal and the denial of the motion to reopen. The court held that the agency’s determination that the petitioner failed to show exceptional and extremely unusual hardship was supported under either clear error or substantial evidence review. The court further held that the Board did not abuse its discretion in denying the motion to reopen. The petitions for review were accordingly denied. View "Petrov v Blanche" on Justia Law

Doe v University of Southern Indiana

2026-04-13T12:33:57-08:00

A former student at the University of Southern Indiana was accused of sexual assault during the 2020–21 academic year. After a hearing, a university panel found the alleged victim’s account more credible than the student’s, noting her consistency over time, and concluded that the student committed rape and forcible fondling. The student was suspended for three semesters and did not return to the university. He subsequently filed a lawsuit against the university and other defendants, alleging sex discrimination in violation of Title IX, deprivation of due process, and intentional infliction of emotional distress. During discovery, the student learned of undisclosed records that suggested his account may have been consistent over time, contrary to the panel’s finding. The United States District Court for the Southern District of Indiana granted summary judgment to the defendants on all claims. In the course of the litigation, a magistrate judge ordered the student to proceed using his real name, not a pseudonym. The student objected, but the district judge overruled the objection, though the district court stayed its order pending this appeal. The student filed multiple appeals, which were consolidated for argument. The United States Court of Appeals for the Seventh Circuit reviewed whether the district court abused its discretion by denying the student’s use of a pseudonym. The court reaffirmed the strong presumption that adult parties litigate under their real names in federal court and found that the student did not present sufficient evidence of a substantial risk of physical harm or retaliation to justify use of a pseudonym. The court declined to broaden the standard to include mental health risks or to consider the merits of the underlying claims in deciding the pseudonym issue. The Seventh Circuit affirmed the district court’s order. View "Doe v University of Southern Indiana" on Justia Law

Mahajni v Do

2026-04-13T12:33:56-08:00

In this case, the plaintiff alleged that his constitutional rights were violated during his state criminal trial when two deputies, assigned as bailiffs, interacted with the jury during deliberations. According to the complaint, one deputy responded to a juror’s question by telling the jury that they must reach a unanimous verdict and that a hung jury was not an option. The second deputy was present but did not intervene or report the communication to the trial judge. The episode was later found to have influenced the jury, leading to the plaintiff’s conviction. After an evidentiary hearing in state court, the convictions were vacated and charges dismissed. The plaintiff then brought a civil suit in the United States District Court for the Eastern District of Wisconsin against the deputies and others, asserting violations of his constitutional rights and various state law claims. The deputies asserted qualified immunity as a defense and moved for judgment on the pleadings. The district court denied qualified immunity to the deputy who spoke to the jury, finding the law clearly established. However, as to the other deputy—who had not spoken but allegedly failed to intervene—the district court denied qualified immunity “without prejudice,” explaining that neither party had properly briefed the issue regarding his specific actions and invited a renewed argument at summary judgment. The United States Court of Appeals for the Seventh Circuit reviewed the interlocutory appeal filed by the deputy who had not spoken to the jury. The court held that because the district court had not made a final or substantive ruling on the qualified immunity issue as it pertained to this deputy, there was no appealable decision under the collateral order doctrine. As a result, the Seventh Circuit dismissed the appeal for lack of jurisdiction. View "Mahajni v Do" on Justia Law

USA v Perry

2026-04-13T07:30:44-08:00

The case concerns a defendant who was indicted for sex trafficking minors and faced serious federal charges. Over the course of three years between his indictment and trial, the defendant was represented by five different court-appointed attorneys. He repeatedly refused to cooperate with his lawyers, frequently submitted pro se motions, and violated court orders prohibiting him from contacting victims and witnesses. Twice, after comprehensive hearings in line with Faretta v. California, the defendant knowingly and voluntarily waived his Sixth Amendment right to counsel and elected to represent himself, despite being warned by the judge that no further attorneys would be appointed if he changed his mind again. Throughout the pretrial proceedings, the United States District Court for the Northern District of Illinois patiently allowed several changes in representation, including the appointment of standby counsel. However, when the defendant again requested an attorney during trial, after previously waiving counsel and being warned that further appointments would not be made, the district judge denied the request. After a jury trial, the defendant was found guilty on all counts, and his posttrial motions—including a challenge to the denial of his midtrial request for counsel—were denied. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether the district judge abused his discretion in denying the midtrial request for a sixth appointed lawyer. The Seventh Circuit held that, after a valid Faretta waiver, district judges may require a defendant to abide by his choice to proceed pro se, especially if the request for counsel is made after trial has begun. The court further held that there is no constitutional requirement to reassess the defendant’s motives or the likely delay caused by such a request under these circumstances. The judgment of the district court was affirmed. View "USA v Perry" on Justia Law

Hewitt v Capital One Bank, N.A.

2026-04-08T10:04:52-08:00

The plaintiffs held individual retirement accounts (IRAs) for which Capital One acted as custodian. Capital One chose to resign as custodian and notified the plaintiffs that, unless they directed otherwise, their IRA funds would be transferred to Inspira Financial Trust (formerly Millennium Trust Company). Plaintiffs did not act to select a different custodian or investment option. After the funds were transferred, Inspira placed them in a “sweeps” account that paid a low annual interest rate—less than Inspira’s management fees. Plaintiffs complained that both Capital One and Inspira breached their contractual duties by causing their funds to earn little or no net return, though they acknowledged Inspira is a reputable institution. In the United States District Court for the Northern District of Illinois, Eastern Division, the judge compelled arbitration of the claims against Inspira due to an arbitration agreement. The court then dismissed the claims against Capital One on the merits under Federal Rule of Civil Procedure 12(b)(6), relying in part on an exculpatory clause in the contract. Plaintiffs appealed the portion of the judgment relating to Capital One, under Rule 54(b). The United States Court of Appeals for the Seventh Circuit reviewed the case. The appellate court held that Capital One did not breach its contractual obligations, even when interpreting the contract as plaintiffs urged. The court found that Capital One’s actions—providing ample notice and allowing plaintiffs to choose their own custodian or investment vehicle—complied with its duties, including any obligations of good faith and fair dealing under applicable state law. The court further noted that plaintiffs were not prevented from learning about or choosing better investment options. The Seventh Circuit affirmed the district court’s dismissal of the claims against Capital One. View "Hewitt v Capital One Bank, N.A." on Justia Law

Walls v Posey

2026-04-06T12:30:43-08:00

William Walls was found by an Illinois state court to be a sexually violent person in 2015, leading to his civil commitment under Illinois law. The commitment was based, in part, on statements he made or that were made by his treatment providers while he was incarcerated for a prior sexual assault conviction. Walls has argued that these statements were obtained in violation of his constitutional rights. After his commitment, his case involved extensive delays, including a twelve-year period before the initial commitment decision and seven years before the state appellate court resolved the appeal filed by his counsel. After the 2015 commitment order, Walls—sometimes proceeding pro se despite being represented—filed a series of appeals and petitions. The Illinois Appellate Court eventually affirmed both the 2015 and a subsequent 2018 recommitment decision in a consolidated opinion. Walls’s first federal habeas petition under 28 U.S.C. §2254 was dismissed by the United States District Court for the Central District of Illinois on procedural default grounds. He did not appeal that dismissal. After the 2018 recommitment proceeding, Walls filed a second federal habeas petition, which was dismissed as an unauthorized successive petition under 28 U.S.C. §2244(b) because it challenged the same 2015 order or did not raise new claims as required. The United States Court of Appeals for the Seventh Circuit reviewed Walls’s appeal of the district court’s dismissal. The court held that, to the extent Walls was once again contesting the 2015 commitment order, his petition was barred as a successive habeas application. Alternatively, if he was challenging later decisions, he had failed to raise or exhaust federal claims relating to those decisions. The Seventh Circuit affirmed the district court’s dismissal of Walls’s petition. View "Walls v Posey" on Justia Law

Velazquez-Olais v Blanche

2026-04-06T12:30:42-08:00

An individual entered the United States without authorization prior to 2018. After she was convicted in Illinois state court for possessing cocaine with intent to deliver, federal immigration authorities issued a Final Administrative Removal Order (FARO) against her under expedited procedures, and she was removed to Mexico in August 2018. Subsequently, she reentered the United States without authorization. She later obtained an amendment of her state conviction to simple possession, arguing the original charge overstated her conduct. Relying on this development, she requested that the Department of Homeland Security (DHS) reopen and cancel her prior removal order. A Deportation Officer in the Chicago Field Office responded by email, stating the office would not revisit the 2018 order. After the Deportation Officer declined to act, the individual petitioned the United States Court of Appeals for the Seventh Circuit to review the decision under 8 U.S.C. §1252(a). She characterized the email as a reviewable final order of removal. Meanwhile, DHS had not reinstated the 2018 removal order but had instead initiated new removal proceedings by issuing a Notice to Appear, beginning a new immigration process. The United States Court of Appeals for the Seventh Circuit held that it lacked jurisdiction to review the petition because the email from the field office was not a “final order of removal” as defined by statute or relevant precedent. The court explained that the 2018 removal order was already executed and had not been reinstated, and that the petitioner was now subject to new removal proceedings. Because there was no reviewable order before it, the court dismissed the petition for review. View "Velazquez-Olais v Blanche" on Justia Law

Polk v Progressive Northern Insurance Company

2026-04-02T13:30:43-08:00

Thomas T.D. Polk and his wife, Katarzyna Kurek-Polk, were struck by a vehicle while assisting another motorist, resulting in serious injury to Thomas and Katarzyna’s death. They recovered $100,000 from the at-fault driver’s insurance and sought additional compensation under three separate underinsured motorist (UIM) policies: $1,000,000 from AMCO Insurance Company, $500,000 from Progressive Northern Insurance Company, and $500,000 from Secura Supreme Insurance Company. Each policy included a proportionate liability clause and an “Other Insurance” anti-stacking provision, which limited the total UIM recovery to the highest coverage available under a single policy. After receiving $800,000 from the AMCO policy and rejecting a $220,000 offer from Secura, Polk filed a breach of contract suit against Secura and Progressive in the United States District Court for the Northern District of Illinois. The district court granted summary judgment in favor of the insurers. It held that the anti-stacking provisions were unambiguous and limited Polk’s maximum recovery to $1,000,000—the highest limit among the policies—regardless of the number of insureds or policies. Since Polk had already received $900,000 from the tortfeasor and AMCO, the court ordered Secura to pay $100,000 to bring the total to $1,000,000, and ruled that Progressive owed nothing. On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. It held that the anti-stacking provisions in both the Progressive and Secura policies were clear and enforceable under Illinois law, and that the insurers’ liabilities were properly offset by the amounts already received, thus capping total recovery at $1,000,000. The court also rejected Polk’s arguments regarding policy ambiguity and statutory interpretation. View "Polk v Progressive Northern Insurance Company" on Justia Law