Justia Constitutional Law Opinion Summaries

Plaintiff was arrested for an alleged sexual assault, which allegation turned out to be false. Plaintiff brought this lawsuit against Defendants, Polk County and a Polk County investigator, advancing claims under 42 U.S.C. 1983 for false arrest and false imprisonment, and state common law claims for false imprisonment, malicious prosecution, negligence, and defamation. The district court granted summary judgment in favor of Defendants, concluding that the investigator had arguable probable cause to effect Plaintiff’s arrest and was entitled to qualified immunity and that Polk County could not be held liable under Monell v. Dep’t of Soc. Servs. The court declined to assert supplemental jurisdiction over Plaintiff’s state law claims and dismissed them without prejudice. The Seventh Circuit affirmed, holding (1) the investigator was entitled to qualified immunity because she reasonably believed probable cause existed to arrest Plaintiff; (2) there was no dispute as to any material fact with regard to Plaintiff’s Monell claims; (3) the district court did not abuse its discretion in dismissing without prejudice Plaintiff’s state law claims; and (4) the district court did not abuse its discretion in denying Plaintiff’s motion to alter or amend the judgment. View "Burritt v. Ditlefsen" on Justia Law

Backpage.com provides an online forum for classified ads and includes an “adult section.” The Sheriff of Cook County initiated a campaign to extinguish Backpage’s adult section - and, by extension, all of Backpage - by demanding that credit card companies prohibit the use of their credit cards to purchase any ads on Backpage since the ads might be for illegal sex-related services or products. Backpage sought a preliminary injunction to stop the sheriff’s actions, arguing that the sheriff was violating the First Amendment by curtailing freedom of expression. The district judge denied the motion for a preliminary injunction. The Seventh Circuit reversed, holding that the sheriff, in his capacity as a public official, violated the First Amendment by issuing and publicizing threats against credit card companies that process payments made through Backpage’s website, including threats of prosecution, in an effort to shut down Backpage. View "Backpage.com, LLC v. Dart" on Justia Law

An Illinois state trooper stopped a car that had been speeding. The subsequent search of the car revealed 1.5 kilograms of cocaine, which the police seized. Defendant, who was one of two passengers in the car, was prosecuted in federal court for possessing and intending to sell the cocaine found in the car. Defendant filed a motion to suppress the cocaine evidence. The district judge denied the motion, concluding (1) as a passenger in the car, Defendant had no standing to challenge the search; and (2) even if Defendant had standing, the delay did not make the search unlawful. Defendant subsequently entered a conditional plea of guilty to the charges. The Seventh Circuit affirmed in part, reversed in part, and remanded, holding (1) Defendant’s conviction was proper; but (2) the district court erred in imposing certain conditions of supervised release as part of Defendant’s sentence. View "United States v. Sanford" on Justia Law

After a jury trial in an Illinois state court, Appellant was found guilty of murdering his girlfriend’s one-year-old daughter. After exhausting his state appeals, Appellant filed a federal habeas petition, claiming, inter alia, that the forty-two-month delay in bringing his case to trial violated his Sixth Amendment right to a speedy trial. The district court denied the habeas petition. On direct appeal, the Illinois Appellate Court concluded that the pretrial delay was presumptively prejudicial but that the delay was attributable to continuances requested by Appellant’s counsel and did not impair the defense. The Seventh Circuit affirmed, holding that the Illinois court’s decision was not an unreasonable application of federal law, and therefore, habeas relief was unwarranted. View "O'Quinn v. Spiller" on Justia Law

Plaintiff, an employee of Costco Wholesale Corporation, made two requests for a medical leave under the FMLA. Costco granted both requests. During that time, Plaintiff was demoted from optical manager to cashier. Plaintiff filed this lawsuit against Costco and Gail Hinds, his supervisor, alleging retaliation and interference, both in violation of the FMLA, and discrimination based upon a disability and failure to accommodate, both in violation of the Americans with Disabilities Act. The district court granted summary judgment for Defendants on all of Plaintiff’s causes of action. The Seventh Circuit affirmed, holding that the district court (1) did not abuse its discretion in finding that Plaintiff failed to comply with the requirements of the Northern District of Illinois Local Rule 56.1; (2) properly granted summary judgment in favor of Defendants on Plaintiff’s FLMA retaliation and interference claims; and (3) properly granted summary judgment in favor of Defendants on Plaintiff’s reasonable accommodation claim. Lastly, Plaintiff waived any arguments with regard to disparate treatment. View "Curtis v. Costco Wholesale Corp." on Justia Law

Pursuant to a plea agreement, Defendant entered a plea of guilty to a drug conspiracy charge. The plea agreement contained a waiver of Defendant’s right to collaterally attack his conviction or sentence. The district judge did not expressly discuss the collateral-attack waiver with Coleman at the guilty-plea hearing. At sentencing, the district court imposed a term of supervised release that included “standard conditions.” The Seventh Circuit (1) affirmed the conviction, holding that the plea colloquy did not comply with Fed. R. Crim. P. 11 with respect to the collateral-attack waiver, but the omission did not affect Defendant’s substantial rights; and (2) remanded for resentencing, as certain conditions of supervised release imposed on Defendant were impermissibly vague. View "United States v. Coleman" on Justia Law

Anthony Zimmerman, the president and owner of Premier Forest Products Products, Inc. (together, Plaintiffs), was hired to harvest trees on certain property. When the landowner discovered that Zimmerman had been harvesting trees without regard to fence lines and had taken more trees than he was supposed to, the landowner warned Zimmerman to leave the property. When Zimmerman refused to do so, the landowner sought help from the Carroll County Sheriff’s Office. The sheriff’s office arrested Zimmerman for criminal trespass. Plaintiffs sued the sheriff’s office and its sheriff, deputy, chief deputy, and detective (collectively, Defendants), alleging that Defendants violated his constitutional rights in arresting him for criminal trespass. The district court granted summary judgment for Defendants, concluding that Defendants had probable cause to arrest Defendant and, alternatively, that Defendants were entitled to qualified immunity. The Seventh Circuit affirmed, holding that Zimmerman failed to establish that probable cause was lacking under the circumstances presented in this case or that Defendants engaged in arbitrary conduct unjustifiable by any government interest. View "Zimmerman v. Doran" on Justia Law

Sixteen days after Defendant, a dentist, learned Plaintiff, an inmate of Illinois’s Stateville prison, was complaining of a tooth abscess, Defendant diagnosed an abscessed molar, prescribed penicillin to bring the infection under control, and extracted the molar. Plaintiff sued the dentist and a prison guard (together, Defendants), charging them with deliberate indifference to his abscess. The district judge granted summary judgment in favor of Defendants. The Seventh Circuit reversed, holding that the evidence of deliberate indifference by Defendants to Plaintiff’s serious medical need precluded granting summary judgment in their favor. Remanded. View "Dobbey v. Mitchell-Lawshea" on Justia Law

In 2008, defendant Jason Austin was the leader of a street-level, retail drug-trafficking operation. Austin received drugs from suppliers and sold the drugs to users, with the help of many others. Money was passed up a chain of “managers” or “bundle runners,” who in exchange distributed drugs to “pack workers” for sales. Drug proceeds were then finally passed from the managers up to Austin. Off-duty Chicago Police Detective Robert Soto and Kathryn Romberg were shot and killed while sitting in Soto’s car on the west side of Chicago. The investigation into their murders focused on Austin and his operation. The murder case against Austin was ultimately dismissed. The Federal Bureau of Investigation and Chicago Police Department then began what became a two-year investigation into Austin and his operation. The investigation included numerous undercover drug purchases, extensive surveillance, and interviews with informants and coconspirators. At the end of the investigation in November 2010, over 100 people were arrested. Austin was indicted on federal charges relating to his role in the drug-trafficking conspiracy, particularly for his participation from January 2008 through June 2010. A jury found Austin guilty of five counts of drug distribution and one count of conspiracy to distribute, but only for an amount of less than 100 grams of heroin. He appealed only his sentence, challenging the quantity of drugs attributable to him and the court’s finding that he played a leading role in the organization. In particular, he argued that a key witness has been so thoroughly discredited by alleged misstatements and contradictions that it was error for the court to credit his testimony at least in part. After review, the Seventh Circuit disagreed, and affirmed Austin’s sentence. View "United States v. Austin" on Justia Law

On July 5, 2013, the Governor of Wisconsin signed into a law a statute that the Wisconsin legislature had passed one month earlier prohibiting a doctor from performing an abortion unless he or she has admitting privileges at a hospital no more than thirty miles from the clinic in which the abortion is performed. Planned Parenthood of Wisconsin and Milwaukee Women’s Medical Services (which operate the only four abortion clinics in Wisconsin) joined by two doctors employed by Planned Parenthood, challenged the statute’s constitutionality under 42 U.S.C. 1983, first seeking and obtaining a preliminary injunction and ultimately seeking a permanent injunction against enforcement of the statute. After a trial, the trial judge granted a permanent injunction against enforcement of the statute. The Seventh Circuit affirmed, holding (1) Plaintiffs had standing to sue; and (2) the statute is unconstitutional because it imposes a burden excessive in relation to the aims of the statute and the benefits likely to be conferred by it. View "Planned Parenthood of Wisconsin, Inc. v. Schimel" on Justia Law