Justia Civil Rights Opinion Summaries

Hill, an African American, began working for the General Services Administration in 2008 through the Federal Career Intern Program. Realizing that his Master’s degree entitled him to a higher pay rate, he filed a complaint with the EEOC. The parties settled. Hill maintains that he acted professionally during his one-year probationary period. His coworkers complained to supervisors about Hill’s temper on three occasions. A supervisor told Hill that his “stomping around” and slamming doors could be seen as threatening because he was a “pretty big guy,” which Hill took as a coded racial reference. After his probation, Hill was fired, based on those three incidents. Hill sued under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e to 2000e-17, for race discrimination, gender discrimination, and retaliation for filing an EEOC complaint. The district court granted summary judgment to GSA, stating that Hill was not meeting legitimate expectations because he had engaged in a pattern of behavior that led three different coworkers to report him to their supervisors, and that a white female intern was not a suitable comparator because only one coworker had ever complained about her behavior, nor had Hill established pretext. The Seventh Circuit affirmed. View "Anthony Hill v. Martha Johnson" on Justia Law

In 2007, Williams was pulled over for allegedly running a stop sign. Because he had no proof of insurance, he and his car were taken to a Chicago police station. The next day, officers approached Williams on the street and claimed that he had wrongfully taken his car from the station the previous night. Williams claimed that one of the officers said he could take the car and gave him the keys. The officers sought to tow his car; Williams resisted. According to Williams, the officers beat him repeatedly; after he was handcuffed and taken to the station, the physical abuse continued. Williams sued the officers for false arrest and excessive force, 42 U.S.C. 1983. . The trial was largely a credibility contest; defendants presented evidence that Williams had committed seven drug or gun felonies in the last 10 years. The Seventh Circuit affirmed a verdict in favor of defendants, rejecting an argument that the district court erred in allowing in evidence of his prior convictions under Federal Rule 609, because it did not articulate a probative-prejudice balancing analysis. Williams did not ask the court to perform the balancing test. View "Williams v. Dieball" on Justia Law

Hawkins has a long history of violent crimes, gun offenses, escapes, drug use, and violations of supervised release. In 2003 he assaulted U.S. marshals and pleaded guilty to violent assault with a weapon that inflicted bodily injury, 18 U.S.C. 111(a)(1), (b), 1114. The guidelines range would have been under 30 months, but with two prior felony convictions for “walkaway” escape, 18 U.S.C. 751(a), the range was 151 to 188 months. At the time, the guidelines were mandatory; two years later the Supreme Court declared them advisory. On remand the judge reimposed the 151-month sentence. The Seventh Circuit affirmed. Three years later the Supreme Court held that walkaway “escape” is not a “violent felony” under the Armed Career Criminal Act, 18 U.S.C. 924(e). The district court denied a motion to set aside the sentence reasoning that the legal error committed in deeming such an escape a violent felony was not the kind of error that can be corrected after a criminal judgment has become final. The Seventh Circuit affirmed, noting that Hawkins’ history would justify reimposing the sentence again. The court found that rehearing was not warranted by the Supreme Court’s subsequent decision in Peugh v. United States, (2013), reasoning that, unlike this case, Peugh involved constitutional error: violation of the ex post facto clause. View "Hawkins v. United States" on Justia Law

Adeyeye, a native of Nigeria, moved to the U.S. in 2008. He requested several weeks of unpaid leave so he could travel to Nigeria to lead his father’s burial rites. He explained that his participation in the funeral ceremonies was “compulsory” and that if he failed to lead the burial rites, he and his family members would suffer at least spiritual death. The employer denied the request, but he traveled to Nigeria for the ceremonies anyway and was fired when he returned to work. Adeyeye filed suit under Title VII of the Civil Rights Act of 1964 for failure to accommodate his religion. The district court granted summary judgment for the employer, finding that Adeyeye’s two written requests did not present evidence sufficient for a reasonable jury to find that he had provided notice of the religious character of his request. The Seventh Circuit reversed. Whether or not Adeyeye’s letters might have justified holding as a matter of law that they provided sufficient notice of the religious nature of his request, they certainly were sufficient to present a genuine issue of material fact regarding whether the employer had notice of the religious nature of the request. View "Adeyeye v. Heartland Sweeteners, LLC" on Justia Law

Estremera was convicted of conspiring to distribute cocaine plus possessing a firearm despite an earlier felony conviction and sentenced to life imprisonment. The Seventh Circuit affirmed in 2007. Estremera sought collateral relief under 28 U.S.C. 2255, claiming that his lawyer had misstated the terms of a plea bargain proposal. The district court denied the petition in 2012 without holding a hearing. The Seventh Circuit reversed. There was insufficient evidence to determine whether the petition was timely, given Estremera’s assertions of his own diligence and of abandonment by counsel. With respect to Estremera’s request that the prosecution be required to offer the original deal again, the court noted that it no longer possible for the defendant to fulfill promises that would have been valuable to the prosecutor, had a deal been struck before trial and that, assuming that it proceeds to the merits, the district court may think it prudent to await the Supreme Court’s opinion in Titlow before crafting a remedy. View "Estremera v. United States" on Justia Law

In 2002, Taylor was convicted on eight counts for initiating inappropriate relationships with children. After trial, Taylor’s retained attorney withdrew. With new counsel, Taylor moved for a new trial, alleging a variety of errors including ineffective assistance of counsel. The trial court agreed and vacated four counts, noting counsel’s failure to impeach or even cross-examine some witnesses. The Illinois Appellate Court affirmed the remaining convictions and the Illinois Supreme Court rejected a Petition for Leave to Appeal in 2004. Seeking state post-conviction relief, Taylor argued that trial counsel represented him while simultaneously under indictment for bribery Illinois, on four felony bribery charges. The Illinois Appellate Court affirmed dismissal of the petition. Continuing to have trouble with attorneys he hired, Taylor turned to an online group, ACDG, which found attorneys to represent him in continuing appeals. Taylor claims that one of those attorneys gave him incorrect information about the deadline for filing a petition of habeas corpus in federal court. When ACDG confirmed to Taylor that it would not represent him in federal post-conviction review, Taylor filed a pro se petition, which was dismissed. The Seventh Circuit affirmed, stating that Taylor does not meet the standard for equitable tolling.View "Taylor v. Dexhiemer" on Justia Law

Plaintiff, a pretrial detainee in a maximum-security tier of Chicago’s Cook County Jail, sued a guard, Anderson, under 42 U.S.C. 1983, alleging that Anderson failed to protect him from an attack by other inmates. Plaintiff claimed that Anderson had released the inmates from their cells and allowed them to congregate in a dark corridor, where the attack occurred, and that Anderson left her post after doing so. The district judge granted summary judgment in favor of Anderson, refusing to allow plaintiff to testify that he overheard prisoners in the dayroom ask Anderson to let the prisoners in the other half of the tier out of their cells so that they could go to the dayroom too. The Seventh Circuit reversed and remanded, stating a jury could draw an inference of deliberate indifference and that the proffered testimony was not inadmissible hearsay. Plaintiff sought to testify to what he heard, not to the truth of anything said. The court also criticized the judge’s refusal to request assistance of counsel for the plaintiff. View "Junior v. Anderson" on Justia Law

After working at the company for four months, Benes charged his employer with sex discrimination. The EEOC arranged for mediation in which, after an initial joint session, the parties separated and a go-between relayed offers. Upon receiving a settlement proposal that he thought too low, Benes stormed into the room used by his employer’s representatives and said loudly: “You can take your proposal and shove it up your ass and fire me and I’ll see you in court.” The firm fired him. He filed suit under the anti-retaliation provision of Title VII of the Civil Rights Act, 42 U.S.C. 2000e–3(a), abandoning his claim of sex discrimination. A magistrate judge granted the employer summary judgment, finding that Benes had been fired for misconduct during the mediation, not for making or supporting a charge of discrimination. The Seventh Circuit affirmed, stating that section 2000e–3(a) does not establish a privilege to misbehave in mediation, but only bans retaliation “because [a person] has opposed any practice made an unlawful employment practice by this subchapter, or because he has made a charge, testified, assisted, or participated in any manner in an investigation, proceeding, or hearing under this subchapter.” View "Benes v. A.B. Data, Ltd." on Justia Law

Blake was indicted for conspiracy to distribute and possess cocaine, 21 U.S.C. 846 and retained attorney Fabbri, not knowing that Fabbri was under investigation. Trial was set for January 9, 2007, within the 70 days required by the Speedy Trial Act, 18 U.S.C. 3161. Killian, prosecutor in the Blake case, had little knowledge of the Fabbri investigation, because he and others in his district had been “screened off” to avoid conflicts of interest. At a final pretrial conference, Blake objected to, and Fabbri withdrew, a motion for continuance. Killian then learned that an indictment of Fabbri was imminent and withdrew from Blake’s prosecution. Fabbri successfully moved to withdraw. Following a bond hearing, several discovery motions by the defense, notice of intent to seek a sentencing enhancement, a conflict of interest hearing, a superseding indictment adding two narcotics-related offenses (two days before trial), and other motions, Blake withdrew consent to a previously-requested continuance and waived the 30-day allotment of time to prepare for trial on the new charges. Trial commenced on March 27; Blake was convicted on all counts. Following unsuccessful appeal, Blake timely filed a habeas petition. The district court denied the petition. The Seventh Circuit affirmed, rejecting claims of ineffective assistance View "Blake v. United States" on Justia Law

Lambert, an African-American was hired as a laborer at a Peri distribution yard in 2003. Lambert claims that co-workers and supervisors often made sexually and racially offensive comments. He complained regularly, but supervisors took no action. Nonetheless, Lambert was promoted to a lead position. One day, Lambert’s supervisors observed him behaving in an unusually aggressive manner and ordered him to take a drug and alcohol test. The test revealed that he was intoxicated. He was immediately fired under Peri’s “no tolerance” policy toward consuming alcohol on the job, an important policy for safety in a yard where workers operate heavy machinery and maneuver large concrete objects. Lambert attributed Peri’s decision to terminate his employment to racial discrimination and retaliation for his complaints. The district court rejected his claims on summary judgment. The Seventh Circuit remanded. There was insufficient evidence that Lambert’s race motivated Peri’s decision to test for intoxication or to fire him, but the court acted prematurely in dismissing claims of sexual and racial harassment. A jury could find that he was subjected to a hostile work environment on account of race or sex, and that he took all necessary steps to call his treatment to the company’s attention. View "Lambert v. Peri Formworks Sys. Inc." on Justia Law