Court: United States Court of Appeals for the Seventh Circuit

Filed: 2026-08-13

The seventh-circuit affirmed the convictions and sentences of three defendants—Nawomi Awoga, Marina Oke, and Assiba Lea Fandohan—for conspiracy to harbor unauthorized aliens, harboring unauthorized aliens in violation of 8 U.S.C. § 1324(a)(1)(A)(iii), and forced labor in violation of 18 U.S.C. § 1589. The court held that the evidence presented at trial was sufficient to support the jury’s guilty verdicts, rejecting the defendants’ arguments regarding the credibility of the two minor victims who testified about being lured from Benin under false pretenses and subsequently subjected to physical abuse, forced labor, and confinement. Applying a de novo standard of review for sufficiency of the evidence, the court emphasized that it must view the trial record in the light most favorable to the verdict and defer to the jury’s credibility determinations, noting that any inconsistencies in the victims’ testimonies were fully aired during vigorous cross-examination and did not render the testimony incredible as a matter of law. The court further found that the evidence reasonably supported an inference that the defendants intended to shield the victims from detection by authorities through acts such as providing false travel documents, instructing the girls to hide from law enforcement, and restricting their movement. Regarding the sentences, the court applied an abuse of discretion standard under 18 U.S.C. § 3553(a) and found no error in the district court’s imposition of terms ranging from 80 to 102 months, which were either within or below the applicable Sentencing Guidelines ranges. The appellate court concluded that the district judge adequately considered all relevant sentencing factors, including the defendants’ lack of criminal history and age, while balancing them against aggravating circumstances such as the number of minor victims, the duration of the criminal conduct, and the defendants’ leadership roles. The court specifically rejected the argument that “cultural norms” from Benin should mitigate culpability, stating that by choosing to reside in the United States, the defendants subjected themselves to American laws. As a result of this decision, the judgments of conviction and the imposed prison terms remain in effect, and the defendants must serve their sentences followed by three years of supervised release.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.

Court: United States Court of Appeals for the Seventh Circuit

Filed: 2026-08-13

The seventh-circuit affirmed the district court’s grant of summary judgment in favor of the police officers against Jevarreo Kelley-Lomax’s civil rights claims for false arrest and malicious prosecution under 42 U.S.C. § 1983. The court held that probable cause existed to support both claims, which serves as a complete defense. Regarding the false arrest claim, the court applied the standard that probable cause exists when facts and circumstances within an officer’s knowledge are sufficient to support a reasonable belief that a suspect has committed a crime. The court determined that the officers had probable cause to arrest Kelley-Lomax for aggravated unlawful use of a weapon because he was found in the front passenger seat of a vehicle where a loaded handgun was discovered underneath his seat, and he admitted to lacking a firearm license. The court rejected the argument that proximity alone is insufficient for possession, noting that while mere presence might not suffice for a criminal conviction beyond a reasonable doubt, it can support the lower threshold of probable cause, particularly under Illinois’s theory of joint constructive possession where exclusive control is not required if others have sufficiently close access to the contraband. Regarding the malicious prosecution claim, the court applied the *Beauchamp* test, which requires a plaintiff to show that officers fabricated or omitted material information and that such fabrication was necessary to establish probable cause. While the court acknowledged a factual dispute suggesting the officers may have recklessly made false statements regarding 911 caller descriptions and surveillance video content during the grand jury proceeding (satisfying the first prong of the test), it ruled that probable cause remained even after removing the alleged fabrications. The undisputed facts—the discovery of the gun under Kelley-Lomax’s seat and his lack of a license—were sufficient to establish probable cause to prosecute him for unlawful possession. The court reasoned that defenses regarding knowledge or ownership, which may have led to his acquittal at trial, do not negate the existence of probable cause at the time of prosecution. The practical consequence is that the judgment in favor of the City of Chicago and the officers is upheld, and Kelley-Lomax’s lawsuit is dismissed without proceeding to a jury trial on these claims.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.

Court: United States Court of Appeals for the Seventh Circuit

Filed: 2026-08-13

The Seventh Circuit affirmed the convictions and sentences of Marina Oke, Nawomi Awoga, and Assiba Lea Fandohan for conspiracy to harbor and shield unauthorized aliens, harboring and shielding unauthorized aliens in violation of 8 U.S.C. § 1324(a)(1)(A)(iii), (B)(i), and forced labor in violation of 18 U.S.C. § 1589. The court held that the evidence was sufficient to support the jury’s guilty verdict, rejecting the defendants’ arguments that the victims’ testimonies were incredible as a matter of law or insufficient to prove intent to conceal the victims from authorities. Applying a de novo standard of review for sufficiency of the evidence while giving great deference to the jury’s credibility determinations, the court found that the jury could reasonably infer intent to harbor based on the defendants’ affirmative acts of concealment, including instructing the victims to hide from law enforcement, restricting their movement, and shuffling them between homes after police inquiries. The court further affirmed the application of the statutory financial-gain enhancement under 8 U.S.C. § 1324(a)(1)(B)(i), noting that the defendants derived substantial economic benefit from the victims’ unpaid labor. Regarding sentencing, the court applied an abuse of discretion standard and found no error in the district court’s imposition of within-guidelines and below-guidelines sentences under 18 U.S.C. § 3553(a). The appellate court concluded that the district judge adequately considered all relevant mitigating and aggravating factors, including the defendants’ ages, lack of criminal history, and the severe nature of the abuse inflicted on two minor victims, and properly declined to treat Beninese cultural norms as a mitigating factor for conduct violating U.S. law. Consequently, the judgments of the district court are affirmed, and the defendants remain subject to their respective prison terms and terms of supervised release.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.

Court: United States Court of Appeals for the Seventh Circuit

Filed: 2026-08-13

The Seventh Circuit reversed the district court’s dismissal of Reginald Chapman’s § 1983 complaint challenging the facial constitutionality of Illinois post-conviction DNA testing statute 725 Ill. Comp. Stat. 5/116-3 under the Fourteenth Amendment’s Due Process Clause and the Sixth Amendment’s right to a jury trial. The court held that Chapman possesses Article III standing because his injury—the denial of access to evidence for DNA testing—is fairly traceable to the defendant, Cook County State’s Attorney Eileen O’Neill Burke, who controls the evidence and denied his request based on the challenged statute, regardless of her subsequent agreement to testing. Furthermore, the court ruled that the Rooker-Feldman doctrine does not divest the district court of subject matter jurisdiction because Chapman is not seeking to review or reverse the Illinois state court’s judgment denying his motion; rather, he is asserting an independent claim challenging the constitutionality of the underlying state statute itself. Consequently, the case was remanded to the district court for further proceedings consistent with this opinion, allowing the merits of the constitutional challenge to be addressed.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.

Court: United States Court of Appeals for the Seventh Circuit

Filed: 2026-08-13

The seventh-circuit reversed the district court’s dismissal of Reginald Chapman’s § 1983 complaint challenging the facial constitutionality of Illinois’s post-conviction DNA testing statute, 725 Ill. Comp. Stat. 5/116-3. The court held that Chapman possesses Article III standing to sue the Cook County State’s Attorney because his injury—the denial of access to evidence for DNA testing—is fairly traceable to the prosecutor’s control over and refusal to release the evidence, regardless of whether the prosecutor personally agreed to testing. Furthermore, the court ruled that the Rooker-Feldman doctrine does not divest the federal district court of subject matter jurisdiction. Applying the standard established in *Skinner v. Switzer* and *Reed v. Goertz*, the court determined that Chapman’s claim is an independent constitutional challenge to the statute itself under the Fourteenth Amendment’s Due Process Clause and the Sixth Amendment’s right to a jury trial, rather than a suit inviting federal review of the state court’s judgment denying his specific motion. Consequently, the case was remanded for further proceedings consistent with this opinion, allowing Chapman’s facial constitutional challenge to proceed in federal court.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.

Court: United States Court of Appeals for the Seventh Circuit

Filed: 2026-08-13

The Seventh Circuit affirmed the district court’s dismissal of Plaintiffs’ breach of contract and professional negligence claims against Aon Risk Services Companies, Inc. The court held that Clarendon America Insurance Company was not a third-party beneficiary of the 1996 and 1999 agreements between Aon and SCB because the contracts lacked explicit language or strong implications demonstrating an intent to confer a direct benefit on Clarendon rather than merely an incidental one. Regarding the professional negligence claim, the court ruled that under Illinois law, insurance brokers owe no duty to non-insured third parties to notify an insured’s carriers of claims made by those third parties against the insured. Additionally, the court determined that even if the claims were viable, they were time-barred under the two-year statute of limitations for actions against insurance producers in Illinois, as the alleged breaches occurred in 1999 and Plaintiffs had inquiry notice of the potential injury by 2012. Consequently, the judgment granting summary judgment to Aon and dismissing the negligence claim is affirmed.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.

Court: United States Court of Appeals for the Seventh Circuit

Filed: 2026-08-13

The Seventh Circuit affirmed the convictions and sentences of three defendants—Nawomi Awoga, Marina Oke, and Assiba Lea Fandohan—who were found guilty of conspiracy to harbor and shield unauthorized aliens, harboring and shielding unauthorized aliens under 8 U.S.C. § 1324(a)(1)(A), and forced labor under 18 U.S.C. § 1589. The court held that the evidence presented at trial was sufficient to support the jury’s verdict, specifically rejecting the defendants’ challenges regarding the credibility of the two minor victims who testified about being lured from Benin with false promises of education and work, only to be subjected to forced labor, physical abuse, and confinement in the United States. The court applied a deferential standard of review for sufficiency of the evidence, viewing the trial record in the light most favorable to the government and reversing only if no rational trier of fact could have found the defendants guilty beyond a reasonable doubt. The court reasoned that it is the exclusive function of the jury to determine witness credibility, particularly when cross-examination has fully aired inconsistencies and potential motives for fabrication, such as the victims’ receipt of T-visas and government benefits. The court found no “incredible as a matter of law” testimony and concluded that the jury could reasonably infer the requisite intent to conceal the victims from authorities based on evidence of falsified documents, instructions to hide from law enforcement, restrictions on movement, and the shuffling of one victim to different locations after police inquiries. Additionally, the court affirmed the application of the statutory financial-gain enhancement under 8 U.S.C. § 1324(a)(1)(B)(i), finding ample evidence that the defendants benefited from the victims’ unpaid labor in their homes and hair salon. Regarding the sentences, the court applied an abuse of discretion standard to review the substantive reasonableness of the terms imposed, which ranged from 80 months to 102 years (within or below the applicable Sentencing Guidelines ranges). The court held that the district court did not abuse its discretion because it adequately considered the factors set forth in 18 U.S.C. § 3553(a), including the defendants’ lack of criminal history and age, while balancing them against the aggravating circumstances of multiple minor victims, the prolonged nature of the conduct, and the defendants’ leadership roles. The court explicitly rejected the argument that “cultural norms” from Benin should mitigate the sentences, noting that the defendants chose to reside in the United States and are subject to its laws. Consequently, the judgment of the district court is affirmed, and the defendants remain subject to their respective prison terms and supervised release.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.

Court: United States Court of Appeals for the Seventh Circuit

Filed: 2026-08-13

The Seventh Circuit reversed the district court’s judgment, holding that the district court erred in denying the defendant’s motion to correct his sentence under 18 U.S.C. § 3582(c)(2). The court ruled that the defendant was eligible for a sentence reduction because he had been sentenced based on sentencing guidelines that were subsequently amended by Amendment 706, which lowered the base offense levels for certain drug trafficking offenses involving crack cocaine. Under the statutory framework of 18 U.S.C. § 3582(c)(2) and United States Sentencing Guidelines § 1B1.10, a defendant may receive a reduced sentence if the amendment lowers the applicable guideline range and the reduction is consistent with the policy statements in § 1B1.10. The court applied the “first step” analysis required by *United States v. Booker* and subsequent circuit precedent to determine eligibility. It found that Amendment 706 was a “substantive change” rather than merely an interpretation of existing law, thereby satisfying the requirement that the amendment lower the defendant’s guideline range. The district court had incorrectly concluded that the defendant was ineligible because his original sentence was based on a statutory mandatory minimum that remained unchanged; however, the Seventh Circuit clarified that eligibility for a reduction exists whenever the advisory guidelines are lowered, regardless of whether a statutory mandatory minimum prevents the actual imposition of a lower sentence at that specific moment. The court further noted that the district court failed to properly consider the defendant’s request for a reduction based on the “extraordinary and compelling reasons” standard or the specific eligibility criteria under § 3582(c)(1)(A) in conjunction with the guideline amendment. Consequently, the practical consequence is that the case is remanded to the district court for further proceedings consistent with this opinion. The district court must reconsider the defendant’s motion to correct his sentence, determining whether a reduction is appropriate based on the amended guidelines and the factors set forth in 18 U.S.C. § 3553(a), while ensuring that any new sentence does not exceed the statutory maximum or fall below the applicable mandatory minimum where such constraints exist. The reversal mandates a fresh evaluation of the defendant’s eligibility and the appropriateness of a reduced sentence under the corrected guidelines.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.

Court: United States Court of Appeals for the Seventh Circuit

Filed: 2026-08-13

The seventh-circuit dismissed Aisha Putnam’s challenges to various trial-related rulings for failure to provide complete trial transcripts necessary to assess prejudice, and affirmed the district court’s summary judgment ruling on her Food Safety Modernization Act (FSMA) retaliation claim as well as the dismissal of her common law retaliatory discharge claim. The court applied the four-element framework for whistleblower retaliation claims under the FSMA, requiring a plaintiff to prove: (1) engagement in protected activity; (2) employer knowledge of that activity; (3) an unfavorable personnel action; and (4) that the protected activity was a contributing factor in the adverse action. Regarding the FSMA claim based on emails sent to the FDA, the court affirmed summary judgment because Putnam failed to present evidence that any decisionmaker at CaramelCrisp had actual knowledge of her anonymous complaints, which is a threshold requirement for establishing causation. The court further held that the district court did not abuse its discretion in refusing to allow Putnam to assert a new retaliation theory based on the defendant’s trade secrets lawsuit after she had previously argued those cases were distinct and during the trial phase. Regarding the common law claim, the court affirmed the dismissal without deciding whether Illinois law permits such a claim when an adequate statutory remedy exists. The court reasoned that because the jury found under the FSMA’s “contributing factor” standard—which is a lower causation threshold than the “because of” standard required for common law claims—that Putnam’s complaints were not a contributing factor in her termination, she cannot relitigate the issue to meet the higher common law standard. The practical consequence is that the judgment in favor of CaramelCrisp stands; Putnam’s appeal regarding trial errors is dismissed due to an incomplete record, and her substantive claims are affirmed based on the jury’s verdict and the lack of evidence regarding employer knowledge.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.

Court: United States Court of Appeals for the Eighth Circuit

Filed: 2026-08-13

The eighth-circuit held that the district court plainly erred by imposing a supervised release condition authorizing the Probation Office to require the defendant to perform up to 20 hours of community service per week if unemployed, without providing any justification for exceeding the U.S. Sentencing Guidelines policy statement cap of 400 hours found in USSG § 5F1.3, comment. (n.1). The court applied the plain error standard and relied on its recent precedents in *United States v. Hinkeldey* and *United States v. Redmon*, which establish that a district court must explain why a specific defendant requires more community service than the generality of defendants to exceed the 400-hour threshold. The court determined the issue was ripe for review because, as in *Redmon*, the defendant faced imminent hardship given his scheduled release in December 2026 and the lack of appointed counsel if he were to later seek modification. Consequently, the court remanded the case to the district court with directions to reconsider whether to reimpose the 20-hour-per-week condition or to fashion an alternative option that accounts for the § 5F1.3 policy statement regarding the generally appropriate 400-hour cap.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.