Justia Constitutional Law Opinion Summaries

Articles Posted in US Court of Appeals for the Seventh Circuit
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Juarez Rogers, who lived in Illinois, was arrested for murder in Griffith, Indiana. A confidential informant in that investigation reported to police in nearby Hobart, Indiana, that Juarez’s sons, including Cortez Juarez Rogers, were threatening him. Hobart Officers investigated and found an Illinois State ID photo and associated information for an Illinois resident, Cortez Javan Rogers, who had never been to Indiana. Believing, mistakenly, that Javan was the individual about whom the informant had complained, an officer attested that he had communicated a threat to commit a felony. An Indiana judge issued an arrest warrant that was listed in a database available to law enforcement officers in other states. A Chicago police officer subsequently stopped a car in which Javan was a passenger, consulted a database, and arrested him. An Illinois judge denied bail and remanded Javan pending extradition to Indiana. The following evening Indiana moved to correct the warrant information. Chicago officers immediately released Javan, who sued under 42 U.S.C. 1983.The Seventh Circuit affirmed the dismissal of the suit for lack of personal jurisdiction. The Hobart officers did not purposefully engage in any activity in Illinois or direct any action in Illinois that would cause them to reasonably anticipate that they would be haled into Illinois courts. The exercise of personal jurisdiction over them would offend traditional notions of fair play and substantial justice. None of the supposed Illinois contacts, considered separately or together, constitute the requisite “minimum contacts” among the state, the defendants, and the cause of action necessary to fulfill the requirements of due process. View "Rogers v. City of Hobart" on Justia Law

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An Illinois jury convicted Evans of the first-degree murder of Williams, who was killed in a Chicago drive-by shooting. Only one eyewitness, Jeffers, connected Evans to the shooting. Jeffers initially only provided a few general identifying details of the shooter and did not specifically identify any shooter. Eleven months later, the police approached him while he was incarcerated; Jeffers then identified Evans as the shooter. At trial, Jeffers recanted that identification: he testified that he did not see the identity of the shooter but had identified Evans because the police told him to. During closing arguments, the prosecutor argued that Jeffers’s trial testimony was false and the jury should disbelieve it because Jeffers only changed his story after being paid a visit by a defense investigator working for Evans’s co-defendant, who was a known gang member.The state appellate court concluded that there was sufficient evidence to support the prosecutor’s closing argument statements, so they were not improper. Evans unsuccessfully sought state post-conviction relief.The Seventh Circuit affirmed an order granting federal habeas relief. The state appellate court’s determination that the prosecutor’s statements were proper was objectively unreasonable. The facts compel the conclusion that Evans was deprived of his right to a fair trial. View "Evans v. Jones" on Justia Law

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In 2009, Newton pleaded guilty to bank robberies, and possessing and discharging a firearm during a bank robbery, and was sentenced to 220 months’ imprisonment. In May 2020, Newton sought compassionate release, arguing that his asthma, combined with prison mismanagement of the pandemic, constituted an extraordinary and compelling reason for his release under 18 U.S.C. 3582(c)(1)(A)(i), and that his prolonged use of a corticosteroid to treat his asthma weakens his immune system, putting him at greater risk. Newton provided a detailed plan for his release and added that a third condition, hypertension. In July 2020, Newton contracted COVID-19. Three weeks later, a prison physician noted that his infection had “resolved” and that he “did not have a severe illness requiring hospitalization.” Newton still reported “recurrent intermittent coughs, headaches, and asthma flare-ups.” The district court denied his request, stating only: The Government contends, however, that Newton has not demonstrated extraordinary and compelling reasons to warrant a sentence reduction. I agree. … The CDC … has not been able to determine conclusively that [Newton’s conditions[ pose an increased danger.…. the prison has lately succeeded in drastically reducing active cases.”The Seventh Circuit vacated. When an inmate like Newton presents individualized arguments along with a meaningfully detailed record, the district court’s opinion must establish that it considered those individualized arguments and properly exercised its discretion. View "United States v. Newton" on Justia Law

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Thill was convicted of sexual contact with A.M.M., his ex‐girlfriend’s eight‐year‐old daughter. A.M.M. testified that Thill had sexually assaulted her; Thill’s semen was found on her underwear. Thill’s defense was that his jilted ex‐girlfriend framed him by saving his semen for over a year, planting it on her daughter’s underwear, and coaching her to make false accusations. While cross‐examining Thill and in closing arguments, the prosecutor referenced Thill’s failure to tell the police during his initial interview that he believed his ex‐girlfriend had the means or motivation to frame him. In postconviction proceedings, Thill argued that the prosecutor impermissibly used his silence after receiving Miranda warnings to impeach him and that his trial counsel was ineffective for failing to object. The Wisconsin Court of Appeals concluded Thill had not demonstrated prejudice.The Seventh Circuit affirmed, finding that conclusion not contrary to nor an unreasonable application of clearly established federal law. The state court correctly paraphrased Strickland’s prejudice standard and nothing in its analysis suggested it used a standard “‘substantially different’ from or ‘opposite to’” that standard. The state presented significant direct evidence of a specific sexual assault. Thill’s defense had significant holes that extended far beyond his failure to raise this defense to the police; it was “weak and unpersuasive” and largely rested on Thill’s “self‐serving testimony.” View "Thill v. Richardson" on Justia Law

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An informant gave South Bend police the number to a phone used by drug dealers. Officers conducted controlled buys in which confidential informants or undercover officers called the number and followed instructions to buy heroin. Officers then submitted an affidavit to a state court judge and obtained a "court order," requiring the phone’s service provider to share 30 days of precise, real-time GPS location data for the phone. The investigation led to two men at the top of the drug-trafficking conspiracy, Gibson and Harris. The district court denied their pre-trial motion to suppress evidence obtained through the cellphone tracking. Officers and cooperators testified to the large-scale drug-trafficking scheme that the defendants had overseen. Both were convicted of conspiring to distribute one kilogram or more of heroin. At sentencing, the court found that the defendants had conspired to distribute a total of 10.5 kilograms of heroin.The Seventh Circuit affirmed, upholding the denial of the motion to suppress, the drug-quantity calculations, and the court’s limits on cross-examination of the cooperators about the specific sentences they hoped to avoid by testifying for the government. The court orders for the cellphone data satisfied the requirements for a search warrant: the judge who issued the orders was neutral and found probable cause to believe that the cellphone tracking would lead to the apprehension of drug traffickers and the orders particularly described the object of the search. View "United States v. Harris" on Justia Law

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Plaintiff filed suit against GoJet for violations of the Family Medical Leave Act (FMLA) and the Americans with Disabilities Act (ADA) after GoJet terminated him following his Diabetes Type II diagnosis. The jury found in plaintiff's favor and the district court granted him back pay, liquidated damages, and front pay. GoJet appealed and plaintiff cross-appealed.The Seventh Circuit affirmed the district court's denial of GoJet's motion to dismiss, holding that the arbitration provisions in the Collective Bargaining Agreement (CBA) did not clearly, unmistakably, or explicitly state that plaintiff's FMLA claims could only be brought in arbitration. The court rejected GoJet's arguments that the district court erred in denying its motion for judgment as a matter of law. In regard to damages, the court held that the district court did not abuse its discretion in calculating damages based on minimum hours at GoJet because it plausibly could have found that plaintiff would have worked the minimum number of hours from his termination date onward. However, the court held that the district court erred when it calculated front pay based on two different values for how much work the court expected plaintiff to work at GoJet and SkyWest. Accordingly, the court reversed and remanded on this issue for the district court to apply a uniform hourly figure to calculate expected earnings at GoJet and SkyWest for the purposes of front pay. Finally, the court concluded that plaintiff waived his argument regarding the district court's front pay calculations based on post-trial evidence and his argument regarding the correct methodology for calculating damages. Accordingly, the court affirmed as to all other issues on appeal. View "Cloutier v. GoJet Airlines, LLC" on Justia Law

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Under the Prison Litigation Reform Act (PLRA), the suit of a prisoner filing a petition to proceed in a suit in forma pauperis (IFP) must be dismissed if the prisoner deliberately misrepresented his financial status. Reyes, an Illinois prisoner, filed a 42 U.S.C. 1983 action in 2017 and another in 2018 and petitioned to proceed IFP in both cases. The district court initially granted those IFP petitions but later dismissed both cases under 28 U.S.C. 1915(e)(2)(A), after the defendants presented evidence that Reyes deliberately misled the court about his finances on his 2017 IFP application. He did not disclose information about his income for three months in 2017, during which time he had received $1,692 in gifts deposited to his trust account. He had spent $785 at the commissary for non-essential items, such as a television. He claimed to have received no income in 2018 but had received $26.The Seventh Circuit affirmed the dismissal of the 2017 case because the district court did not clearly err in finding that Reyes was dishonest about his financial status. The court did not give Reyes a chance to explain any potential issues with his 2018 IFP application and the defendants conceded that he should have been given that opportunity. The court vacated that dismissal. View "Reyes v. Ashcraft" on Justia Law

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Smith has been in state prison for 19 years for a 2001 murder and robbery that he insists he did not commit. Smith had been charged on the basis of the confession by another (Houghtaling) and was tried three times. The state had no physical evidence linking Smith to the crime. In 2020, the district court held that he is entitled to release unless the state decides to retry him but Smith was seeking more: an unconditional writ based on the insufficiency of the evidence. The state appealed from the issuance of the conditional writ and Smith cross-appealed.The Seventh Circuit reversed and ordered the issuance of an unconditional writ and Smith’s immediate release. Even taking the highly deferential view required by 28 U.S.C. 2254(d), the evidence failed to support Smith’s conviction beyond a reasonable doubt; the Illinois Appellate Court was unreasonable, in holding otherwise. The court noted the flaws in Houghtaling’s confession, the exclusion of evidence vital to Smith’s defense, and the trial court’s refusal to allow Smith to impeach prosecution evidence. View "Smith v. Brookhart" on Justia Law

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The Seventh Circuit affirmed the district court's grant of summary judgment to the University in an action alleging retaliation claims against the University under the Age Discrimination in Employment Act (ADEA). In this case, plaintiff alleged that the University unlawfully retaliated against him for declining requests to implement age-discriminatory policies against older faculty members. Plaintiff alleged that the University did so by removing him as department chair and by denying his application for promotion.In regard to plaintiff's claim that the University violated the ADEA by removing him as department chair, the court concluded that plaintiff's cat's paw theory of liability failed where plaintiff cannot demonstrate that the supervisor proximately caused plaintiff's removal as chair because the decisionmaker drew a conclusion independent of any alleged influence by the supervisor. The court explained that, in his deposition, the decisionmaker explained that he removed plaintiff based on the faculty grievance committee report and the Title IX investigation report, both of which highlighted the toxic and dysfunctional culture within the department. In regard to plaintiff's denial-of-promotion claim, the court concluded that the district court correctly determined that this claim is time-barred. View "Sinha v. Bradley University" on Justia Law

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Illinois Trooper Chapman received a message about a Volkswagen with California license plates driving on I-72. Chapman spotted the Volkswagen, driven by Cole, and trailed him, intending to find a pretext for a roadside stop. After another car cut off the Volkswagen, Chapman believed that the Volkswagen trailed that car at an unreasonably close distance. Chapman stopped Cole, requested his papers, and ordered him to sit in the police cruiser. This initial stop lasted 10 minutes. Chapman spent about six minutes questioning Cole about his residence, employment, travel history, plans, vehicle history, and registration information. Chapman told Cole that he would get a warning but that they had to go to a gas station to complete the paperwork because he was concerned for their safety. Chapman testified later that he had already decided that he was not going to release Cole until he searched the car. Driving to the gas station, Chapman requested a drug-sniffing dog and learned that Cole had been arrested for drug crimes 15 years earlier. At the gas station, Cole’s answers became contradictory. Finishing the warning, 30 minutes after the stop, Chapman told Cole that he could not leave because he suspected Cole was transporting drugs. The dog arrived 10 minutes later and quickly alerted. Chapman found several kilograms of methamphetamine and heroin in a hidden compartment.The Seventh Circuit reversed the denial of a motion to suppress. Even assuming that the stop was permissible, the officer prolonged the stop by questioning the driver at length on subjects well beyond the legal justification for the stop, in violation of the Fourth Amendment. View "United States v. Cole" on Justia Law