Justia Constitutional Law Opinion Summaries

Schaumburg’s 2016 ordinance requires commercial buildings to send fire‐alarm signals directly to the local 911 dispatch center, NWCDS, which has an exclusive arrangement with Tyco. To send signals to NWCDS, local buildings must use Tyco equipment. Schaumburg’s notice of the ordinance referred to connection through Tyco and stated that accounts would be charged $81 per month to rent Tyco’s radio transmitters and for the monitoring service. Tyco pays NWCDS an administrative fee of $23 per month for each account it connects to the NWCDS equipment. Tyco’s competitors filed suit charging violations of constitutional, antitrust, and state tort law. The district court dismissed the case. The Seventh Circuit reversed the dismissal of the Contracts Clause claim against Schaumburg. The complaint alleges a potentially significant impairment, the early cancellation of the competitors’ contracts, and Schaumburg’s self‐interest, $300,000 it stands to gain. The court otherwise affirmed, noting that entities not alleged to have taken legislative action cannot be liable under the Contracts Clause. WIth respect to constitutional claims, the court noted the government’s important interest in fire safety. Rejecting antitrust claims, the court stated that the complaint did not allege a prohibited agreement, as opposed to an independent, legislative decision. View "Alarm Detection Systems, Inc. v. Village of Schaumburg" on Justia Law

Four Illinois Villages passed ordinances that require commercial buildings to send fire-alarm signals directly to the local 911 dispatch center through one alarm-system provider, Tyco, which services the area pursuant to an exclusive agreement with the dispatch center. An alarm-system competitor, ADS, sued, citing the Illinois Fire Protection District Act, the Sherman Act, and the Fourteenth Amendment. The district court granted the defendants summary judgment. The Seventh Circuit affirmed. The Sherman Act claims fail because they are premised on the unilateral actions of the Villages, which ADS did not sue. The court noted that ADS can compete for the contract now held by Tyco. ADS’s substantive due process claim asserted that the district acted arbitrarily and irrationally by going with an exclusive provider rather than entertaining ADS’s efforts at alternative, methods. The ordinances effectively require the district to work with an exclusive provider and there was thus a rational basis to choose an exclusive provider. View "Alarm Detection Systems, Inc. v. Orland Fire Protection District" on Justia Law

In 2004, Conroy was charged with solicitation of murder, solicitation of murder for hire, and attempted first‐degree murder. The court determined that Conroy was fit to stand trial. In 2007, Conroy pleaded guilty and was sentenced to 30 years in prison. He did not appeal. Conroy received mental health services through the Illinois Department of Corrections and, in 2007, was diagnosed with depressive and schizoaffective disorders. In 2008, Conroy’s evaluations indicated that he was “alert and oriented,” and his “[t]hought processes were logical, coherent and goal-directed.” Conroy “denied any auditory [or] visual hallucinations or delusions.” In 2009, Conroy filed an unsuccessful state court post-conviction petition, arguing that his counsel provided ineffective assistance by coercing him into pleading guilty. In 2014, Conroy filed other unsuccessful state court post-conviction motions. In 2016, Conroy filed a federal court petition under 28 U.S.C. 2254, alleging ineffective assistance. Conroy argued that the limitations period for filing his petition should be equitably tolled because his mental limitations prevented him from understanding his legal rights. The district court determined that Conroy’s mental limitations were not an extraordinary circumstance and that he failed to show that he had been reasonably diligent in pursuing his claim. The Seventh Circuit affirmed, noting evidence of Conroy’s competency in prior years. Conroy did not meet the “high bar” for equitable tolling. View "Conroy v. Thompson" on Justia Law

Fincher lived in a one‐bedroom apartment with his uncle, a drug dealer, and began selling drugs. Both were arrested after selling heroin to undercover police officers. Police searched the apartment. In the bedroom closet, they found more than 100 grams of heroin, cash, and .40 caliber bullets. A loaded .40 caliber handgun was found in the kitchen. Fincher, whose criminal record was clean, was charged with conspiring to knowingly and intentionally possess with intent to distribute 100 grams or more of heroin and six counts of distribution of and intent to distribute heroin. Fincher pleaded guilty to the conspiracy charge, which carried a mandatory minimum sentence of five years. The safety‐valve provision, 18 U.S.C. 3553(f), however, provides that a court is precluded from applying the mandatory minimum if it finds that the defendant has a minimal criminal history; the defendant did not use or threaten violence or possess a firearm in connection with the offense; the offense did not result in death or injury; the defendant was not an organizer or leader; and the defendant truthfully provided all information and evidence related to the offense before the sentencing hearing. Fincher’s DNA was found on the firearm. The district court found that Fincher possessed the firearm in connection with his offense, and was ineligible for safety‐valve relief and subject to a two‐level firearm enhancement, and imposed a five-year sentence. The Seventh Circuit affirmed. The safety‐valve potentially allows for relief from a mandatory minimum, but it does not increase or trigger it. Judicial fact-finding precluding safety‐valve relief does not violate the Sixth Amendment under the Supreme Court's Alleyne holding. Fincher failed to show by a preponderance of the evidence his possession of the handgun was not in connection with his offense. View "United States v. Fincher" on Justia Law

Police responded to a reported residential burglary in progress. M.G. met officers at the property and stated that he owned the home as a rental property with no current tenants and that no one should be inside. M.G. spotted a window cracked open and, peering inside, he saw someone in the house. Officers banged on the door and ordered all the occupants outside. Sawyer and three others came out and stood with the officers on the porch. M.G. asked the officers to “check my house.” Inside, officers found a backpack; they opened it and discovered four guns. Outside, officers placed the four men in custody. The backpack was brought outside. An officer opened it, found a cell phone, gave Miranda warnings, and asked the arrestees who owned the phone. Sawyer responded that it was his phone and bag. Sawyer later denied it was his bag. Sawyer moved to suppress the contents of the backpack and his statements. The government successfully argued that Sawyer failed to provide evidence that he had a subjective expectation of privacy in the backpack and that, as a trespasser, Sawyer had no legitimate expectation of privacy; officers had obtained the owner's consent to search the home. Sawyer conditionally pleaded guilty to knowingly possessing a firearm as a felon. The Seventh Circuit affirmed. The officers were entitled to search the backpack as part of their ongoing investigation of a burglary; Sawyer, as a trespasser, had no reasonable expectation of privacy in the backpack he brought in when he unlawfully entered the premises. View "United States v. Sawyer" on Justia Law

While Flores was on supervision for a state conviction, Flores and her co-defendant were found with more than 300 pounds of marijuana with a street value of approximately $1.8 million. Flores, who had a prior felony drug conviction, pled guilty to possession with the intent to distribute 100 kilograms or more of marijuana, 21 U.S.C. 841(a)(1). At her sentencing hearing, Flores did not object to standard condition 3, which stated: “Defendant shall maintain lawful employment, seek lawful employment, or enroll and participate in a course of study or vocational training that will equip defendant for suitable employment, unless excused by the probation officer or the Court.” The Seventh Circuit affirmed, rejecting an argument that condition 3’s use of the word “suitable” was unconstitutionally vague. Flores had notice and opportunity to make the challenge in the district court, she submitted other sentencing challenges, and she affirmatively waived reading of the conditions and their justifications at sentencing. Her failure amounts to waiver, precluding appellate review. View "United States v. Flores" on Justia Law

A jury found that Morgan possessed the 86.5 grams of methamphetamine that he tossed past law enforcement officers in the Peoria airport. Morgan had testified that all of it was for his personal use. The jury could not agree on whether the government proved that he possessed the methamphetamine with the intent to deliver, 21 U.S.C. 841(a)(1); (b)(1)(A). They declared themselves deadlocked on that issue—the one charged in the indictment—but found him guilty of the lesser included offense of possession of methamphetamine. At a second trial, the court read the jury a limiting instruction several times: you’re going to hear testimony that the defendant committed a wrong other than the one charged in the indictment. Before using this evidence, you must decide whether it’s more likely than not that the defendant committed the wrong that is not charged in the indictment. If you decide that he did, then you may consider this evidence to help you decide whether the defendant intended to distribute methamphetamine …. You may not consider it for any other purpose ... the defendant is on trial here for possessing methamphetamine with the intent to distribute ... not for the other wrong. Morgan was sentenced to 240 months for possession with intent to distribute. The Seventh Circuit affirmed, finding only harmless errors and no violation of his Fifth Amendment right to be free from double jeopardy. View "United States v. Morgan" on Justia Law

Purdue students John and Jane had consensual sexual intercourse 15-20 times. Jane’s behavior became erratic. Jane attempted suicide. Weeks later, John reported Jane’s suicide attempt to an advisor. Jane was upset and distanced herself from John. Months later, during Sexual Assault Awareness Month, Jane alleged that while sleeping with John, she woke to him groping her over her clothes. Jane says she reprimanded John. John then purportedly confessed that he had digitally penetrated her while she was sleeping weeks earlier. Jane told the university that John had gone through her underwear drawer, chased her through a hallway while joking about tasering her, gone to her room unannounced, and lost his temper in front of her. Purdue pursued Jane’s allegations although Jane did not file a formal complaint. John was suspended from Navy ROTC, banned from buildings where Jane had classes and from his dining hall. John submitted a denial, noting that after the alleged incidents, Jane texted him over the holidays, sent his family cookies, and invited him to her room. Investigators neither gave him a copy of the report nor shared its contents. Moments before his committee appearance, he learned that it falsely claimed that he had confessed and failed to describe Jane’s suicide attempt. Jane neither appeared nor submitted a written statement. The panel refused John permission to present witnesses. John was found guilty by a preponderance of the evidence. Purdue suspended him for a year and imposed conditions on his readmission. The ROTC program terminated his scholarship. John sued, asserting Purdue used flawed procedures and violated Title IX by imposing a punishment infected by sex bias. A magistrate dismissed. The Seventh Circuit reversed. John adequately alleged violations of both the Fourteenth Amendment and Title IX. View "Doe v. Purdue University" on Justia Law

During a Rock Island, Illinois traffic stop, two officers were arresting the driver of a vehicle on an outstanding warrant, when they recognized defendant Yancey, the passenger. Based on their past interactions with Yancey, and their familiarity with a contact sheet labeling him as potentially armed, the officers decided to pat him down for weapons. Before they could do so, Yancey ran. The officers tackled him and saw a handgun sticking out of his waistband. Yancey was subsequently convicted of felony possession of a firearm. Yancey claimed that police lacked justification to keep him from leaving the scene. The Seventh Circuit affirmed, Under Supreme Court precedent, police officers can detain passengers in a car while a stop is ongoing if they have a lawful reason to seize the driver. The officers lawfully stopped the car in which Yancey rode as a passenger and that stop was still lawfully ongoing when Yancey tried to flee; it was not unreasonable for the officers to detain him. View "United States v. Yancey" on Justia Law

M.J.J. and J.K.J. were inmates at Polk County Jail at various times between 2011 and 2014. Christensen admits he engaged in sexual acts with the women individually. He urged the women not to discuss his sexual advances; his assaults were kept hidden from jail officials until a former inmate reported her own sexual encounters with Christensen to an investigator in a neighboring county. An investigation led to Christensen pleading guilty to several counts of sexual assault. He is serving a 30‐year prison sentence. J.K.J. and M.J.J. sued Christensen and the county under 42 U.S.C. 1983, alleging Eighth and Fourteenth Amendment claims, with a state law negligence claim against the county. A jury found Christensen and the county liable and awarded each woman $2 million in compensatory damages. The jury also levied punitive damages against Christensen, $3,750,000 to each plaintiff. The Seventh Circuit affirmed as to Christensen. His assaults were predatory and knowingly criminal. The court reversed as to the county. To impose liability against the county for Christensen’s crimes, there must be evidence of an offending county policy, culpability, and causation. Christensen’s acts were reprehensible, but the evidence shows no connection between the assaults and any county policy. View "J.K.J. v. Polk County" on Justia Law