The case involved Cornelius M. Jackson, who was convicted by a jury of four counts of sex trafficking and one count of conspiracy to commit sex trafficking. Jackson appealed, arguing that the search warrant for his residence lacked probable cause, that the supporting affidavit contained material omissions warranting a Franks hearing, and that the government's expert witness on sex trafficking dynamics should not have been permitted to testify. The Seventh Circuit affirmed the district court's judgment, holding that the affidavit provided sufficient probable cause based on the victim's detailed account of coercion, threats, and forced commercial sex acts, that any omissions were not material, and that the expert testimony was admissible under Rule 702 and Daubert because it helped explain victim behavior without addressing case specifics. The court further noted that any error in admitting the testimony would have been harmless given the other overwhelming evidence, including victim testimony, digital records, and video footage.
The case involved the conviction of Cornelius M. Jackson on four counts of sex trafficking and one count of conspiracy to commit sex trafficking after a jury trial in federal district court. Jackson appealed, arguing that the search warrant for his residence lacked probable cause, that he was entitled to a Franks hearing due to material omissions in the supporting affidavit regarding a victim's initial statements to police, and that the government's expert witness on sex trafficking victim behavior should not have been allowed to testify. The Seventh Circuit affirmed the district court's judgment, holding that the affidavit provided sufficient probable cause based on the victim's detailed account of coercion and control, that the omitted details were not material to the probable cause determination, and that the expert testimony was properly admitted under Federal Rule of Evidence 702 and Daubert standards with any potential error being harmless given the other overwhelming evidence of guilt including victim testimony, electronic records, and video footage.
The case involved a dispute between Peters Broadcast Engineering, a telecommunications company, and PEM Consulting Group and its owner Philip Miller over an alleged subcontracting arrangement for cell tower construction work under a master services agreement with Crown Castle. Peters Broadcast claimed there was an enforceable agreement for PEM to provide crews and equipment, but no final written contract was executed, and disputes arose over payments and communications with Crown Castle. The district court granted summary judgment to the defendants on all claims, including breach of contract, negligent misrepresentation, and tortious interference with business relations. The Seventh Circuit affirmed, reasoning that the parties had only exchanged proposals without reaching a binding agreement, that Miller's statements did not constitute professional advice, and that PEM had a legitimate justification for contacting Crown Castle to seek payment for completed work.
Raymond Echevarria sued police officers and the Forest Preserve District under 42 U.S.C. § 1983, alleging that his detention, citation for public indecency, and the towing of his vehicle violated the Fourth Amendment, and that the officers' conduct amounted to intentional infliction of emotional distress under Illinois law. The district court granted summary judgment to the defendants, and the Seventh Circuit affirmed. The court held that the officer had probable cause to detain and cite Echevarria because he matched the detailed description provided by a complainant in an area known for such activity, and that the same information supported towing the vehicle under the applicable ordinance as it was used in a qualified violation. The Monell claim against the district failed due to the absence of an underlying constitutional violation. The IIED claim also failed because the officers' statements, though unprofessional, did not rise to the level of extreme and outrageous conduct required under Illinois precedent.
Alma Sanchez sued El Milagro, Inc. under Title VII of the Civil Rights Act and the Illinois Human Rights Act, alleging sexual harassment by a coworker at a tortilla factory and the employer's failure to promptly investigate her complaints. The district court granted summary judgment for the employer, and the Seventh Circuit affirmed. The court concluded that Sanchez's reports to her supervisor were too vague or inconsistent to provide the employer with enough information to reasonably suspect sexual harassment, precluding liability. The opinion also highlighted ambiguities in the timing and descriptions of the alleged incidents that supported the grant of summary judgment.
In this section 1983 case, plaintiff Marwan Mahajni sued two Wisconsin court deputies, claiming they violated his constitutional rights during jury deliberations in his state criminal trial by instructing the jury that it must reach a unanimous verdict and could not deadlock or hang. The district court denied qualified immunity to the deputy who spoke to the jury and denied it without prejudice to the second deputy, who was present but did not speak or intervene, inviting further arguments at summary judgment. On appeal by the second deputy, the Seventh Circuit held that the district court's ruling was not a final adjudication of qualified immunity, so no appeal lay under the collateral order doctrine. The court therefore dismissed the appeal for lack of appellate jurisdiction, noting that the factual record required no further development and that qualified immunity questions should be resolved at the earliest stage.