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

Eric Stupak, a pass-holder at a Wisconsin resort, was injured after using the resort’s tube slides during the summer of 2022. The slides were closed at the time, but the resort had not posted the “Ride Closed” sign or removed the tubes; instead, the protective bumpers on the slides were deflated. After playing disc golf, Stupak and two friends asked the manager if they could use the slides. The manager responded ambiguously, saying, “I’m not going to say anything.” The group proceeded to use the slides, and Stupak fell off, sustaining serious injuries.The United States District Court for the Western District of Wisconsin reviewed Stupak’s suit against the resort and its insurer. The district judge determined, as a matter of law, that Stupak had been a trespasser on the slides, which meant the resort could only be liable if it engaged in “willful, wanton, or reckless conduct.” The judge found insufficient evidence of recklessness and granted summary judgment for the defendants, without addressing other issues raised in the parties’ motions.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s grant of summary judgment de novo, applying Wisconsin substantive law. The appellate court agreed that Stupak was a trespasser, as he lacked express or implied permission to use the closed slides. However, the Seventh Circuit found that a reasonable jury could determine the resort’s actions were reckless, given the ambiguous response by the manager and the unsafe condition of the slides. The court vacated the district court’s summary judgment and remanded the case for further proceedings, allowing the district court to address additional arguments regarding assumption of risk and proximate cause. View "Stupak v Mont du Lac Snowsports, LLC" on Justia Law

The petitioners, a mother and her four children, are citizens of Mexico who fled their home in Ciudad Hidalgo, Michoacán, after receiving threatening phone calls from individuals claiming to be members of the Knights Templar cartel. The callers demanded ransom, threatened kidnapping, and demonstrated knowledge of the family's whereabouts and routine. After a second threat, the family fled to a farmhouse and soon after left Mexico for the United States. The mother also described an earlier incident where her sister’s husband was kidnapped by the cartel for ransom; other family members remained unharmed in Ciudad Hidalgo. The petitioners sought asylum, withholding of removal, and protection under the Convention Against Torture, citing cartel threats and government corruption.An Immigration Judge from the U.S. Department of Justice conducted a hearing, found the mother’s testimony credible, but denied relief. The judge concluded that the threats did not amount to past persecution, were motivated by extortion rather than protected grounds, and the Mexican government was not shown to be unable or unwilling to protect. The judge also determined that internal relocation within Mexico could avoid harm and that the risk of torture did not meet the threshold under the Convention Against Torture. The Board of Immigration Appeals affirmed and adopted the Immigration Judge’s decision.Upon review, the United States Court of Appeals for the Seventh Circuit examined whether the petitioners had exhausted their administrative remedies before the Board. The court found that the petitioners, through counsel, failed to adequately develop arguments challenging key findings by the Immigration Judge, thus depriving the Board of the opportunity to address those points. As a result, the Seventh Circuit held that the petitioners had not exhausted their administrative remedies as required by statute and denied the petition for review. View "Gonzalez Perez v Blanche" on Justia Law

Children in the custody of the Illinois Department of Children and Family Services (DCFS), held at the Juvenile Temporary Detention Center in Chicago, often remained detained even after judges ordered their release due to a lack of available placements. This issue was widespread, with instances of children being unjustifiably confined for extended periods, sometimes exceeding 300 days. The plaintiffs, including the Cook County Public Guardian representing nine minors and a putative class, alleged that individual DCFS officials were aware of this problem and failed to act to secure timely placements, violating the children’s due process rights. The suit sought compensatory and punitive damages for Fourteenth Amendment violations and also asserted claims under the Americans with Disabilities Act (ADA) and the Rehabilitation Act.The United States District Court for the Northern District of Illinois allowed the ADA and Rehabilitation Act claims against DCFS to proceed but dismissed the Fourteenth Amendment claims against the individual DCFS defendants. The district court concluded that the claims were, in substance, official-capacity claims against the state agency and barred by Eleventh Amendment immunity. The dismissal was entered as a final order, permitting appeal, as the court determined that the § 1983 claims were distinct and could not be cured by amendment.The United States Court of Appeals for the Seventh Circuit reviewed the dismissal de novo. It held that the plaintiffs’ complaint asserted personal-capacity claims against the individual DCFS defendants, seeking money damages rather than injunctive relief, and included both current and former officials. The court found that Eleventh Amendment immunity does not bar personal-capacity suits for damages under § 1983. Accordingly, the Seventh Circuit reversed the district court’s dismissal and remanded the case for further proceedings. View "Golbert v Smith" on Justia Law

A student diagnosed with depression and anxiety attended a public school as a transfer student under the district’s policy, which required annual approval. To address her mental health challenges and learning difficulties, school officials and her parents implemented a Section 504 Plan granting accommodations such as frequent breaks, testing modifications, and access to counseling. Despite these accommodations, the student repeatedly engaged in disruptive behavior, resulting in ten out-of-school suspension days and numerous absences. Following an incident of sexual harassment, the school added a Safety Plan to further protect her. Persistent disciplinary issues continued, and requests by her parents for a manifestation-determination meeting to evaluate whether her behavior was linked to her disability were denied by the school.The United States District Court for the Southern District of Indiana, Indianapolis Division, presided over the case with consent of the parties. The court granted summary judgment to the school, finding that the school had reasonably accommodated the student’s disability and did not retaliate against her for requesting accommodations. It also held that the plaintiffs waived their Title IX claim by failing to include it in their statement of claims as required by local rules.Reviewing the appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The Seventh Circuit held that the school reasonably accommodated the student’s disability as required under the Americans with Disabilities Act and Section 504 of the Rehabilitation Act, and was not deliberately indifferent. The court concluded that the denial of reenrollment was based on valid, non-pretextual reasons—specifically, the student’s ten out-of-school suspensions—and did not constitute unlawful retaliation. The court also upheld the district court’s discretionary waiver of the Title IX claim. View "E. W. v Mt. Vernon Community School Corp." on Justia Law

American Backflow & Fire Prevention, Inc. employs plumbers who voted to unionize in June 2021. Following allegations by the union of unfair labor practices—including encouraging decertification efforts, refusing to bargain, and failing to provide requested information—the company and the union entered into a settlement agreement in April 2022. Under this agreement, American Backflow was required to bargain in good faith with the union and acknowledged that if it breached the agreement without curing the breach, the National Labor Relations Board (NLRB) could seek a default judgment, resulting in the admission of all allegations in a related complaint.In March 2023, after holding one bargaining session, American Backflow canceled a subsequent session and withdrew recognition of the union, citing evidence that the union no longer had majority support. The NLRB’s Regional Director notified American Backflow that this action breached the settlement. After the company failed to cure the breach, the Regional Director filed two complaints with the NLRB, one alleging unfair labor practices and another seeking default judgment for breach of the settlement. The company responded by generally denying wrongdoing but did not substantively address the basis for withdrawing recognition.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court upheld the NLRB’s decision to grant default judgment, finding that substantial evidence supported the Board’s conclusion that American Backflow breached the settlement and failed to present a material issue of fact. The court also held that the company had waived statutory and due process arguments by not raising them before the Board. Accordingly, the court denied the petition for review and granted the Board’s application to enforce its order requiring the company to bargain in good faith with the union. View "NLRB v American Backflow & Fire Prevention, Inc." on Justia Law

After being stopped by Illinois State Police for speeding, a driver was questioned about his criminal history and denied a request to search his vehicle. The officer issued only a warning and allowed the driver to leave. However, the officer notified a nearby canine unit about his suspicions. Less than two hours later, the canine officer observed the driver commit another traffic infraction, pulled him over, and conducted a dog sniff that led to the discovery of drugs in the vehicle. The driver was subsequently indicted for possession with intent to distribute cocaine base.Reviewing the case, the United States District Court for the Central District of Illinois denied the driver’s motion to suppress the drug evidence, finding the second traffic stop was independently justified by a new traffic violation and that the dog sniff did not unreasonably prolong the stop. The district court also denied the driver’s motion to dismiss the indictment for vindictive prosecution and selective enforcement, concluding that there was no evidence of impermissible motives or that similarly situated individuals were treated differently. The driver entered a conditional guilty plea, reserving the right to appeal these rulings.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s decisions. The appellate court held that the initial traffic stop was unreasonably prolonged but that the evidence from the second stop was attenuated from this violation, as the second stop was based on an independent traffic infraction. The court also found the second stop was not unlawfully prolonged and that the dog sniff occurred during the normal course of the traffic warning process. Regarding the motion to dismiss, the court held the driver failed to raise a reasonable doubt that enforcement was selectively or vindictively motivated and upheld the denial of an evidentiary hearing. View "USA v Pennington" on Justia Law

A dentist applied for benefits under his individual disability insurance policy after suffering impairments to his hip and back. While his claim was under review, he received payments from his insurer for over a year. During that period, he earned income through part-time teaching and performing duties for two professional dental associations. After discovering this income, the insurer terminated his benefits, determining that his continued work qualified as a “gainful occupation” and thus he did not satisfy the policy’s requirement for “total disability.”The dentist subsequently filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, alleging breach of contract and seeking statutory penalties for bad faith under the Illinois Insurance Code. Both parties moved for summary judgment. The district court granted summary judgment in favor of the insurer, finding that the policy’s language was unambiguous and that the dentist was, as a matter of law, engaged in a gainful occupation based on the undisputed facts.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s ruling de novo. The appellate court held that the policy unambiguously required the claimant to show not only inability to perform his prior occupation but also that he was not engaged in any other gainful occupation. The court concluded that “gainful occupation” was not ambiguous and that the dentist’s nonclinical work, which generated substantial income, disqualified him from benefits. The court also rejected the contention that “gainful occupation” should be defined as earning at least 60% of pre-disability income, finding no support for that standard in the policy language. The Seventh Circuit affirmed the district court’s judgment for the insurer. View "Caraba v Paul Revere Life Insurance Co." on Justia Law

Matthew Frazier was convicted in federal court for possession of child pornography under 18 U.S.C. § 2252A and sentenced to 120 months' imprisonment and seven years of supervised release. Frazier had a prior history involving a state court conviction for similar offenses, during which he was initially found incompetent to stand trial but later restored to competency following mental health treatment. After his release on probation, authorities discovered that he was again accessing prohibited materials, leading to a federal search that uncovered additional incriminating evidence. Prior to his federal trial, Frazier underwent a psychological evaluation, revealing ongoing hallucinations but ultimately concluding he was competent to stand trial.Following Frazier's waiver of a jury trial in the United States District Court for the Northern District of Indiana, he made statements about experiencing hallucinations. However, neither his attorney nor the prosecutor questioned his competency at that time, and the district judge conducted a thorough inquiry into his understanding of the proceedings. Defense counsel confirmed that Frazier’s decision-making abilities were consistent with the earlier finding of competency.On appeal to the United States Court of Appeals for the Seventh Circuit, Frazier challenged the district court’s failure to order a second competency hearing and contested the supervised release condition requiring full-time employment. The Seventh Circuit held that the district court did not abuse its discretion by not ordering a second competency hearing, given the evidence and the deferential standard of review. Regarding supervised release, the court concluded that the employment condition was not plain error because it included alternatives like community service or job training, and Frazier had not shown he was incapable of meeting those requirements. The Seventh Circuit affirmed the judgment of the district court. View "USA v Frazier" on Justia Law

Maria Reynoso-Salgado, a Mexican citizen, has lived in the United States since 1997. In 2012, she pleaded guilty to a misdemeanor charge of child neglect under Wisconsin law. The following year, the Department of Homeland Security initiated removal proceedings against her, alleging she was present in the country without proper authorization. Reynoso-Salgado admitted the factual allegations and sought cancellation of removal, which is only available to noncitizens without certain disqualifying convictions.An immigration judge denied her request for cancellation, finding that her conviction for child neglect constituted a “crime of child abuse, child neglect, or child abandonment” under 8 U.S.C. § 1227(a)(2)(E)(i), making her ineligible for relief. The Board of Immigration Appeals affirmed this decision, concluding that the Wisconsin statute was a categorical match to the federal standard for such crimes. Reynoso-Salgado then petitioned the United States Court of Appeals for the Seventh Circuit for review, arguing that her state conviction should not disqualify her from cancellation of removal.The United States Court of Appeals for the Seventh Circuit considered whether the Wisconsin child neglect statute matched the federal definition of a “crime of child abuse, child neglect, or child abandonment” for immigration purposes. Employing the categorical approach, the court concluded that the elements of the Wisconsin statute—requiring intentional conduct resulting in a child’s neglect—met or exceeded the minimum mental state and conduct required by the federal statute. The court also held that the federal provision should be read as a single category encompassing various forms of child maltreatment, with a minimum mens rea of criminal negligence. The Seventh Circuit denied Reynoso-Salgado’s petition, holding that her conviction rendered her ineligible for cancellation of removal. View "Reynoso-Salgado v Blanche" on Justia Law

The plaintiff, an individual designer, developed a spill-proof cup lid and sought to have it manufactured and sold. She contacted a company for manufacturing and, during this process, shared confidential materials with a sales representative who was also representing the manufacturer in the same product category. Later, she discovered that the manufacturer had released a product almost identical to her design and had obtained both a design and a utility patent for it. The plaintiff then engaged a law firm and attorney to pursue potential legal claims and settlement discussions with the manufacturer’s parent company. During the representation, the attorney was negotiating employment with the law firm representing the opposing party, a fact not initially disclosed to the plaintiff. Eventually, the law firm terminated its representation of the plaintiff, citing unpaid fees.After the termination, the plaintiff, acting without legal counsel, filed suit in the United States District Court for the Northern District of Illinois against the law firm and the attorney, asserting multiple claims including legal malpractice, fraud, breach of contract, and intentional infliction of emotional distress. The district court dismissed the complaint with prejudice for failure to state a claim, emphasizing the plaintiff’s failure to adequately allege harm causally connected to the defendants’ conduct, particularly any lost viable legal claim or damages resulting from the alleged conflict of interest.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s dismissal. The appellate court held that, under Ohio law (as specified in the retainer agreement), the plaintiff did not sufficiently plead that the attorney’s conduct caused her to lose any viable underlying legal claim due to the expiration of a statute of limitations. The court also found the plaintiff’s alternative theories of harm, including loss of the retainer fee and emotional distress, insufficient to sustain a malpractice claim. Accordingly, the judgment was affirmed. View "Sima v Benesch, Friedlander, Coplan & Aronoff LLP" on Justia Law