Justia U.S. 7th Circuit Court of Appeals Opinion Summaries

The plaintiff, Richard Rodgers, a prisoner with a history of scoliosis and back pain, had steel rods implanted in his back prior to his incarceration. During his time in prison, the rods broke, but this went undetected for over a year due to two radiologists misreading his x-rays. The prison's primary care physician, Dr. William Rankin, discovered the broken rods and arranged for corrective surgery. Rodgers sued the radiologists and Dr. Rankin, alleging violation of his Eighth Amendment rights.The district court dismissed Rodgers' claims against the radiologists, finding that he did not state a viable constitutional claim against them. The court allowed Rodgers to proceed against Dr. Rankin but eventually granted summary judgment in his favor. The court found that Rodgers had not provided evidence that would allow a reasonable jury to find that Dr. Rankin had violated the Eighth Amendment by acting with deliberate indifference toward Rodgers' serious medical condition.The United States Court of Appeals for the Seventh Circuit affirmed the district court's judgment. The court agreed that Rodgers' allegations against the radiologists amounted to no more than negligence, which is insufficient to state a viable Eighth Amendment claim. Regarding Dr. Rankin, the court found that the evidence would not support a reasonable finding that he acted with deliberate indifference to Rodgers' serious medical condition. The court noted that Dr. Rankin was the one who discovered the radiologists' errors and arranged for Rodgers' corrective surgery. View "Rodgers v. Rankin" on Justia Law

The case involves a class action lawsuit brought against the Illinois Department of Corrections (IDOC) by four parents who were convicted of sex offenses and were on mandatory supervised release (MSR). The plaintiffs challenged an IDOC policy that restricts contact between a parent convicted of a sex offense and their minor child while the parent is on MSR. The plaintiffs argued that this policy violates their Fourteenth Amendment rights to procedural and substantive due process.The district court upheld the policy, with two exceptions. It ruled that the policy's ban on written communications was unconstitutional and that IDOC must allow a parent to submit a written communication addressed to their child for review and decision within seven calendar days. The plaintiffs appealed, challenging the policy's restrictions on phone and in-person contact.The United States Court of Appeals for the Seventh Circuit affirmed in part and reversed in part. The court agreed with the district court that the policy does not violate procedural due process. However, it held that the policy's ban on phone contact violates substantive due process. The court found that call monitoring is a ready alternative to the phone-contact ban that accommodates the plaintiffs’ right to enjoy the companionship of their children at a de minimis cost to IDOC’s penological interests. View "Montoya v. Jeffreys" on Justia Law

The case involves Songie Adebiyi, a former Vice President of Student Services at South Suburban College in Illinois, who was terminated in 2019 due to alleged performance issues. Adebiyi claimed that her termination was in retaliation for filing a charge with the United States Equal Employment Opportunity Commission and the Illinois Department of Human Rights. She sued the college and its president, alleging racial discrimination and retaliation under 42 U.S.C. § 1981 and Title VII of the Civil Rights Act of 1964, as well as breach of contract.The United States District Court for the Northern District of Illinois granted summary judgment to the college and its president, ruling that Adebiyi failed to show a causal link between her charge of discrimination and her termination. The court found that the evidence did not support Adebiyi’s retaliation claim. Adebiyi appealed the decision, arguing that the district court erred in dismissing her Title VII retaliation claim and abused its discretion when it denied her motion to amend the complaint and seek more discovery.The United States Court of Appeals for the Seventh Circuit affirmed the judgment of the district court. The appellate court agreed with the lower court's finding that Adebiyi failed to demonstrate a causal link between her protected activity and the adverse employment action. The court found no evidence of pretext in the college's reasons for termination or suspicious timing between Adebiyi's filing of her EEOC and IDHR charge and her termination. The court also found no abuse of discretion in the district court's denial of Adebiyi's motion to file an amended complaint and take additional discovery. View "Adebiyi v. South Suburban College" on Justia Law

On July 4, 2021, Gavin Wallmow was arrested for violating his probation and was taken to Oneida County jail. During his booking, Wallmow denied any suicidal tendencies or mental health issues. Two days later, Wallmow's probation officer visited him and noticed a change in his behavior, including him hitting himself and expressing "demonic" thoughts. The officer reported this to a corrections officer at the jail, who then informed her superior. Despite these reports, Wallmow was observed behaving normally during routine checks. On July 8, Wallmow was found unresponsive in his cell, having committed suicide. His estate brought a series of constitutional claims under 42 U.S.C. § 1983, alleging that the jailers failed to protect Wallmow from himself.The United States District Court for the Western District of Wisconsin granted summary judgment to the defendants, concluding that the record did not support an inference that any defendant knew Wallmow faced a serious risk of harm. The court also found no reason to think the County's policies were inadequate, given the absence of any pattern of suicides to put it on notice.Upon appeal, the United States Court of Appeals for the Seventh Circuit affirmed the lower court's decision. The appellate court found that the jail's employees had taken reasonable precautions, including checking on Wallmow at least 37 times per day. The court also noted that Wallmow had thrice disavowed any risk of suicide, and nothing indicated otherwise after his talk with his probation officer. The court concluded that the jail's actions complied with the Constitution's requirements. View "Estate of Wallmow v. Oneida County, Wisconsin" on Justia Law

The case involves Circle City Broadcasting I, LLC, a local television broadcasting network operating in Indianapolis, which owns two local television stations—WISH-TV and WNDY. The company is majority-owned by DuJuan McCoy, a Black man. The dispute arose when DISH and DirecTV Network declined to pay broadcast fees to Circle City for rights to carry the company’s two Indianapolis-based television stations. Circle City alleged that the decisions reflected discrimination against its majority owner, DuJuan McCoy, and thus discrimination against the company itself.Previously, the United States District Court for the Southern District of Indiana entered summary judgment for DISH and DirecTV, concluding that Circle City failed to identify evidence permitting a jury to find that the decisions not to pay the broadcast fees reflected anything other than lawful business choices responsive to dynamics of the television broadcast market.The United States Court of Appeals For the Seventh Circuit affirmed the lower court's decision. The court found that Circle City failed to produce evidence that would allow a jury to find that DISH or DirecTV's conduct during the contractual negotiations reflected racial discrimination. The court concluded that DISH and DirecTV declined to pay fees for rights to broadcast WISH and WNDY because Circle City—unlike Nexstar—as the new owner of both stations lacked the market power to demand the fees. The court also found that Circle City fell short of demonstrating any pretext in DISH and DirecTV’s explanations for choosing not to pay retransmission fees. View "Circle City Broadcasting I, LLC v. DISH Network L.L.C." on Justia Law

The case involves plaintiffs Tabatha Washington and Donte Howard who were charged with first-degree murder. They were detained for over a year before being acquitted. They then filed a suit against the City of Chicago and three police detectives, alleging unlawful pretrial detention under the Fourth Amendment and malicious prosecution under Illinois law. The district court granted summary judgment in favor of the defendants.Previously, the Circuit Court of Cook County had found probable cause to detain both plaintiffs without bail. A few weeks later, a grand jury indicted them on charges of first-degree murder, including a felony-murder theory premised on felony mob action. The plaintiffs argued that the detectives deliberately misled judges and the grand jury to secure these determinations of probable cause.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court found that even if the detectives' alleged misrepresentations and omissions were accepted as true, the prosecutors' independent fact-gathering and the remaining undisputed evidence still supported probable cause to detain the plaintiffs. Therefore, the judicial determinations of probable cause were presumed to be valid, and the pretrial detention of the plaintiffs did not violate the Fourth Amendment. The court also held that the plaintiffs' malicious prosecution claims failed for the same reason. View "Washington v. City of Chicago" on Justia Law

The case revolves around Anthony Gay, a convicted felon, who was found guilty of possessing firearms and ammunition, both of which he was prohibited from possessing due to his prior felony convictions. Gay was a passenger in a car that was stopped by the police, and upon being pursued, he fled on foot. The police testified that they found a gun where Gay had fallen and later discovered bullets in a motel room he had rented. Gay was subsequently indicted and convicted on one firearms count and one ammunition count, leading to a sentence of 84 months' imprisonment on each count, to run concurrently, plus three years' supervised release.Previously, Gay had contested the admissibility of the bullets found in the motel room, arguing that their discovery violated his Fourth Amendment rights. However, the district court denied his motion to suppress the bullets, stating that Gay's right to occupy the room had expired, the motel manager had found the bullets before the police were involved, and the manager had the right to admit the police under state law. Furthermore, the court noted that Gay, being on parole, had a diminished expectation of privacy.In the United States Court of Appeals for the Seventh Circuit, Gay argued that the evidence did not support his conviction on the firearms charge, suggesting that the weapon may have been planted. However, the court found that the evidence, including the bullets found in the motel room, supported the firearms charge. The court also dismissed Gay's argument that the reduction of two weeks in preparation time for his second trial was prejudicial, stating that the parties had just been through a trial and the evidence had been assembled.Gay also contended that the prosecution was unconstitutional, arguing that the Second Amendment permits persons with felony convictions to possess firearms and ammunition. However, the court affirmed the lower court's decision, citing precedents that upheld the validity of "longstanding prohibitions on the possession of firearms by felons." The court concluded that Gay, having been convicted of 22 felonies and being on parole, did not fit the description of a "law-abiding, responsible citizen" who has a constitutional right to possess firearms. View "United States v. Gay" on Justia Law

In the early hours of a snowy morning, police officer Owen McGuinness responded to a hit-and-run accident in Rockford, Illinois. Upon arrival, he received conflicting accounts from Daniel Madero, who was accused of being the driver of the hit-and-run vehicle, and three witnesses who claimed they had followed the vehicle and identified Madero as the driver. Madero was arrested for aggravated battery and issued traffic citations. An investigation later concluded that Madero's vehicle was likely not involved in the hit-and-run accident, and no charges were pressed against him.Madero subsequently filed a federal complaint claiming false arrest in violation of the Fourth and Fourteenth Amendments. The district court granted summary judgment to Officer McGuinness, determining that he had probable cause to arrest Madero based on the information available at the time.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court concluded that Officer McGuinness had probable cause to arrest Madero given the testimony of the three witnesses who insisted that Madero was the driver of the hit-and-run vehicle, despite Madero's denial. Discrepancies in the witnesses' accounts and later recantations did not dispel the probable cause at the time of arrest. Therefore, Madero's claim of false arrest was rejected. View "Madero v. McGuinness" on Justia Law

This case was brought before the United States Court of Appeals For the Seventh Circuit by plaintiffs John Brooks and Gregory Simmons against the City of Pekin and four of its employees. Brooks, a former police lieutenant who developed sleep apnea, claimed that the City violated the Americans with Disabilities Act by failing to reasonably accommodate his condition, discriminating against him, and retaliating against him for raising complaints. Simmons, a former police officer, alleged retaliation under Title VII of the Civil Rights Act of 1964 for reporting sexually harassing comments made by his former boss. The district court had granted summary judgment in favor of the defendants.The Court of Appeals affirmed the lower court's decision. The Court found that Brooks failed to show that the City had not offered him reasonable accommodations for his sleep apnea. The Court also ruled that Brooks could not establish disparate treatment because he failed to identify similarly situated employees who received more favorable treatment. Furthermore, Brooks was unable to prove retaliation because he lacked evidence that the City's reason for disciplining him was pretextual.Regarding Simmons, the Court found that he could not establish a claim for retaliation under Title VII because the inappropriate comments made about him were not because of his sex and were not severe or pervasive enough to create an abusive working environment. Moreover, Simmons could not show that his termination was due to his complaints against his former boss. The Court also noted that the district court did not err in denying the plaintiffs' request to amend their summary judgment response. The Court declined the City's request to impose sanctions on Brooks and Simmons, reasoning that their appeal was not frivolous. View "Brooks v. City of Pekin" on Justia Law

In this case, the United States Court of Appeals for the Seventh Circuit ruled on an appeal brought by Randall Artis, a former city councilman for East Chicago, Indiana. Artis was previously convicted of misappropriating public money for personal political gain. After returning to public service as a junior clerk, he was fired by his boss, Adrian Santos. Artis alleged that Santos fired him in retaliation for exercising his First Amendment free speech rights. The case went to trial, and a jury found in favor of Santos.Artis appealed, arguing that the district court erred in admitting the testimony of an expert witness, in denying him an impartial jury, and in issuing inaccurate and confusing jury instructions and verdict forms. He also questioned the jury's verdict. The appeals court affirmed the district court's judgment, finding no error or reason for a new trial.The court held that the district court did not abuse its discretion in allowing the expert witness to testify, and it did not err in denying Artis's for-cause challenge to a prospective juror. Moreover, the court ruled that the district court did not abuse its discretion in its choice of jury instructions and verdict form. Finally, the court found no inconsistency in the jury's verdict. View "Artis v. Santos" on Justia Law