Justia Constitutional Law Opinion Summaries

While proceeding to the Stateville prison cafeteria, Navejar spoke to other inmates in their cells. Officer Iyiola ordered him to get out of the line because prison rules forbid inmates from stopping to speak to other inmates. Navejar disobeyed, became belligerent, and punched Iyiola. Other guards wrestled Navejar to the ground where he was handcuffed. Navejar claims that guards kicked him in the forehead, stomped his head against the ground, pepper-sprayed him, dragged him along the floor, and left him alone for a half-hour, while he screamed in pain, before he was allowed to wash off the pepper spray. The next morning a guard brought Navejar to Stateville’s health care unit, where nurses examined him. Before a doctor could provide attention, a guard escorted Navejar out, explaining that he was being transferred to Pontiac. At Pontiac, Navejar was examined by a physician, who concluded that he had suffered only bruises and scratches. In Navejar’s suit under 42 U.S.C. 1983, the district court denied motions to recruit counsel and entered summary judgment for the guards on Eighth Amendment claims. The Seventh Circuit reversed, finding that the court applied the wrong legal standard to Navejar’s motion and that lack of counsel prejudiced him. View "Navejar v. Iyiola" on Justia Law

Earl was convicted of intentional homicide, jailed, and placed for five days onto “suicide watch” segregation where he was dressed in a “suicide-proof gown,” kept in continuous light for 24 hours, and constantly monitored. The jail says that suicide watch is required of every inmate convicted of a serious felony until he is examined by a mental-health expert. Earl claims that he was placed on suicide watch as punishment after an officer relayed false information that he had threatened other guards. Earl claimed an allergic reaction to the special gown and received medical attention. After a mental-health worker recommended that Earl be discharged from suicide watch, Earl was placed for 12 days in administrative segregation, apparently as punishment for initially refusing to wear the suicide gown, and afterwards was transferred to a Wisconsin state prison. Two years later Earl returned to the jail for a court appearance and again was housed in segregation. In his suit (42 U.S.C. 1983) the district court granted the defendants summary judgment, finding that Earl’s placement in segregation was too short to deprive him of a liberty interest and that conditions were not “unusually harsh.” Earl did not show delay in responding to his claim of allergic reaction. The Seventh Circuit affirmed. View "Earl v. Racine Cnty. Jail" on Justia Law

Ramos was arrested in 2007 and charged with residential burglary. After an Illinois state court acquitted him of that charge, he brought an action under 42 U.S.C. 1983, alleging that Chicago and five police officers violated his constitutional rights under the Fourth and Fourteenth Amendments in conducting a false arrest and malicious prosecution, and also asserting state law claims for malicious prosecution and indemnification. The district court granted summary judgment in favor of the defendants on the section 1983 claims and declined to exercise supplemental jurisdiction over Ramos’ state law claims. The Seventh Circuit affirmed. Based on a report of a burglary and a description of the suspect, the officers had reasonable suspicion that criminal activity was ongoing, sufficient to justify a “Terry” stop. Ramos’ failure to produce a valid driver’s license provided probable cause for his arrest. View "Ramos v. City of Chicago" on Justia Law

Federal agents and local police executed a search warrant at Williams’ residence and found five kilograms of marijuana, a handgun, and several scales. Williams moved to suppress, arguing that the warrant was invalid because officers presented the warrant judge with an affidavit that contained false statements and misleading omissions made with at least reckless disregard for the truth. The district court held a Franks hearing and found that the officers did not recklessly disregard the truth, and that even if they had, once the errors were removed and the omitted material included, probable cause would have remained for a search warrant to issue. Williams was convicted of being an illegal alien in possession of a firearm, 18 U.S.C. 922(g)(5). The Seventh Circuit affirmed, stating that the police were rushing to draft an application and hastily omitted both favorable and unfavorable evidence from the affidavit. The court particularly noted omission of the information from monitored calls involving Williams that was “clearly sufficient to establish probable cause.” That omission provides a reasonable basis to believe that the police did not intend to mislead. View "United States v. Williams" on Justia Law

Under Illinois law, a candidate for the state legislature seeking placement on the general election ballot without having participated in a primary (or having replaced a candidate who did) must submit a nominating petition signed by a certain number of eligible voters. In July 2012, the Chicago Board of Election Commissioners determined that five Republican candidates for the state legislature had not collected the requisite numbers of signatures and denied their petitions to be listed on the ballot in the 2012 general election. In September the candidates and supporters sought injunctive and declaratory relief, alleging that the statutory scheme violated their constitutional rights to free speech and association under the First and Fourteenth Amendments. The district court dismissed, holding that the doctrine of laches barred their claims. The Seventh Circuit affirmed, after holding that laches does not apply because the delay in filing suit did not impact the Board’’ ability to fashion prospective relief in future elections. The requirement that candidates seeking ballot access submit nominating petitions is reasonable and nondiscriminatory, and serves the important regulatory interests of protecting the integrity of elections from frivolous candidates and preventing voter confusion; it does not unconstitutionally burden the candidates’ and voters’ expressive and associational rights. View "Navarro v. Neal" on Justia Law

From 1996 to 2003, Harbaugh worked periodically for Chicago Public Schools as a substitute music teacher. In 2003, she was hired as a “full-time basis substitute,” and tin 2004 she was appointed to a fulltime probationary tenure-track teaching position. In 2008, the principal at Harbaugh’s school recommended against renewing her contract. The Chicago Board of Education accepted that recommendation and terminated her appointment effective at the end of the semester. Harbaugh sued, alleging violation of her due-process rights by terminating her employment without a hearing. The district court entered summary judgment for the Board. The Seventh Circuit affirmed. Under Illinois law Harbaugh had a constitutionally protected property interest in continued employment only if she had tenure; a teacher becomes tenured at the beginning of her fifth year of full-time employment on the tenure track. Her year as a full-time-basis substitute teacher does not count toward the four-year requirement. View "Harbaugh v. Bd. of Educ. of the City of Chicago" on Justia Law

In 1996, Brown was convicted of possession with intent to distribute cocaine base and possession of a firearm by a felon. The district court classified Brown as a “career offender” under U.S.S.G. 4B1.1. Brown filed a 28 U.S.C. 2255 motion arguing that “counsel was ineffective for failure to object to his sentencing as a career offender which resulted in his sentence being a minimum of 360 months instead of between 262 and 327 months.” The district court rejected this argument. The Third Circuit denied a certificate of appealability. Now incarcerated in Indiana, Brown filed a pro se habeas petition under 28 U.S.C. 2241, contending that under the Supreme Court’s 2008 decision, Begay v. U.S., his Delaware conviction for Arson in the Third Degree did not qualify as a crime of violence under U.S.S.G. 4B1.1. The district court dismissed, reasoning that the savings clause in 2255(e) requires a claim of actual innocence directed to the conviction, not merely the sentence. The Seventh Circuit reversed, holding that challenges to a sentence are not categorically barred under 28 U.S.C. 2241. Under Begay, Brown’s prior conviction does not qualify as “generic” arson under the Guidelines’ enumerated crimes clause, nor is it covered by the residual clause. View "Brown v. Lockett" on Justia Law

Loera was a passenger in a car stopped for traffic violations. The driver consented to a search and the police found cocaine. Arrested, Loera was read his Miranda rights and refused to sign a waiver. Loera stated that he knew nothing about the cocaine; he had been asked to deliver the car. He offered to assist in apprehending intended recipients of the drugs. On his attorney’s motion, the judge suppressed statements made after a request for counsel, but did not suppress all post-arrest statements, nor rule that Loera had actually requested a lawyer. The court dismissed without prejudice, for violation of the Speedy Trial Act, 18 U.S.C. 3162(a)(2). After reindictment, Loera's attorney moved to suppress all the statements made after his arrest. The court ruled that Loera had never asked for a lawyer. Loera was convicted. The Seventh Circuit affirmed. Loera then moved to aside his conviction, arguing that his lawyer was ineffective, 28 U.S.C. 2255, for failing to argue that the first ruling on suppression should be binding at trial and for failing to argue that the delay violated both the Speedy Trial Act and the speedy trial clause of the Sixth Amendment, so that dismissal should have been with prejudice. The Seventh Circuit affirmed. View "Loera v. Unted States" on Justia Law

Tucker was found guilty of conspiracy to distribute more than one kilogram of heroin, 21 U.S.C. 841 (a)(1) and (b)(1)(A), the use of which resulted in death, and sentenced to 480 months’ imprisonment. During the trial, the prosecutor made references to the devastating effects of heroin and to possible its impacts on members of the jury, the criminal backgrounds of Tucker’s coconspirators, the plea agreements made by coconspirators “with the judge,” and the consistency of statements by coconspirators outside trial. Tucker’s trial counsel did not object to these statements. The jury also heard from the lead investigator on the case, Officer Baranek, describing how his investigation of Tucker unfolded. The Seventh Circuit affirmed, rejecting a claim of prosecutorial misconduct and a challenge to the use of Officer Baranek as a “dual capacity” witness, without giving the jury any guidance on how to properly evaluate such testimony. A “dual capacity” witness weaves fact and expert opinion testimony together and the prosecutor did lay a foundation for Officer Baranek’s expertise. View "United States v. Tucker" on Justia Law

Kamlager was convicted of first-degree intentional homicide and use of a dangerous weapon in the death of his girlfriend, Wis. Stat. 940.01(1)(a), and was sentenced to life imprisonment with no possibility for extended supervision. He was also convicted of hiding a corpse and was sentenced to five years’ imprisonment. After exhausting postconviction remedies, Kamlager sought collateral relief under 28 U.S.C. 2254. The district court denied his writ of habeas corpus petition. The Seventh Circuit affirmed, characterizing as “harmless error” the admission of statements Kamlager made to officers after he requested to see counsel. Given the “overwhelming” evidence of guilt, it was clear beyond a reasonable doubt that a rational jury would have rendered the same verdict even if the tainted evidence had been suppressed. View "Kamlager v. Pollard" on Justia Law