The case involved Michael Parish's appeal of the dismissal of his federal lawsuit against the City of Chicago and several detectives, in which he asserted a claim under 42 U.S.C. § 1983 for malicious prosecution in violation of the Fourth Amendment after his acquittal on murder charges. Parish alleged that officers had fabricated evidence and suppressed exculpatory material, but he conceded at the district court level that Seventh Circuit precedent foreclosed the claim. The Seventh Circuit affirmed the dismissal, holding that its earlier decision in Newsome v. McCabe remains controlling because Illinois provides a state-law remedy for malicious prosecution, and a footnote in Wallace v. Kato does not require reconsideration of that precedent. The court noted that other potential constitutional theories, such as a Brady due-process claim, were not pursued on appeal.
In United States v. Badayah Brazelton, police arrested the defendant after a shooting and obtained a warrant to search his home, where they found firearms and drugs leading to his conviction on two gun charges under 18 U.S.C. § 924 and three drug charges under 21 U.S.C. § 841. The defendant argued on appeal that his conviction should be reversed because one juror was a relative of the shooting victim, but the court held that he had expressly waived any challenge to that juror during voir dire and jury selection. The court affirmed the conviction on the basis of this waiver but remanded the case for resentencing, agreeing with the parties that the district court should have the opportunity to consider a below-guidelines sentence in light of Kimbrough v. United States regarding the crack-to-powder cocaine ratio.
The case involved Badayah Brazelton, who was arrested after a shooting but convicted by a jury on two firearm offenses under 18 U.S.C. § 924 and three drug possession offenses under 21 U.S.C. § 841 based on guns and drugs found during a search of his home. Brazelton appealed his conviction, arguing that one juror was related to the shooting victim and thus biased, and he also challenged his 425-month sentence on the ground that the district court lacked discretion to vary from the guidelines due to the crack-to-powder cocaine ratio. The Seventh Circuit affirmed the conviction, holding that Brazelton had expressly waived any challenge to the juror during voir dire by declining two opportunities to strike the juror for cause. The court remanded for resentencing, agreeing with the parties that Kimbrough v. United States permitted the district court to consider a below-guidelines sentence based on disagreement with the crack-powder disparity.
In United States v. Badayah Brazelton, the defendant was arrested after being identified as the shooter in an incident, and a subsequent search of his home pursuant to a warrant uncovered firearms, crack cocaine, marijuana, and related paraphernalia. He was convicted by a jury on two gun-related counts under 18 U.S.C. § 924 and three drug possession counts under 21 U.S.C. § 841, receiving a 425-month sentence. On appeal, the Seventh Circuit affirmed the conviction, holding that Brazelton had waived any claim of juror bias by explicitly declining to challenge for cause a juror who was a relative of the shooting victim, despite knowing of the relationship during voir dire. The court remanded for resentencing, however, because the district court had not considered its discretion to vary from the guidelines based on the crack-to-powder cocaine ratio following Kimbrough v. United States.
The case involves Darryl Allen's federal habeas appeal challenging his Illinois armed robbery conviction on grounds of ineffective assistance of trial and appellate counsel. Allen contended that his trial lawyer improperly elicited testimony from a detective about Allen's post-arrest silence after Miranda warnings, and that appellate counsel failed to raise this issue on direct appeal. The Seventh Circuit affirmed the denial of habeas relief, concluding that even if counsel's performance was deficient, Allen suffered no prejudice because the evidence of guilt—including the victim's identification, a surveillance video, and evidence of flight—was overwhelming. The court noted the first trial ended in a mistrial but held the state courts reasonably applied Strickland v. Washington in finding no prejudice on the full record.
The case involved Victor Dean, who was charged with being a felon in possession of a firearm after police found stolen guns and heroin in his home following his arrest on outstanding warrants. Dean moved to suppress the evidence, arguing the search was conducted without his consent, but the district court credited the officers' testimony that he had orally consented and denied the motion. Dean then sought to reconsider based on claims of ineffective assistance by his attorney, which the court also denied. On appeal, the Seventh Circuit affirmed, holding that the district court did not abuse its discretion in its credibility determinations or in finding that any deficiencies in counsel's performance did not prejudice Dean, as the outcome depended on resolved credibility issues.