Justia Constitutional Law Opinion Summaries

Articles Posted in US Court of Appeals for the Seventh Circuit
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The case revolves around Denis Navratil, his wife Dimple Navratil, and their business, Dimple’s LLC, who filed a lawsuit against the City of Racine and Mayor Cory Mason. The lawsuit was based on several constitutional claims and a defamation claim against Mason. The core of the claims was the city's decision not to grant an emergency grant to Dimple’s LLC because Denis had attended a rally protesting the statewide “Safer at Home Order” that limited public gatherings, travel, and business operations to combat the COVID-19 pandemic. The rally was a violation of the Safer at Home Order and a permit required for holding rallies at the State Capitol had been denied due to the pandemic.The case was initially heard by a magistrate judge who granted summary judgment for both defendants on all claims. The plaintiffs appealed this decision.The United States Court of Appeals for the Seventh Circuit affirmed the lower court's decision. The court found that Denis's attendance at the rally was not protected First Amendment activity because the rally was prohibited by two valid time, place, and manner restrictions—the Safer at Home Order and the state permit requirement. The court also rejected the plaintiffs' equal protection claims, finding no evidence of political animus or similarly situated comparators. The court further dismissed the plaintiffs' due process claims, finding no deprivation of any constitutionally protected property or liberty interest. Lastly, the court found that Mayor Mason's statements were substantially true or pure opinion and thus not actionable under defamation law. View "Denis Navratil v. City of Racine" on Justia Law

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Shamar Betts was indicted for inciting a riot in violation of the Anti-Riot Act, 18 U.S.C. § 2101, after he posted a flyer on Facebook calling for a riot at a mall in Champaign, Illinois. The riot resulted in damage to several businesses. Betts moved to dismiss the indictment, arguing that the Anti-Riot Act was overbroad and violated the First Amendment, but the district court denied his motion. Betts then pled guilty and was sentenced to 48 months’ imprisonment and ordered to pay $1,686,170.30 in restitution to 35 businesses under the Mandatory Victims Restitution Act (MVRA), 18 U.S.C. § 3663A.On appeal, Betts challenged the constitutionality of the Anti-Riot Act, the application of a sentencing guideline by analogy, and the district court's order of restitution. The Court of Appeals for the Seventh Circuit upheld the constitutionality of the Anti-Riot Act, finding no compelling reason to overrule its previous decision in United States v. Dellinger, which upheld the Act. The court also found no error in the district court's application of a sentencing guideline by analogy to the Anti-Riot Act.However, the court agreed with Betts's argument that the government failed to meet its burden of showing that he directly and proximately caused damages to all businesses included in the restitution order. The court vacated the sentence with regard to the amount of restitution ordered and remanded the case for the limited purpose of reconsidering the amount of restitution. View "United States v. Betts" on Justia Law

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The Greenwald Family Limited Partnership, a landowner in the Village of Mukwonago, Wisconsin, had a longstanding positive relationship with the Village, collaborating on several development projects. However, this relationship soured after a failed land deal in 2014 and several other conflicts. The Partnership sued the Village, alleging that it had been irrationally singled out for unfavorable treatment, violating its Fourteenth Amendment rights. The Partnership pointed to several adverse municipal decisions, focusing primarily on the failed land deal and a new road that was rerouted from the Partnership’s property.The case was initially filed in state court but was later removed to federal court. The district court concluded that the Village had a rational basis for its actions regarding the failed land deal, the new road, and other decisions affecting the Partnership’s properties. The court entered summary judgment in favor of the Village and relinquished jurisdiction over the state-law claims.The case was then brought before the United States Court of Appeals for the Seventh Circuit. The court affirmed the district court's decision, stating that the Partnership had failed to show that the Village’s actions lacked any conceivable rational basis. The court found that the Village’s decisions were rationally related to its legitimate interests in promoting its land-use objectives and protecting public funds. The court concluded that the Partnership was a disappointed landowner, but not a victim of unconstitutional discrimination. View "Greenwald Family Limited Partnership v. Village of Mukwonago" on Justia Law

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The case involves a medical student at Indiana University–Purdue University Indianapolis, referred to as John Doe, who was accused of physical abuse by a fellow student, Jane Roe. The University’s Office of Student Conduct found Doe culpable and suspended him for one year. Doe applied to the University’s MBA program and described his suspension as an exoneration. This led to an investigation by the University’s Prior Misconduct Review Committee, which concluded that Doe had withheld pertinent information and gave false or incomplete information to the business school. Dean Hess of the medical school, without inviting further response from Doe, expelled him from the medical school. Doe accused the University of violating both the Due Process Clause of the Constitution’s Fourteenth Amendment and Title IX of the Education Amendments Act of 1972.The district court granted summary judgment to the defendants. The court found that the record did not support an inference of sex discrimination. The court also found that the University’s delay in launching an investigation into Doe’s complaint that Roe hit him on occasion did not contribute to the ultimate decision, and it was justified by the fact that Doe elected not to pursue this charge against Roe.The United States Court of Appeals for the Seventh Circuit found that Doe’s constitutional argument was stronger. The court held that Doe had a legitimate claim of entitlement to remain a student unless he transgressed a norm, which is a property interest in constitutional lingo and requires some kind of hearing. The court vacated the judgment and remanded the case to the district court. If Doe elects to continue with the suit, his true name must be disclosed to the public, and the district court must decide what remedy is appropriate for Dean Hess’s failure to allow Doe an opportunity to present his position before expelling him. If Doe elects not to reveal his name, the complaint must be dismissed. View "Doe v. Trustees of Indiana University" on Justia Law

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The case revolves around Dylan Ostrum, who was under investigation for drug dealing and possession of firearms. During a search of his home, Ostrum revealed that he had moved his belongings, including his car, to his father's house. However, the car, which was reported stolen by a rental company, was found nearby with Ostrum's belongings inside, including a gun, methamphetamine, and marijuana, all stashed in two safes. The key issues on appeal were whether Ostrum had standing to challenge the search of the stolen car and whether the search violated his Fourth Amendment rights.The investigation into Ostrum began after law enforcement agents found text messages between him and another individual, Ricky Blythe, showing that they repeatedly sold each other methamphetamine and marijuana. Based on this evidence and information from confidential informants, law enforcement obtained a valid warrant to search Ostrum’s residence. However, the search turned up little, and Ostrum informed the officers that he had moved his belongings to his father's house. The officers later located the car, which was reported stolen, and discovered the safes inside.Ostrum was charged with multiple counts related to drug possession and distribution, and being a felon in possession of a firearm. He moved to suppress the evidence found inside the car, arguing that it was the fruit of an illegal search. The district court denied the motion, finding that Ostrum lacked standing to challenge the search because the car was stolen, and that the search was valid under the automobile exception to the Fourth Amendment’s warrant requirement. Ostrum was convicted on all counts and received a 240-month sentence.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court found that Ostrum failed to meet his burden on standing and that the existence of probable cause justified the search under the automobile exception to the Fourth Amendment’s warrant requirement. The court concluded that Ostrum had no reasonable expectation of privacy in the stolen car or its contents, and thus no standing to object to its search. View "USA v. Ostrum" on Justia Law

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The plaintiff, Richard Rodgers, a prisoner with a history of scoliosis and back pain, had steel rods implanted in his back prior to his incarceration. During his time in prison, the rods broke, but this went undetected for over a year due to two radiologists misreading his x-rays. The prison's primary care physician, Dr. William Rankin, discovered the broken rods and arranged for corrective surgery. Rodgers sued the radiologists and Dr. Rankin, alleging violation of his Eighth Amendment rights.The district court dismissed Rodgers' claims against the radiologists, finding that he did not state a viable constitutional claim against them. The court allowed Rodgers to proceed against Dr. Rankin but eventually granted summary judgment in his favor. The court found that Rodgers had not provided evidence that would allow a reasonable jury to find that Dr. Rankin had violated the Eighth Amendment by acting with deliberate indifference toward Rodgers' serious medical condition.The United States Court of Appeals for the Seventh Circuit affirmed the district court's judgment. The court agreed that Rodgers' allegations against the radiologists amounted to no more than negligence, which is insufficient to state a viable Eighth Amendment claim. Regarding Dr. Rankin, the court found that the evidence would not support a reasonable finding that he acted with deliberate indifference to Rodgers' serious medical condition. The court noted that Dr. Rankin was the one who discovered the radiologists' errors and arranged for Rodgers' corrective surgery. View "Rodgers v. Rankin" on Justia Law

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On July 4, 2021, Gavin Wallmow was arrested for violating his probation and was taken to Oneida County jail. During his booking, Wallmow denied any suicidal tendencies or mental health issues. Two days later, Wallmow's probation officer visited him and noticed a change in his behavior, including him hitting himself and expressing "demonic" thoughts. The officer reported this to a corrections officer at the jail, who then informed her superior. Despite these reports, Wallmow was observed behaving normally during routine checks. On July 8, Wallmow was found unresponsive in his cell, having committed suicide. His estate brought a series of constitutional claims under 42 U.S.C. § 1983, alleging that the jailers failed to protect Wallmow from himself.The United States District Court for the Western District of Wisconsin granted summary judgment to the defendants, concluding that the record did not support an inference that any defendant knew Wallmow faced a serious risk of harm. The court also found no reason to think the County's policies were inadequate, given the absence of any pattern of suicides to put it on notice.Upon appeal, the United States Court of Appeals for the Seventh Circuit affirmed the lower court's decision. The appellate court found that the jail's employees had taken reasonable precautions, including checking on Wallmow at least 37 times per day. The court also noted that Wallmow had thrice disavowed any risk of suicide, and nothing indicated otherwise after his talk with his probation officer. The court concluded that the jail's actions complied with the Constitution's requirements. View "Estate of Wallmow v. Oneida County, Wisconsin" on Justia Law

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The case involves Jacob Lickers, who was convicted for transporting and possessing child pornography. The conviction was based on evidence found on Lickers' devices, which were seized during a traffic stop and subsequent arrest for drug possession. The initial search of the devices was authorized by a state court warrant, which later suppressed the evidence due to the unconstitutionality of the initial stop and arrest. However, the case was referred to federal authorities who conducted a second search of the devices under a federal warrant. The federal warrant application did not mention the state court's suppression ruling.In the lower courts, Lickers' attorney challenged the constitutionality of the initial stop and arrest, and the adequacy of the state search warrant. The state court agreed, suppressing all evidence seized during the stop and any statements made by Lickers. The state charges were subsequently dismissed. However, in the federal court, the same arguments were unsuccessful. Lickers pleaded guilty, reserving the right to appeal the denial of his motion to suppress. The district court sentenced him to concurrent terms of 132 months' imprisonment on each count.In the United States Court of Appeals For the Seventh Circuit, Lickers argued that his trial and appellate counsel rendered ineffective assistance by failing to argue that the federal agent acted in bad faith by omitting the state court's suppression ruling from the federal warrant application. The court disagreed, finding that the link between the state court's suppression ruling and the federal warrant application was too attenuated to obligate the attorneys to explore the possibility of bad faith. The court affirmed the district court's denial of relief. View "Lickers v. United States" on Justia Law

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The case revolves around Anthony Gay, a convicted felon, who was found guilty of possessing firearms and ammunition, both of which he was prohibited from possessing due to his prior felony convictions. Gay was a passenger in a car that was stopped by the police, and upon being pursued, he fled on foot. The police testified that they found a gun where Gay had fallen and later discovered bullets in a motel room he had rented. Gay was subsequently indicted and convicted on one firearms count and one ammunition count, leading to a sentence of 84 months' imprisonment on each count, to run concurrently, plus three years' supervised release.Previously, Gay had contested the admissibility of the bullets found in the motel room, arguing that their discovery violated his Fourth Amendment rights. However, the district court denied his motion to suppress the bullets, stating that Gay's right to occupy the room had expired, the motel manager had found the bullets before the police were involved, and the manager had the right to admit the police under state law. Furthermore, the court noted that Gay, being on parole, had a diminished expectation of privacy.In the United States Court of Appeals for the Seventh Circuit, Gay argued that the evidence did not support his conviction on the firearms charge, suggesting that the weapon may have been planted. However, the court found that the evidence, including the bullets found in the motel room, supported the firearms charge. The court also dismissed Gay's argument that the reduction of two weeks in preparation time for his second trial was prejudicial, stating that the parties had just been through a trial and the evidence had been assembled.Gay also contended that the prosecution was unconstitutional, arguing that the Second Amendment permits persons with felony convictions to possess firearms and ammunition. However, the court affirmed the lower court's decision, citing precedents that upheld the validity of "longstanding prohibitions on the possession of firearms by felons." The court concluded that Gay, having been convicted of 22 felonies and being on parole, did not fit the description of a "law-abiding, responsible citizen" who has a constitutional right to possess firearms. View "United States v. Gay" on Justia Law

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The case involves Harold McGhee, who was convicted and sentenced for drug trafficking. In August 2021, law enforcement received information from a confidential source about a drug dealer distributing large amounts of cocaine in Peoria, Illinois. The dealer was said to drive a Chevy Malibu and supplied cocaine to a house on West Millman Street. With this information, along with details from other informants and a tracking warrant, the police identified McGhee as the suspected dealer. They conducted three controlled buys and a trash pull at McGhee's residence, which led to the discovery of rubber gloves and baggies with a white powdery residue that tested positive for cocaine. This evidence led to a search warrant for McGhee's residence, vehicle, person, and electronic devices, resulting in the discovery of nearly a kilogram of various drugs, a handgun, and other drug trafficking paraphernalia.McGhee sought to suppress the evidence recovered at his residence and moved for a hearing to challenge the validity of the search warrant. He argued that the affidavit's use of "SUBJECT PREMISES," in reference to both his residence and the Millman Street house, was impermissibly ambiguous. The district court denied the motion. McGhee later renewed his motion to suppress, arguing that the trash pull was constitutionally unreasonable because it was executed without a warrant. The court denied this motion as well.On appeal, McGhee raised ten challenges to the criminal proceedings resulting in his convictions and sentence. The court considered some of his arguments on the merits and resolved others on procedural grounds. Ultimately, the court affirmed the judgment of the district court in all respects. View "United States v. McGhee" on Justia Law