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Decision levers
AI-measured from their own opinions — each lever cites its cases
PurposivismTextualism
Opinions [1] and [2] parse 11 U.S.C. §§ 1322, 1325, and 1326 by their express terms to require priority payments before unsecured creditors, rejecting purposive arguments that would alter the 2005 BAPCPA amendment. City of Chicago v. Ahmed Alayah ↗ City of Chicago v. Stephen Falkn… ↗
Living constitutionalismOriginalism
Opinion [4] applies the Press-Enterprise II experience-and-logic test by reference to historical practice since the mid-nineteenth century rather than evolving standards. Associated Press v. Ron Neal ↗
In United States v. Fernando D. Bolden, the defendant, a convicted felon, was charged with federal firearms offenses after Milwaukee police executed a search warrant at a residence and recovered guns, ammunition, fentanyl, cocaine, and cash. Bolden conditionally pleaded guilty but preserved his challenge to the warrant, arguing it lacked probable cause to connect him to the address and contained material misrepresentations or omissions in the supporting affidavit. The district court found probable cause questionable but upheld the search under the good-faith exception to the exclusionary rule, and the Seventh Circuit affirmed the convictions. The appeals court held that the officers reasonably relied on the warrant issued by a neutral judge, as the affidavit established Bolden’s access to the home through surveillance showing him entering while armed, and any minor inaccuracies or omitted details did not demonstrate reckless or deliberate falsehoods that would negate good faith.
In City of Chicago v. Ahmed Alayah (consolidated with a related case), two below-median-income debtors filed Chapter 13 bankruptcy petitions and proposed three-year repayment plans that allocated funds to pay their attorneys’ fees (priority claims) before or alongside distributions to nonpriority unsecured creditors such as the City, which held claims for unpaid fines. The City objected to plan confirmation under 11 U.S.C. § 1325(b)(1)(B), arguing that the statute required all projected disposable income to go exclusively to unsecured creditors and that attorneys could not receive payments without filing proofs of claim. The bankruptcy court overruled the objections and confirmed the plans, and the Seventh Circuit affirmed. The court held that other Code provisions—particularly §§ 1322(a)(2) and 1326(b)(1)—expressly require plans to pay priority administrative expenses such as reasonable attorneys’ fees before or concurrently with payments to other creditors, and that the 2005 BAPCPA amendment to § 1325(b)(1)(B) did not alter this longstanding practice or preclude attorneys from qualifying as unsecured creditors entitled to receive projected disposable income.
In City of Chicago v. Stephen Falkner, two Chapter 13 debtors proposed three-year repayment plans that allocated funds to pay their bankruptcy attorneys’ fees (a priority administrative expense) before or alongside distributions to nonpriority unsecured creditors such as the City, which held claims for traffic and other debts. The City objected to confirmation under 11 U.S.C. § 1325(b)(1)(B), arguing that the plans failed to apply all projected disposable income solely to unsecured creditors because attorneys’ fees could not qualify or, alternatively, because the attorneys had not filed proofs of claim. The bankruptcy court overruled the objections and confirmed the plans. The Seventh Circuit affirmed, holding that §§ 1322(a)(2) and 1326(b)(1) expressly require plans to pay priority claims including attorneys’ fees before or at the same time as other creditors during the commitment period, that the 2005 BAPCPA amendment did not displace this practice or the Code’s treatment of such fees as either necessary expenses or allowable unsecured claims, and that a separate request for payment under § 503(a) suffices without a proof of claim.
The case involved several media organizations suing Indiana prison officials under the First Amendment, seeking a preliminary injunction to allow journalists to attend executions that the state otherwise restricts to prison staff, a few victim family members, the inmate’s spiritual advisor, and up to five people invited by the inmate. The Seventh Circuit affirmed the district court’s denial of the injunction. The majority held that the qualified right of access recognized in cases such as Press-Enterprise II does not extend to executions, which are not court proceedings and have not historically been open to the press and public; even under the “experience and logic” test, the long-standing trend toward private executions since the mid-nineteenth century precludes such a right. The court further concluded that the policy does not violate the Press Clause because it treats members of the media the same as the general public and is generally applicable rather than targeted at the press.
In United States v. Thomas Hawkins, the Seventh Circuit reviewed a district court’s revocation of supervised release for a defendant who, while on release following 2008 robbery convictions, committed two additional armed commercial robberies in 2020. The district court conducted a combined sentencing hearing, first imposing 135 months for the new offenses and then revoking supervised release and imposing the statutory maximum of 108 months, emphasizing public protection under the factors listed in 18 U.S.C. § 3583(e). Hawkins appealed, contending that the court improperly considered retribution (a factor barred by Esteras v. United States) by incorporating its earlier § 3553(a) analysis and that the sentence was substantively unreasonable and created unwarranted disparities. The court of appeals affirmed, holding that the district court had explicitly omitted retribution from the revocation analysis, properly weighed the seriousness of the new violations only insofar as they demonstrated ongoing danger to the public, and that the 108-month term was not plainly unreasonable given Hawkins’ repeated violent conduct.
James C. Wenzler, a longtime member and leader in the Coast Guard Auxiliary, sued the Coast Guard after it removed him from the organization for refusing to delete LinkedIn posts that depicted him in uniform while making crude and derogatory remarks about public figures, including Supreme Court Justices and a university president. The district court granted summary judgment to the Coast Guard, and the Seventh Circuit affirmed. The court applied the Connick/Pickering balancing test and concluded that, even assuming Wenzler’s posts addressed matters of public concern, the Auxiliary’s interests in maintaining internal discipline, public confidence, and its mission outweighed his speech interests. The opinion emphasized that the Auxiliary functions as a uniformed, congressionally established component of the Coast Guard with a military-style hierarchy, warranting deference to its reasonable judgments about how members’ public statements affect its reputation and operations when they present themselves as representatives.