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

Dyamond Davis, an employee at the Shapiro Development Center, informed her supervisor on May 12, 2017, that she needed to leave work due to pregnancy-related morning sickness. Her supervisor allowed her to leave, reminding her to complete the necessary paperwork. Davis was later granted FMLA leave retroactive to May, but DHS determined that part of her May 12 absence was unauthorized because it believed FMLA did not cover morning sickness and that Davis violated policies requiring the substitution of accrued paid leave for FMLA leave. Consequently, DHS terminated her employment. Davis appealed her termination unsuccessfully to the Illinois Civil Service Commission and then filed a lawsuit alleging FMLA interference. Another employee, Antionette Burns, joined the lawsuit with a similar claim.The United States District Court for the Central District of Illinois dismissed Burns’s claim for lack of Article III standing and granted summary judgment in favor of DHS on Davis’s claim. The court found that Burns failed to establish a concrete injury-in-fact and that DHS was entitled to rely on the medical certification provided by Davis’s doctor, which did not indicate a need for intermittent leave for morning sickness.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the dismissal of Burns’s claim without prejudice, agreeing that she failed to establish a concrete injury-in-fact. However, the court found that there were genuine disputes of material fact regarding Davis’s FMLA claim. The court noted that morning sickness qualifies as a serious health condition under FMLA and that DHS was aware of Davis’s need for intermittent leave due to morning sickness. The court also found that DHS may have improperly applied its paid leave substitution policy, which could have led to Davis’s termination. Therefore, the court reversed the district court’s grant of summary judgment for DHS on Davis’s claim and remanded the case for further proceedings. View "Davis v Illinois Department of Human Services" on Justia Law

Grant Gambaiani was sentenced to 34 years in prison after being found guilty by an Illinois jury of multiple crimes, including the repeated sexual assault of his minor cousin, D.G. During the trial, the courtroom was partially closed during D.G.'s testimony, which Gambaiani argued violated his Sixth Amendment right to a public trial. The Illinois Appellate Court affirmed his conviction, and the Supreme Court of Illinois denied review. Gambaiani then sought postconviction relief, claiming ineffective assistance of counsel during plea negotiations, but the state courts denied relief.Gambaiani filed a petition for a writ of habeas corpus in federal district court, claiming violations of his constitutional rights to a public trial and effective assistance of counsel. The district court denied his petition. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the case.The Seventh Circuit affirmed the district court's decision. The court held that the Illinois Appellate Court's conclusion that Gambaiani waived his right to a public trial by failing to object to the partial closure was not contrary to, or an unreasonable application of, clearly established federal law. The court also found that the partial closure of the courtroom during D.G.'s testimony did not violate Gambaiani's Sixth Amendment right. Additionally, the Seventh Circuit upheld the state court's determination that Gambaiani's attorneys provided effective assistance of counsel during plea negotiations, as the state court's credibility determinations were reasonable and supported by the record. View "Gambaiani v Greene" on Justia Law

On December 15, 2015, police officers responded to a hostage situation at Eagle Nation Cycles in Neenah, Wisconsin. Initial reports indicated a lone gunman had fired a shot and was threatening to kill hostages. When officers attempted to enter the shop, they were met with gunfire and heavy smoke, leading them to suspect an ambush. Several hostages escaped, and the officers detained and questioned them, transporting two to the police station. Three of these hostages later sued the City of Neenah and multiple officers, claiming their Fourth Amendment rights against unreasonable seizures were violated.The United States District Court for the Eastern District of Wisconsin found the plaintiffs' detention reasonable and ruled that no constitutional violation occurred. Additionally, the court held that qualified immunity shielded the officers from liability. The court also dismissed Sergeant Angela Eichmann from the suit due to her lack of involvement in the alleged misconduct. The district court granted summary judgment in favor of the defendants.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's decision, holding that the officers' actions were reasonable under the circumstances of a violent hostage situation. The court found that the officers were justified in temporarily detaining the plaintiffs to ascertain their identities and ensure safety. The court also affirmed the dismissal of Sergeant Eichmann, as there was no evidence of her direct involvement in the alleged constitutional violations. The court did not address the issue of qualified immunity, as it concluded that no constitutional violation occurred. View "Moderson v. City of Neenah" on Justia Law

Marcus Dixon, while on supervised release after a federal prison sentence, was arrested based on his suspected involvement in a hit-and-run accident and drug dealing. Probation officers conducted warrantless searches of his property, including a Pontiac, a cellphone, a home in Silvis, Illinois, an Audi, and a duffel bag, finding evidence of drug distribution and firearms. Dixon was convicted on multiple counts related to drug possession and firearms. He moved to suppress the evidence obtained from these searches, arguing they exceeded the scope authorized by his supervised release conditions. The district court denied his motion, leading to this appeal.The United States District Court for the Central District of Illinois denied Dixon's motion to suppress, concluding that he lacked a legitimate expectation of privacy in the searched items and places. The court also found that the searches were supported by reasonable suspicion. Dixon was subsequently convicted on all counts by a jury and sentenced to 260 months in prison. He appealed the denial of his motion to suppress, challenging the searches' legality and the denial of an evidentiary hearing.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court held that Dixon failed to establish Fourth Amendment standing as he did not provide evidence of a legitimate expectation of privacy in the searched items and places. The court also found that the searches of the Pontiac and cellphone were reasonable and permissible under Dixon's supervised release conditions. The court concluded that the district court did not abuse its discretion in denying an evidentiary hearing, as Dixon did not identify any disputed material facts warranting such a hearing. View "United States v. Dixon" on Justia Law

A former inmate at the Illinois River Correctional Center (IRCC) filed a lawsuit under 42 U.S.C. § 1983 against several prison officials, including Wardens Walter Nicholson and Gregory Gossett. The plaintiff alleged that the IRCC's failure to treat his chronic kidney disease, which progressed to acute renal failure, constituted deliberate indifference in violation of the Eighth and Fourteenth Amendments. The plaintiff claimed that the wardens were aware of the deficient medical practices that led to his injury.The United States District Court for the Central District of Illinois granted Warden Nicholson's motion to dismiss, concluding that the plaintiff's claim was time-barred and that he failed to state a claim. The court also granted Warden Gossett's motion for summary judgment, finding that the plaintiff did not provide sufficient evidence to show that Gossett was deliberately indifferent to his medical needs. Additionally, the court excluded the plaintiff's expert witnesses, determining that their testimony would not assist the jury and might cause confusion.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's dismissal of the claim against Warden Nicholson, agreeing that the plaintiff's complaint contained only general allegations and did not provide specific deficiencies in the IRCC's health care system. The court also upheld the summary judgment in favor of Warden Gossett, concluding that the plaintiff did not present sufficient evidence to show that Gossett was deliberately indifferent to his medical needs. The court found that the district court did not abuse its discretion in excluding the expert testimony, as the experts lacked relevant expertise and their opinions would not assist the jury. View "Ollison v Gossett" on Justia Law

Edward C. Brown was convicted of distribution and possession of child pornography in 2015. After serving his prison sentence, he was placed on supervised release with conditions, including allowing unannounced visits by probation officers and reporting any cell phones he possessed. During an unannounced visit in April 2023, probation officers discovered an unreported cell phone in Brown's apartment. A forensic search of the phone revealed 75 thumbnail images of child pornography in an inaccessible cache folder. Brown was subsequently charged with possession of child pornography and convicted by a jury.The United States District Court for the Central District of Illinois admitted Brown's prior child pornography convictions as evidence under Federal Rules of Evidence 414 and 404(b). The court also allowed evidence of Brown's supervised release status. At trial, the jury heard testimony from government witnesses, including a probation officer, a police detective, and an FBI special agent, as well as defense witnesses who highlighted deficiencies in the forensic evidence. Despite the lack of metadata and direct evidence linking Brown to the images, the jury found him guilty. The district court denied Brown's motion for acquittal and sentenced him to 78 months in prison, followed by a 15-year term of supervised release. The court also revoked his supervised release from prior convictions, adding a consecutive 6-month prison term.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed Brown's conviction. The court held that the combination of the 75 thumbnail images, Brown's prior convictions, his interview admissions, and his failure to report the phone provided sufficient circumstantial evidence for a reasonable jury to find him guilty beyond a reasonable doubt. The court emphasized that the forensic evidence, while flawed, was supported by other incriminating factors, including Brown's technological knowledge and his concealment of the phone from probation. View "USA v Brown" on Justia Law

Mullins Food Products, Inc. was sued in Illinois state court for violating the Biometric Information Privacy Act (BIPA). Mullins requested its liability insurer, Citizens Insurance Company of America, to defend the suit, but Citizens declined and instead filed a federal suit seeking a declaratory judgment that it had no duty to defend or indemnify Mullins based on exclusions in the commercial liability insurance policies issued to Mullins in 2015, 2016, and 2017. While the federal suit was pending, Mullins settled the state-court action.The United States District Court for the Northern District of Illinois agreed with Citizens that the policy exclusions relieved Citizens of the duty to defend or indemnify Mullins. Specifically, the court found that the Access or Disclosure of Confidential or Personal Information exclusion and the Recording and Distribution of Material or Information in Violation of Law exclusion barred coverage for BIPA claims. The district court also ruled against Mullins on its counterclaim for breach of contract, reasoning that Citizens' timely filing of the declaratory judgment action precluded a finding of breach.The United States Court of Appeals for the Seventh Circuit reviewed the case and vacated the district court's decision. The appellate court concluded that the Access or Disclosure exclusion in the 2016 and 2017 policies barred coverage for BIPA claims, but the Statutory Violations exclusion did not. Therefore, Citizens had a duty to defend and indemnify Mullins under the 2015 policy, assuming Mullins provided timely notice of the state-court action. The appellate court remanded the case for further proceedings to determine the timeliness of Mullins' notice and to address Mullins' claim for reimbursement of defense costs. View "Citizens Insurance Company of America v Mullins Food Products, Inc." on Justia Law

An executive at a litigation funding company, Signal, resigned to start a competing business and sought legal advice from Signal’s outside counsel, Sugar Felsenthal Grais & Helsinger LLP. Signal sued the law firm and several of its attorneys, alleging legal malpractice, breach of contract, breach of fiduciary duty, and fraud. The district court dismissed some claims and granted summary judgment in favor of the defendants on the remaining claims. Signal appealed these rulings.The United States District Court for the Northern District of Illinois dismissed Signal’s breach of fiduciary duty claim and part of its fraud claim, allowing the legal malpractice, breach of contract, and fraudulent misrepresentation claims to proceed. The court also struck Signal’s request for punitive damages. During discovery, the court denied Signal’s motion to compel production of a memorandum prepared by one of the defendants. The district court later granted summary judgment in favor of the defendants on all remaining claims.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s rulings. The appellate court agreed that Signal failed to establish proximate cause and damages for its legal malpractice and breach of contract claims. The court also found that Signal waived its challenge to the summary judgment ruling on the fraudulent misrepresentation claim by not adequately addressing it on appeal. Additionally, the court upheld the district court’s decision to deny Signal’s motion to compel production of the memorandum, as Signal did not demonstrate that the document influenced the witness’s testimony. The appellate court concluded that the district court’s dismissal of the fraudulent concealment theory was harmless error and denied Signal’s motion to certify a question to the Illinois Supreme Court as moot. View "Signal Funding, LLC v Sugar Felsenthal Grais & Helsinger LLP" on Justia Law

David Walton, a Wisconsin prisoner, filed a lawsuit under 42 U.S.C. § 1983 against Ashley Nehls, a prison nurse, alleging that she violated his Eighth Amendment rights by engaging in a sexual relationship with him. Walton testified that the relationship was consensual. The district court granted summary judgment for Nehls, reasoning that a consensual sexual relationship does not constitute cruel or unusual punishment under the Eighth Amendment.The United States District Court for the Eastern District of Wisconsin reviewed the case and entered summary judgment in favor of Nehls. The court concluded that Walton's testimony about the consensual nature of the relationship meant that it could not be considered a violation of the Eighth Amendment. Walton appealed the decision, urging the appellate court to adopt a legal presumption that any sexual activity between a prisoner and a prison official is nonconsensual and violates the Constitution unless the prison official can show an absence of coercion.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The Seventh Circuit acknowledged the power dynamics between prisoners and prison officials and the evolving standards of decency, noting that all 50 states have criminalized sexual conduct between prison officials and prisoners. However, the court found that even if it applied the presumption of nonconsent, the evidence in the record established that the relationship between Walton and Nehls lacked any coercive factors. Therefore, the court affirmed the district court's entry of summary judgment for Nehls, leaving the broader legal question of adopting a presumption of nonconsent for another day. View "Walton v Nehls" on Justia Law

George and Maria Dernis borrowed money from Premier Bank, which was involved in fraudulent lending practices. The loans were secured by mortgages on their personal real estate. After Premier Bank collapsed, the FDIC was appointed as receiver and sold some of the bank's loans, including the Dernises' loans, to Amos Financial in 2014. The Dernises claimed that the FDIC was aware of the fraudulent nature of the loans and failed to take remedial action. They filed a lawsuit against the FDIC, which was dismissed by the district court. They then filed an amended complaint against the United States under the FTCA, alleging various torts based on the FDIC's conduct.The United States District Court for the Northern District of Illinois dismissed the amended complaint, determining that most of the claims were not timely exhausted under 28 U.S.C. § 2401(b). The court also found that the sole timely claim was barred by the FTCA’s intentional torts exception under 28 U.S.C. § 2680(h). The court dismissed the action with prejudice and entered final judgment.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that the Dernises failed to timely exhaust their administrative remedies for most of their claims. The court also held that the only timely claim was barred by the FTCA’s intentional torts exception, as it involved misrepresentation, deceit, and interference with contract rights. The court rejected the Dernises' argument that the FDIC’s "sue-and-be-sued" clause provided a broader waiver of sovereign immunity, noting that the United States was the sole defendant and the FTCA provided the exclusive remedy for tort claims against the United States. View "Dernis v United States" on Justia Law