38 results for 'judge:"St. Eve"'.
J. St. Eve finds that the lower court properly denied defendant's motion for post-conviction relief alleging ineffective assistance of counsel based on the fact that his second hired attorney also presided over his preliminary hearing in this same case. Defendant presents no specific evidence that his counsel's performance was in any way deficient despite this conflict of interest that went unremarked. Affirmed.
Court: 7th Circuit, Judge: St. Eve, Filed On: April 26, 2024, Case #: 22-3086, Categories: Drug Offender, Ineffective Assistance
J. St. Eve finds that the lower court properly convicted singer R. Kelly of sexually abusing underage girls, and of child pornography for videotaping his sex acts with his victims. Under current law, there is no statute of limitations for sex crimes against children. Although R. Kelly's abuse of his victims took place in the 1990s and 2000s, he is not entitled to the application of an earlier version of the statute with a shorter limitations period. The PROTECT Act of 2003 unambiguously applies retroactively to R. Kelly's crimes. Affirmed.
Court: 7th Circuit, Judge: St. Eve, Filed On: April 26, 2024, Case #: 23-1449, Categories: Criminal Procedure, Sex Offender, Child Victims
J. St. Eve finds that the lower court properly convicted defendant on drug charges and of being a felon in possession of a firearm after searching a stolen car and finding his belongings inside. Defendant has no evidence to support his claim he did not know the rental car was stolen, especially as the license plates had been switched out. Further, he had no expectation of privacy in the safes located in the stolen car. Even if he did, the automobile exception to the warrant requirement applies as officers had ample reason to believe the car held contraband. Affirmed.
Court: 7th Circuit, Judge: St. Eve, Filed On: April 25, 2024, Case #: 23-1364, Categories: Drug Offender, Search
J. St. Eve finds that the lower court properly sentenced defendant to 96 months in prison for stealing 25 firearms, of which police only recovered eight. The court's speculation that the missing firearms were "likely in the hands of other felons" does not amount to impermissible speculation requiring the court to vacate his sentence. Affirmed.
Court: 7th Circuit, Judge: St. Eve, Filed On: April 24, 2024, Case #: 23-1564, Categories: Firearms, Sentencing
J. St. Eve finds that the lower court properly found for the county in a family's suit following a man's suicide in jail. The deceased gave jail staff no indication that he was a threat to himself. The staff's delay in waiting for 20 minutes to tell the man to take down a bedsheet obscuring the view of his bed was not unreasonable given that many inmates put sheets up just for privacy and the jail had never had a suicide before. Affirmed.
Court: 7th Circuit, Judge: St. Eve, Filed On: April 17, 2024, Case #: 23-2141, Categories: Civil Rights, Wrongful Death
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[Consolidated.] J. St. Eve finds that the lower court improperly sentenced defendant for conspiracy to distribute meth based on a finding that the conspiracy involved 737 grams of "ice" meth. The state only tested a small amount of the drug for purity, and cannot simply rely on co-conspirators' statements to calculate the total drug weight. Reversed.
Court: 7th Circuit, Judge: St. Eve, Filed On: April 11, 2024, Case #: 22-2994, Categories: Drug Offender, Sentencing
J. St. Eve finds that the court lacks jurisdiction to hear the school's appeal of the lower court's order denying its motion to dismiss a sex discrimination suit on the basis of church autonomy. The lower court has not issued a conclusive decision on the school's church-autonomy defense, and did not second-guess the school's determination that the teacher was not in doctrinal good standing. Rather, the viability of the school's defense depends on the strength of the teacher's allegations related to pretext.
Court: 7th Circuit, Judge: St. Eve, Filed On: March 18, 2024, Case #: 21-2683, Categories: Jurisdiction, Employment Discrimination, First Amendment
J. St. Eve finds that the lower court properly overturned the bankruptcy court's decision, holding that the parties' loan authorization agreement and guaranty qualified as securities contracts totaling $25 million. Although this transfer left the debtor in dire financial straits, the trustee cannot seek to recover this money because it falls within the safe harbor provision. Affirmed.
Court: 7th Circuit, Judge: St. Eve, Filed On: March 15, 2024, Case #: 23-1931, Categories: Bankruptcy, Securities
J. St. Eve finds that the lower court properly convicted defendant of possession of marijuana and possession of a firearm as a felon. A jury could infer that defendant possessed the gun based on his responses to deputies' questions, and because it was in close proximity to him in the car on the day of the offense. Further, while defendant only acknowledged ownership of the bag with the drugs inside it, it is only logical that the second bag containing scales also belonged to him. Affirmed.
Court: 7th Circuit, Judge: St. Eve, Filed On: March 15, 2024, Case #: 23-1315, Categories: Drug Offender, Evidence
J. St. Eve finds that the lower court properly rejected the employee's employment retaliation claims at a jury trial. The court's jury instructions were not misleading, even if they asked the jury to question the employer's "belief" for firing the employee. Further, the court was within its discretion to deny the employee's for-cause challenge to a prospective juror based on an alleged bias against Black men. Affirmed.
Court: 7th Circuit, Judge: St. Eve, Filed On: March 8, 2024, Case #: 22-2619, Categories: Jury, Employment Retaliation
J. St. Eve finds that the lower court properly dismissed an Indiana citizen's Takings Clause claim based on the state's failure to pay interest accrued on property while it was in state custody. The specific relief sought in this case is now moot, as Indiana has since passed a law requiring payment of interest on all property recovered under the Revised Indiana Unclaimed Property Act. Further, the citizen cannot seek compensation in federal court from Indiana official defendants due to Eleventh Amendment immunity. Affirmed.
Court: 7th Circuit, Judge: St. Eve, Filed On: March 6, 2024, Case #: 23-1792, Categories: Constitution, Property, Immunity
J. St. Eve finds that the lower court properly applied a two-level sentencing enhancement for defendant's possession of a chewing tobacco can full of energetic powder, sealed with adhesive, and outfitted with a fuse. This "firework" qualifies as a destructive device for sentencing purposes on top of his possession of a firearm as a felon. Affirmed.
Court: 7th Circuit, Judge: St. Eve, Filed On: March 6, 2024, Case #: 23-1942, Categories: Firearms, Sentencing
J. St. Eve certifies three questions to the Illinois Supreme Court in a suit challenging the temporal limitations of the Workers' Occupational Diseases Act which provides workers' compensation for employees who contract a disease arising out of their employment, sometimes years or decades after that employment ends.
Court: 7th Circuit, Judge: St. Eve, Filed On: March 6, 2024, Case #: 23-2343, Categories: Civil Procedure, Workers' Compensation
J. St. Eve finds that the immigration board erred by reinstating an El Salvadoran citizen's removal order after he re-entered the U.S. because he feared he would be killed by gangs in his home country. The board "actively ignored" the evidence relied upon by the immigration judge who granted him asylum, and inappropriately reweighed the evidence rather than showing deference to the immigration judge's factual findings. Reversed.
Court: 7th Circuit, Judge: St. Eve, Filed On: February 27, 2024, Case #: 21-2284, Categories: Immigration
J. St. Eve finds that the lower court properly rejected defendant's habeas petition alleging his counsel was ineffective for failing to object to witness testimony that violated an Indiana evidentiary ruling. Counsel's failure was knowing and strategic, so it did not rise to the level of constitutionally deficient performance. Affirmed.
Court: 7th Circuit, Judge: St. Eve, Filed On: February 22, 2024, Case #: 22-2073, Categories: Habeas
[Consolidated.] J. St. Eve finds that the lower court properly found for the lead paint manufacturers in a series of toxic tort cases brought by 170 plaintiffs who allege injuries from exposure to white lead carbonate, a paint pigment. After plaintiffs in the first two waves of litigation met with defeat, the court correctly extended those rulings to the remaining plaintiffs on issue preclusion grounds. Affirmed.
Court: 7th Circuit, Judge: St. Eve, Filed On: February 9, 2024, Case #: 22-2636, Categories: Environment, Tort, Class Action
J. St. Eve finds that the lower court properly denied defendant's motion to suppress evidence of drugs, cash, and a gun in his apartment after detectives obtained a search warrant based on a tip he was dealing drugs out of his home. The lower court reasonably found the detectives' testimony credible and any misstatements in the affidavit, which was admittedly deficient, were not reckless or intentional. Affirmed.
Court: 7th Circuit, Judge: St. Eve, Filed On: January 12, 2024, Case #: 23-1057, Categories: Drug Offender, Evidence, Search
J. St. Eve finds that the lower court properly found for the County and dismissed a class action filed by pre-trial detainees alleging that the use of camera to record holding cell toilets infringed their Fourth Amendment privacy rights. The security risks inherent to the jail setting require the court to grant great deference to prison administrators' assessment of the security needs, such as addressing emergencies and monitoring detainees with behavioral or mental health problems. Affirmed.
Court: 7th Circuit, Judge: St. Eve, Filed On: December 18, 2023, Case #: 22-2863, Categories: Privacy, Class Action, Prisoners' Rights
J. St. Eve finds that the lower court properly held defendant in criminal contempt for his refusal to answer a prosecutor's question. Defendant took the stand to testify in his own defense, but then attempted to invoke the Fifth Amendment when the prosecutor questioned him. Defendant had already waived his Fifth Amendment right against self-incrimination when he chose to testify and could not validly refuse to answer questions relevant to his testimony. Affirmed.
Court: 7th Circuit, Judge: St. Eve, Filed On: December 18, 2023, Case #: 23-1303, Categories: Firearms, Contempt
J. St. Eve finds that the lower court properly ruled against the Black postal employee on allegations he was fired for discriminatory reasons. While the employee filed 15 EEOC charges against his supervisors, the evidence supports a finding he was fired for failing to appear at work for months. Affirmed.
Court: 7th Circuit, Judge: St. Eve, Filed On: December 15, 2023, Case #: 22-2472, Categories: Employment, Labor
J. St. Eve finds that the lower court properly denied defendant's motion to suppress medical staff's discovery of "something plastic" in his mouth while he was in the emergency room, prompting them to instruct him to spit it out for 20 minutes. When he finally did so, it was a device used to convert a firearm into a fully automatic weapon. Small interactions between hospital staff and the police officer posted outside defendant's hospital room do not transform the staff's actions into a warrantless government search. Affirmed.
Court: 7th Circuit, Judge: St. Eve, Filed On: November 16, 2023, Case #: 23-1108, Categories: Firearms, Search
J. St. Eve finds that the lower court properly ordered the defendant to be medicated as her delusions led her to believe that three current and former presidents sexually assaulted her, leading her to threaten to kill them, and she is currently unable to assist in her own defense. However, the court must provide a dosage range based on an expert's recommendation to provide a limit to the medical staff's discretion. Affirmed in part.
Court: 7th Circuit, Judge: St. Eve, Filed On: October 19, 2023, Case #: 23-1739, Categories: Threats, Commitment
J. St. Eve finds that the lower court properly found for the defendant city in a dispute with a rural water association over another city's decision to buy water from defendant city rather than the association. The association does not have a legal right to provide water to the purchasing city because its facilities are not designed to produce sufficient water under Illinois law. Affirmed.
Court: 7th Circuit, Judge: St. Eve, Filed On: August 8, 2023, Case #: 22-2942, Categories: Water, Contract
J. St. Eve finds that the lower court improperly found for the prison security director on an inmate's claims he was denied due process in a hearing that led to the seizure of $10,000 sent to him by a fellow inmate in gratitude for his help in a successful civil rights lawsuit against the prison. The director failed to recuse himself, despite his involvement in the underlying lawsuit, and made statements before and during the hearing suggesting a predetermined outcome. Reversed.
Court: 7th Circuit, Judge: St. Eve, Filed On: August 7, 2023, Case #: 21-1320, Categories: Civil Rights, Due Process, Prisoners' Rights
J. St. Eve finds that the district court properly denied a request by the Democratic Party of Illinois to intervene in a lawsuit against state voting officials. Litigants argue that a state law allowing extended counting of mail-in ballots violates federal law. The state Democratic party fails to point to any reason that the state’s representation of its interests may be inadequate. In addition, the district court’s focus on public time and resources over the political organization’s individual interests is not an abuse of judicial discretion. Affirmed.
Court: 7th Circuit, Judge: St. Eve, Filed On: July 27, 2023, Case #: 22-3034, Categories: Elections, Government
J. St. Eve finds that the district court properly ruled against a formerly imprisoned Rastafarian, barring his suit against Illinois corrections officials for the coerced shaving of his “unsearchable” dreadlocks. The former inmate, whose religious beliefs prohibit him from cutting his hair, acquiesced after the warden brought a tactical team and Mace to his cell and threatened to forcibly cut his hair. The former inmate concedes that his claim for injunctive relief is moot now that he is out of prison. He waived his claim for money damages from the prison officials in their official capacities without qualification. Pending “a fully developed” district court record, the appeal court declines to rule on whether a federal law concerning religious beliefs of institutionalized persons authorizes the formerly inmate to seek monetary damages from the prison officers in their individual capacities. Affirmed.
Court: 7th Circuit, Judge: St. Eve, Filed On: July 26, 2023, Case #: 22-2342 , Categories: Civil Rights, Constitution, Damages
J. St. Eve finds that the lower court improperly dismissed a prisoner's claims against a prison kitchen supervisor, individually, after he suffered severe burns from tripping while carrying a bucket of boiling water across the damaged kitchen floor. The dangerous floor condition, plus the supervisor's order requiring the prisoner to carry scalding water across it, may given rise to a potential Eighth Amendment claim against the supervisor who was present while inmates were carrying hot water in this manner and must have been aware of the danger. Reversed in part.
Court: 7th Circuit, Judge: St. Eve, Filed On: July 14, 2023, Case #: 21-2393, Categories: Constitution, Prisoners' Rights
J. St. Eve finds that the lower court properly found for the Catholic school on discrimination claims stemming from its firing of guidance counselor for marrying another woman. The counselor clearly worked in a ministerial role, sharing her own spiritual experiences and conveying religious teachings to young people seeking direction. Therefore, the misterial exception bars this suit. Affirmed.
Court: 7th Circuit, Judge: St. Eve, Filed On: July 13, 2023, Case #: 22-2954, Categories: Employment Discrimination, First Amendment
J. St. Eve finds that the lower court properly found for the police officers on a man's unlawful entry and excessive force claims stemming from a wellness check where police Tased him twice and gave him a concussion. A jury reasonably found that exigent circumstances justified warrantless entry through the doorway due the man's violence towards his mother and lack of cooperation with police. Affirmed.
Court: 7th Circuit, Judge: St. Eve, Filed On: July 11, 2023, Case #: 22-2757, Categories: Civil Rights, Immunity, Police Misconduct
J. St. Eve finds that the lower court improperly considered defendant's habeas petition on the merits when precedent holds that federal courts lack jurisdiction to consider habeas petitions filed by federal prisoners asserting an intervening change in statutory interpretation in an attempt to circumvent the restrictions on successive petitions. Vacated.
Court: 7th Circuit, Judge: St. Eve, Filed On: July 7, 2023, Case #: 22-2182, Categories: Criminal Procedure, Habeas