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

The case concerns a man who sued several parties after negative posts about him appeared in a large Chicago-based Facebook group where women share experiences about local men. The posts, made in late 2023, included a woman he briefly dated recounting her unpleasant experiences, attaching a screenshot of a profane text message he sent her after their breakup. Other posts by unidentified users included supportive comments and, in one instance, a link to a news article about a criminal case involving someone with a different name and appearance. The plaintiff alleged these posts caused him reputational, economic, and emotional harm.In the United States District Court for the Northern District of Illinois, the defendants—including the former date, her parents (for allegedly allowing use of their internet connection), the group’s administrators, and Meta Platforms—moved to dismiss the complaint for failure to state a claim. The court granted the motions, finding the claims legally insufficient and dismissing the case with prejudice. The plaintiff appealed and voluntarily dismissed claims against unidentified “Jane Doe” defendants to preserve diversity jurisdiction.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s dismissal. The appellate court affirmed, holding that the plaintiff failed to state plausible claims under the Illinois Right of Publicity Act because none of the defendants used his likeness for a commercial purpose. The court also found the “doxing” claim insufficient, as there were no plausible allegations of intent or recklessness regarding harm or stalking. Defamation and related claims failed because the allegedly defamatory material could be innocently interpreted or lacked special damages. The court also concluded that the appeal as to the woman and her parents was frivolous and ordered the plaintiff and his attorneys to show cause why sanctions should not be imposed for bringing a meritless appeal and for submitting briefs containing fictitious quotations and misstatements of law. The court awarded costs to other appellees and referred attorney conduct to state disciplinary authorities. View "D'Ambrosio v Meta Platforms, Inc." on Justia Law

Tire Town Auto LLC, a towing service based in Marshfield, Wisconsin, operated for years on a list maintained by Wood County for dispatching towing companies to remove disabled vehicles from public roads. Wood County required businesses on the list to comply with a set of minimum standards, including 24/7 availability, liability insurance, and rules such as the use of reflective vests. After complaints about noncompliance with these standards—including failure to wear vests and alleged overcharging—Wood County removed Tire Town from the rotation list. Tire Town filed suit three years later, alleging that its removal violated its procedural due process rights under the Fourteenth Amendment.The United States District Court for the Western District of Wisconsin dismissed Tire Town’s amended complaint, finding that Tire Town had not plausibly alleged deprivation of a property interest protected by due process. The court determined that neither Wisconsin law nor any contract, statute, or ordinance guaranteed Tire Town a spot on the towing rotation list. The Minimum Standards policy explicitly stated it was not a contract and gave the county broad discretion to remove companies from the list.The United States Court of Appeals for the Seventh Circuit reviewed the dismissal de novo. The appellate court affirmed the district court’s judgment, holding that Tire Town had not plausibly alleged a protected property interest in remaining on the towing rotation list. The court concluded that the Minimum Standards policy did not restrict the county’s discretion sufficiently to create a legitimate claim of entitlement, and Tire Town could not reasonably rely on the policy as a source of property rights. The court rejected arguments based on unwritten “mutually explicit understandings,” finding no basis in law or contract for a protected property interest. View "Tire Town Auto LLC v Wood County" on Justia Law

The plaintiff, a pretrial detainee, was incarcerated for two and a half years in a county jail operated by Milwaukee County, which contracted with Wellpath, LLC to provide medical and mental-health services. Upon arrival, the plaintiff disclosed a history of traumatic brain injury and post-traumatic stress disorder, as well as other ailments, and claimed he was actively being treated before detention. The record lacks medical documentation from either before or during detention and contains limited information on his evaluation or treatment in the jail. During the COVID-19 pandemic, detainees, including the plaintiff, were subjected to frequent and lengthy lockdowns, which sometimes involved disabling toilets in cell blocks due to flooding. The plaintiff consistently filed grievances regarding inadequate mental-health care, lack of veteran services, physical pain, and unsanitary conditions within the facility.The plaintiff initiated a pro se lawsuit under 42 U.S.C. § 1983 against the county, alleging unconstitutional conditions of confinement and inadequate medical care. The United States District Court for the Eastern District of Wisconsin, after screening the complaint, allowed several claims to proceed but ultimately granted summary judgment in favor of the county. The magistrate judge concluded that the plaintiff had not shown the lockdown policies were unconstitutionally excessive, that the cited unsanitary conditions were objectively serious or pervasive, or that the medical care provided was constitutionally deficient or attributable to a county policy or practice under Monell v. Department of Social Services.The United States Court of Appeals for the Seventh Circuit reviewed the grant of summary judgment de novo. The court held that, despite serious allegations and the plaintiff's challenging circumstances, the evidence in the record did not raise a triable issue of material fact as to whether any of the alleged conditions or medical care rose to the level of a constitutional violation. Therefore, the Seventh Circuit affirmed the district court’s grant of summary judgment in favor of Milwaukee County. View "Lee v Milwaukee County, Wisconsin" on Justia Law

A young elementary school student with disabilities was placed by agreement of his parents and local school district in a special education classroom at his neighborhood school due to behavioral struggles. Three weeks after this placement, the school district proposed an Individualized Education Plan (IEP) that would move the student to a private therapeutic day school in another district, requiring lengthy daily bus rides and removing him from his local environment and peers. The parents objected, believing that this more restrictive placement violated their son’s rights under the Individuals with Disabilities Education Act (IDEA), and requested a due process hearing.An independent hearing officer conducted several days of hearings and found in favor of the school district, concluding that the district had complied with the IDEA and that the proposed placement at the therapeutic day school was appropriate. The parents then sought judicial review in the United States District Court for the Central District of Illinois. At a bench trial, the district court considered new evidence, including testimony about the student's progress and potential benefits of additional supports in his current classroom. The district court found that the student had made significant progress and would benefit from a one-on-one aide, and concluded that the school district’s proposed placement would violate his right to an education in the least restrictive environment under the IDEA.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court's decision for clear error, giving due weight to the administrative record but acknowledging the significance of new evidence introduced at trial. The Seventh Circuit held that the district court did not make mistakes of law or clearly err in finding that the student could receive a satisfactory education in his local special education classroom with additional supports, and affirmed the district court’s order requiring the school district to create an appropriate IEP for that placement. View "N. T. v Galesburg Community Unit School District No. 205" on Justia Law

The petitioner, a Muslim from India, managed a family slaughterhouse business that became a target for hostility from local Hindus affiliated with the Bharatiya Janata Party, who viewed cows as sacred. In May 2016, he and his mother were attacked by a group who demanded that the slaughterhouse be closed; the incident resulted in minor injuries and police intervention. Shortly after, he entered the United States on a visitor visa but overstayed. He did not apply for asylum until January 2019, well past the one-year statutory deadline.Following his application, the U.S. Citizenship and Immigration Services rejected it as untimely. Removal proceedings were initiated, and the immigration judge found no extraordinary circumstances excusing the late filing, denying his asylum application as untimely. The judge also denied requests for withholding of removal and protection under the Convention Against Torture, finding insufficient evidence of past or future persecution. The Board of Immigration Appeals reviewed and affirmed these decisions, dismissing his appeal.The United States Court of Appeals for the Seventh Circuit reviewed his petition. Relying on existing circuit precedent, the court held it lacked jurisdiction to review the immigration judge’s determination that the asylum application was untimely, as the petitioner did not present arguments addressing the jurisdictional issue and the challenge involved factual rather than legal questions. On the merits of withholding of removal, the court applied the substantial evidence standard and concluded that the record did not compel a finding of past persecution or a likelihood of future persecution, given the limited harm suffered, the lack of government complicity, and the petitioner's ability to relocate within India. The court dismissed the petition regarding asylum for lack of jurisdiction and denied it in all other respects. View "Mohammed v Blanche" on Justia Law

After suffering a workplace injury just two months into his role as an immigration officer at the United States Citizenship and Immigration Services (USCIS), the plaintiff took medical leave and received workers’ compensation for more than three years. When it became clear that he could not return to work, the agency terminated his employment. He challenged this decision before the Merit Systems Protection Board (MSPB), which ordered his reinstatement based on new medical opinions indicating he could return with restrictions. However, his attempt to resume work was unsuccessful due to worsening symptoms, and he quickly returned to medical leave. During his extended absence, the Office of Inspector General investigated his freelance activities, ultimately concluding that he had misused his federal position. The agency terminated him again.The plaintiff then filed complaints with the USCIS Office of Equal Opportunity and Inclusion and the Equal Employment Opportunity Commission (EEOC), alleging disability discrimination, failure to accommodate, a hostile work environment, and retaliation under the Rehabilitation Act. After EEOC proceedings concluded against him, he filed suit in the United States District Court for the Northern District of Illinois. The district court entered summary judgment for the Secretary of Homeland Security, finding that most of the claims were unexhausted because the plaintiff did not timely pursue administrative remedies. The court also found that, on the merits, he was not a “qualified individual” under the Rehabilitation Act because he could not perform the essential functions of his job, and that there was insufficient evidence of a hostile work environment or retaliation.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed only the accommodation and hostile-workplace claims. The court held that both claims were barred for failure to timely exhaust administrative remedies. Alternatively, the court held that the claims also failed on the merits. The judgment of the district court was affirmed. View "Shiba v Mullin" on Justia Law

Adam Blocker used Dropbox, a cloud storage service, to share files, some of which contained child pornography. Dropbox detected these illegal files through its own monitoring, as permitted by its terms of service, and reported them to the National Center for Missing and Exploited Children (NCMEC). Following this report, NCMEC notified federal authorities, which led the FBI to obtain a search warrant for Blocker’s digital storage. The subsequent search uncovered additional illegal images. Blocker pleaded guilty to two counts related to possession and distribution of child pornography, but reserved the right to appeal the denial of his motion to suppress the evidence obtained from Dropbox and his devices.In the United States District Court for the Northern District of Illinois, Eastern Division, Judge Lee denied Blocker’s suppression motion. The court concluded that Blocker had consented to Dropbox’s search and disclosure of his files by agreeing to its terms of service. Blocker argued that the terms were not specific or clear enough to constitute voluntary consent, especially because NCMEC is a government-affiliated entity. After Judge Lee’s elevation to the appellate court, the case was transferred to Chief Judge Kendall, who oversaw Blocker’s sentencing.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s decision. The court held that Blocker’s acceptance of Dropbox’s terms of service constituted effective consent for Dropbox to scan his files and disclose them for certain purposes, including reporting to authorities. The court rejected Blocker’s argument that the consent was invalid because the terms did not obligate Dropbox to search every file or regularly disclose information. The Seventh Circuit found no clear error in the district court’s finding of consent, and thus upheld the denial of the motion to suppress. View "USA v. Blocker" on Justia Law

A group of consumers residing in California purchased products online from a national retailer’s website between 2020 and 2022. To complete their purchases, they were required to agree to the retailer’s Terms and Conditions, which included an arbitration clause mandating that any disputes be resolved through arbitration before the American Arbitration Association (AAA) and that certain pre-arbitration steps be followed. When the consumers later believed that the retailer had engaged in false and deceptive marketing, they followed the pre-arbitration process as outlined, served notices of dispute, attempted mediation, and, after those efforts failed, filed demands for arbitration with the AAA and paid all required fees.After the consumers initiated arbitration, the AAA notified the parties that the retailer had not filed its arbitration agreement with the AAA as required by AAA rules. The AAA requested compliance, but the retailer refused to register its agreement. As a result, the AAA, following its Consumer Arbitration Rules, terminated the arbitration proceedings and closed the consumers’ cases. The consumers then filed a petition in the United States District Court for the Eastern District of Wisconsin seeking to compel arbitration, arguing that the retailer’s refusal to register the agreement and pay related fees constituted a refusal to arbitrate under the Federal Arbitration Act.The district court denied the petition, relying on precedent which holds that, when arbitration proceeds and ends in accordance with the agreed rules—even if terminated by the arbitral forum for procedural reasons—a court may not intervene to compel further arbitration. The United States Court of Appeals for the Seventh Circuit affirmed, holding that because the parties’ agreement delegated procedural questions to the AAA and the AAA exercised its discretion under its rules in terminating the proceedings, there was no refusal to arbitrate that would justify judicial intervention under the Act. View "Bernal v Kohl's Corporation" on Justia Law

The petitioner, a noncitizen, entered the United States without inspection in 2004 and, after surviving a car accident and being detained, was served with a notice to appear at a Chicago immigration hearing. The notice did not specify the date and time of the hearing; a later notice with that information was sent to an Indiana address provided by the petitioner during her detention. The petitioner claims she never lived at that address, having moved to Ohio after the accident. She failed to appear at the hearing and was ordered removed in absentia. No action was taken on the removal order for sixteen years.Years later, the petitioner filed a motion to reopen her removal proceedings, citing the Supreme Court’s decisions in Pereira v. Sessions and Niz-Chavez v. Garland, which clarified notice requirements for removal hearings. She argued these decisions should allow equitable tolling of the deadline to reopen her case and render her eligible for cancellation of removal. The Immigration Judge denied her motion, finding no basis for equitable tolling and declining to reopen sua sponte. While her appeal to the Board of Immigration Appeals was pending, she filed a second motion to reopen, arguing for the first time that she had not received proper notice of the hearing. The Board found this second motion was numerically barred and rejected her lack-of-notice claim.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that Niz-Chavez does not equitably toll the statutory deadline to reopen a final order of removal when the claimed defect could have been raised earlier with diligence. It also held that the petitioner’s second motion was properly denied as numerically barred. The court further dismissed, for lack of jurisdiction, the claim that the Board erred by declining to reopen the case sua sponte, as no constitutional or legal error was identified. The petition for review was denied in part and dismissed in part. View "Coatl-Chiquito v Blanche" on Justia Law

Glenn Wooden was caught selling nearly 100 grams of methamphetamine to confidential informants in a series of controlled buys organized by the West Central Illinois Task Force. Police obtained audio and video evidence of the transactions, searched Wooden’s apartment, and found an additional 222 grams of methamphetamine packaged for distribution, along with proceeds from the sales. After his arrest, Wooden confessed on video to distributing methamphetamine, describing the substance as “hot”—slang for illegal. He was indicted on three counts of distributing and one count of possessing methamphetamine.At trial in the United States District Court for the Central District of Illinois, Wooden represented himself. He did not dispute the facts but argued that the government failed to prove the methamphetamine involved was the specific “optical isomer” form that is illegal under federal law, asserting that not all methamphetamine is criminalized by the Controlled Substances Act. He raised this defense throughout trial and in a post-trial motion. The district court rejected his argument, instructed the jury using the Seventh Circuit’s pattern instructions that treat “methamphetamine” as a generic term, and clarified to the jury that all methamphetamine is illegal. Wooden was convicted on all counts and sentenced to 25 years in prison.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and held that the Controlled Substances Act criminalizes the possession and distribution of methamphetamine generically, not limited to specific isomers. The court affirmed the district court’s instructions and found the government’s evidence sufficient. The Seventh Circuit also found no error in allowing testimony from a DEA chemist and declined to adopt Wooden’s narrow statutory interpretation. The district court’s judgment was affirmed. View "USA v Wooden" on Justia Law