Justia Constitutional Law Opinion Summaries

Plaintiff, who is black, filed a complaint against the Chicago Transit Authority (CTA) in federal court, alleging that the CTA fired him because of his race in violation of Title VII of the Civil Rights Act of 1964 and 42 U.S.C. 1981. The CTA responded that Plaintiff was fired because he violated CTA’s policy against sexual harassment. The district court granted the CTA’s motion for summary judgment, concluding that Plaintiff’s evidence was insufficient to create a triable issue under either the direct or indirect methods of proving unlawful discrimination. The Seventh Circuit affirmed, holding that Plaintiff’s case failed under both the direct and indirect methods of proof. View "Smith v. Chicago Transit Auth." on Justia Law

ACT, Inc. and The College Board (collectively, Defendants) are national testing agencies that administer the ACT and SAT college entrance exams. When a student applies to take a test, Defendants obtain some of the student’s personally identifiable information (PII). As part of the examination process, some students authorize Defendants to share certain PII with participating educational organizations through an information exchange program. In 2014, a group of former information exchange program participants (collectively, Plaintiffs) filed a putative class action complaint against Defendants, alleging that they were harmed because the testing agencies did not disclose that the students’ PII was actually sold to the educational organizations for profit. The district court dismissed the complaint for lack of subject matter jurisdiction under Fed. R. Civ. P. 12(b)(1), concluding that Plaintiffs failed to establish standing under Article III of the Constitution. The Seventh Circuit affirmed, holding that Plaintiff’s factual allegations failed to establish a plausible claim of Article III standing. View "Silha v. ACT, Inc." on Justia Law

On four occasions, Normal, Illinois, police attached battery‐powered, global‐positioning‐ system devices (GPS) to the Lincoln sedan belonging to Martin, a suspected drug trafficker, in an effort to monitor his movements. The police attached the GPS without seeking a warrant or consulting legal counsel regarding the constitutionality of this investigative technique. The GPS tracking assisted police in identifying locations Martin used for his drug‐trafficking operations, which later led to a search warrant, seizure of evidence, and indictment. Before Martin’s trial, the Supreme Court held that attachment of a GPS to a vehicle and its subsequent use to track a vehicle’s movements constitutes a “search” under the Fourth Amendment. The district court denied Martin’s motion to suppress, finding that Seventh Circuit 2010 precedent permitted warrantless use of the GPS. Martin was later convicted of drug trafficking and sentenced to a mandatory term of life imprisonment under 21 U.S.C. 841(b)(1)(A). The Seventh Circuit affirmed, the exclusionary rule does not apply “when the police conduct a search in objectively reasonable reliance on binding judicial precedent.” View "United States v. Martin" on Justia Law

A building that housed the Café, other restaurants, and 10 apartments burned to the ground. The Cafe’s owner, Rahman, signed a consent form that allowed investigators to look for the “origin and cause” of the fire. Investigators performed a line search looking for a laptop and safe that Rahman told investigators were in the basement, but found neither. Based on the absence of the laptop, the presence of gasoline, and other evidence, investigators settled on arson as the cause of the fire. Rahman was charged with arson and lying to investigators about the location of the laptop. He was acquitted of the arson counts, but convicted of providing false statements to the government. The Seventh Circuit reversed, finding that evidence from the basement line search should have been suppressed as exceeding the scope of Rahman’s consent. The investigators had already ruled out the basement as the origin of the fire when they conducted the search. Their only purpose was to find secondary and circumstantial evidence of arson, which exceeded the scope of Rahman’s consent. The fact that one of Rahman’s computers was found at his home and did not contain business records was not sufficient to find him guilty of the charged false statement. View "United States v. Rahman" on Justia Law

Vinyard pled guilty to conspiracy to manufacture, distribute, and possess methamphetamine with intent to distribute. At sentencing, he started to backtrack on whether he was admitting some of the relevant conduct. After consulting his attorney, he withdrew his objections. His hesitation prompted the district judge (Gilbert) to vacate his plea and sentence on the court’s own initiative, which led to unusual proceedings culminating in a writ of mandamus ordering the court to reinstate Vinyard’s plea and sentence. Vinyard tried to challenge his plea in district court proceedings conducted to comply with the mandate. Judge Stiehl rejected Vinyard’s challenge and reinstated the plea and sentence. Vinyard then could have filed either direct appeal or a collateral attack under 28 U.S.C. 2255. On his attorney’s advice, he chose collateral attack. He later sought reinstatement of his right to direct appeal, arguing that advice caused him to default some claims and amounted to constitutionally ineffective assistance of counsel under Strickland v. Washington. The district court denied relief, concluding that the decision to forgo a direct appeal was strategic and not objectively unreasonable, and that Vinyard could not show prejudice in any event. The Seventh Circuit affirmed, finding that Vinyard proved neither deficient performance nor prejudice. View "Vinyard v. United States" on Justia Law

Chicago Officer Williams received information from a registered informant that an individual whom the informant personally knew was selling narcotics from a gold Toyota Camry with tinted windows near 71st and Paxton. The informant gave the license plate number and the suspect's description. Williams drove to the location, saw Sands in the driver’s seat of a gold Toyota Camry at 7102 South Paxton, and parked to conduct surveillance. Officers Kilroy, Darling, and Gadzik were in another vehicle, out of sight. Williams saw Sands engage in a hand-to-hand transaction. He informed the enforcement officers that a narcotics transaction had occurred. Kilroy drove the enforcement vehicle to block the Camry. Kilroy testified that the buyer exited the Camry and ran into a store. Gadzik pursued the buyer. Kilroy approached the Camry and saw Sands, holding a firearm, which he moved to the center console. Kilroy ordered Sands to exit the car, then removed Sands, patted him down, and passed Sands to another officer. Kilroy entered the Camry, opened the console, and located Sands’s firearm, containing live ammunition, and 10-15 bags of marijuana under a false console floor. At trial on charges of being a felon in possession of a firearm, 18 U.S.C. 922(g)(1), the court precluded Sands from arguing that Hunter placed the firearm into the console, but allowed Sands to argue that the firearm was Hunter’s. The Seventh Circuit affirmed, upholding that ruling and denial of a motion to suppress. View "United States v. Sands" on Justia Law

Chapman’s sales of heroin and cocaine were recorded by an undercover informant wearing a Hawk recording device, which captured audio-video recordings of each transaction. The recordings were introduced at trial. Following his conviction, Chapman was sentenced to 200 months’ imprisonment. The Seventh Circuit affirmed, rejecting an argument that the district court violated his constitutional rights to a fair trial by both refusing to grant him a third expert witness to examine the informant’s recordings and by denying his motion to subpoena one of his earlier expert witnesses. The court upheld admission of the recordings at trial; denial of motion for acquittal based on a defense of entrapment; and the sentence. View "United States v. Chapman" on Justia Law

In 2001, Sherman was shot and died from multiple gunshot wounds. When an officer arrived, Sherman lay on the ground with 50-60 people gathered around. Long was tried for first degree murder. No physical evidence tied Long to the crime. The state presented four witnesses. Two witnesses named Long as the shooter during the investigation, but recanted at trial. In closing argument, the prosecutor made improper statements, resulting in reversal of Long’s conviction and a new trial. At Long’s second trial, the state again presented the four eyewitnesses. One maintained her identification of Long. The two witnesses who recanted during the first trial continued to deny having seen Long shoot Sherman, despite their prior videotaped statements. The fourth witness, Irby, gave inconsistent testimony. During closing arguments, the prosecutor made comments that no evidence or theory was presented that another individual committed the crime, referred to the movie “Gone with the Wind,” and referenced the contents of a letter written by Irby that had not been admitted into evidence. The jury found Long guilty. His state court appeals and post-conviction petitions were unsuccessful. The district court dismissed Long’s federal habeas petition, finding the prosecutorial misconduct claims procedurally defaulted and that Long had not shown a reasonable likelihood that Irby’s testimony or the closing argument prejudiced the outcome; that Long’s ineffective assistance claim was without sufficient merit to overturn the state court; and that his post-conviction counsel ineffective assistance claim was procedurally barred. The Seventh Circuit reversed, finding that the state’s failure to correct Irby’s denial of her recantation prejudiced Long. View "Long v. Butler" on Justia Law

In 2007, Adkins, a detective at a Chicago Veterans Affairs (VA) Medical Center, installed a hidden surveillance camera in the ceiling of an office used by female officers as a changing area. The camera captured images of female officers dressing and undressing. VA personnel discovered the covert surveillance equipment during a 2009 renovation. Gustafson learned that the camera had captured images of her changing and filed suit against Adkins, alleging an unconstitutional search in violation of the Fourth Amendment. The district court denied Adkins’s motion for summary judgment on qualified immunity grounds. The Seventh Circuit affirmed, rejecting Adkins’s claims that Gustafson’s Bivens claim was precluded by the “comprehensive remedial scheme[s]” laid out in the Civil Service Reform Act and the Federal Employees’ Compensation Act. Supreme Court precedent clearly established the contours of the Fourth Amendment violation Gustafson alleged. View "Gustafson v. Adkins" on Justia Law

In 2005, Martinez, Vallejo, and 47 others were indicted for crimes committed while they were members of the Milwaukee chapter of the Latin Kings gang organization. Martinez and Vallejo pled guilty to a RICO offense, 18 U.S.C. 1962, and admitted to engaging in predicate racketeering activities, including a 2003 murder. Vallejo, who was 17 years old at the time, and Martinez, who was 16, each fired several shots at the victim. Martinez also pled guilty to attempted murder of a rival gang member; Vallejo’s plea agreement included two attempted murders. All of the attempted murders occurred while the defendants were under the age of 18. In both cases, the court imposed the “maximum sentence”—life in prison.. Neither Martinez nor Vallejo filed a direct appeal. In 2012, the Supreme Court held, in Miller v. Alabama, that the Eighth Amendment prohibits the imposition of a mandatory life sentence without the possibility of parole for juveniles. The Seventh Circuit affirmed the district court’s denial of their motion to vacate, set aside, or correct their sentences under 28 U.S.C. 2255. Martinez and Vallejo’s life sentences were imposed after an individualized sentencing, and not by statutory mandate,and did not violate Miller. View "Vallejo v. United States" on Justia Law