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

An employee of the Chicago Transit Authority (CTA), represented by a union, was terminated after repeatedly failing to follow the proper procedure for reporting Family and Medical Leave Act (FMLA) absences. The CTA required employees to notify a third-party administrator, ReedGroup, as well as their work location, when taking FMLA leave. The employee, who is transgender and had previously advocated for workplace accommodations and insurance coverage related to his transition, applied for intermittent FMLA leave for back pain, but his application was denied after he failed to complete the required process for obtaining a third medical opinion. Despite the denial, he continued to report absences as FMLA leave only to his work location, not ReedGroup, resulting in his termination for falsification of leave.After his discharge, the employee sought the union’s assistance in contesting his termination and pursued the available grievance and arbitration procedures. He also filed charges with the Equal Employment Opportunity Commission, then sued both the CTA and the union in the United States District Court for the Northern District of Illinois, Eastern Division. He asserted claims of transgender discrimination and retaliation under Title VII, as well as FMLA interference and retaliation against the CTA, and a municipal liability claim. The district court granted summary judgment in favor of the CTA and the union, concluding that the employee had failed to produce evidence that would allow a reasonable jury to find in his favor.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The court held that the employee failed to provide sufficient evidence that similarly situated non-transgender employees were treated more favorably, or that the CTA or the union’s actions were pretextual or motivated by discriminatory or retaliatory animus. The court also found no error in the exclusion of evidence and upheld the dismissal of the FMLA claims. The summary judgment for both defendants was affirmed. View "Brown v Chicago Transit Authority" on Justia Law

Michael Jezior worked as an engineer-paramedic for the Chicago Fire Department until a stroke in 2013 left him with limited mobility. Unable to perform his original duties, Jezior was reassigned to a procurement position at O’Hare Airport. In 2021, Jezior became eligible for promotion to lieutenant. However, the Department informed him that all available lieutenant positions at the airport required active firefighting, which he could not perform due to his disability. Jezior was offered the option to seek an accommodation for a different lieutenant position or to remain in his current role without promotion. He declined to pursue the accommodation process, fearing it could result in medical disqualification and early retirement, and chose to stay in his current position. Jezior then sued the City of Chicago under the Americans with Disabilities Act (ADA), claiming denial of a reasonable accommodation and disability discrimination.The United States District Court for the Northern District of Illinois, Eastern Division, granted summary judgment for the City. The court found that Jezior was not a “qualified individual” for the lieutenant position at the airport because he could not perform the essential firefighting functions. It further held that the ADA does not require an employer to create a new position or provide the employee’s preferred accommodation.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The Seventh Circuit held that Jezior was not qualified for the requested promotion because he could not meet the essential job requirements. The court also determined that the City was not obligated to provide Jezior his preferred accommodation or to promote him in place. Additionally, the court found no evidence of pretext or disparate treatment compared to similarly situated employees. The judgment for the City was affirmed. View "Jezior v City of Chicago" on Justia Law

Robert Hossfeld received twelve telemarketing calls advertising Allstate Insurance products, despite having previously requested that Allstate not contact him. The calls were made by Atlantic Telemarketing Center, which had been subcontracted by Transfer Kings, a company retained by Allstate’s insurance agents, Fleming and Gilmond. Allstate’s internal do-not-call list included Hossfeld’s number months before the calls occurred. Neither Allstate nor its agents were aware that Atlantic was involved in marketing Allstate insurance until after Hossfeld initiated his lawsuit.Hossfeld sued Allstate in the United States District Court for the Northern District of Illinois, alleging violations of the Telephone Consumer Protection Act (TCPA) because Allstate failed to maintain an adequate do-not-call policy and permitted calls to be made to him after his request. He also sought class certification for other similarly affected individuals. The district court denied class certification, finding Hossfeld had not demonstrated that the proposed class was sufficiently numerous. On cross-motions for summary judgment, the district court ruled in Hossfeld’s favor, holding Allstate vicariously liable for Atlantic’s calls under agency law and awarding treble damages for willful violations.The United States Court of Appeals for the Seventh Circuit reviewed the case. The appellate court affirmed the denial of class certification, agreeing that Hossfeld failed to prove numerosity and impracticability of joinder. However, it reversed the district court’s summary judgment on liability, concluding that Hossfeld failed to show Allstate was liable for Atlantic’s calls under any theory of agency law, including subagency, apparent authority, or ratification. The Seventh Circuit clarified that the willfulness standard under the TCPA requires reckless or knowing conduct, not merely volitional acts. The court affirmed in part and reversed in part, directing judgment for Allstate. View "Hossfeld v Allstate Insurance Co." on Justia Law

The case concerns a worker who was employed as a ship painter at a shipyard in Indiana for twelve years. After being laid off in 2017, he filed a claim for workers’ compensation under the Longshore and Harbor Workers’ Compensation Act, alleging that he experienced breathing difficulties due to prolonged exposure to various lung irritants during his employment, including fumes from paints, paint thinners, sandblasting materials, and other chemicals. He had a history of health issues, including asthma, COPD, and emphysema, and was a longtime smoker who switched to vaping in 2015. Medical evidence was presented by both the claimant and the employer, with dueling expert reports on whether workplace exposures contributed to his lung conditions.The Department of Labor administrative law judge (ALJ) conducted a formal hearing. The ALJ found the claimant had suffered harm and that workplace conditions could have caused it, entitling him to a statutory presumption of causation. The employer rebutted this presumption, but after considering the evidence, the ALJ credited the claimant’s expert and concluded that workplace exposures contributed to his lung impairment. The ALJ awarded permanent partial disability benefits and medical expenses. The Office of the District Director later granted a reduced attorney’s fee award. The Benefits Review Board affirmed both the ALJ’s decision and the fee award, finding the factual and legal conclusions rational and supported by substantial evidence.The United States Court of Appeals for the Seventh Circuit reviewed the ALJ and District Director’s decisions directly. Applying the substantial evidence standard, the court held that the ALJ’s findings and conclusions regarding disability, causation, and the extent of impairment were supported by the record and consistent with applicable law. The court also found the employer’s challenge to the fee award waived for lack of record support and legal citation. The petition for review was denied, affirming the Board’s decision. View "Jeffboat, Inc. v Director, OWCP" on Justia Law

The case centers on a lawsuit filed by the Attorney General of Florida against the American Academy of Pediatrics (AAP) and other organizations, alleging that their advocacy for gender-affirming care violated several Florida statutes, including the state's Deceptive and Unfair Trade Practices Act, RICO Act, and antitrust law. The Florida enforcement action targeted AAP's policy statements and legal filings that supported access to gender-affirming care for transgender youth, with the Attorney General seeking significant monetary penalties and organizational restrictions. Although the lawsuit was publicized, there was a three-month delay before the organizations were served.Following the initiation of the Florida state court action, AAP, an Illinois nonprofit, filed a separate suit in the United States District Court for the Northern District of Illinois. AAP claimed that the Florida enforcement proceeding was brought in bad faith to retaliate against its First Amendment–protected advocacy. The district court granted a preliminary injunction to prevent the Florida Attorney General from pursuing the enforcement action against AAP and denied the Attorney General’s motion to dismiss, finding that personal jurisdiction and venue in Illinois were supported, and that the facts suggested the Florida action was brought in bad faith.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed only whether to stay the district court’s injunction during the expedited appeal. The Seventh Circuit denied the motion for a stay, holding that the Attorney General did not make a strong showing of likely success on the merits or irreparable harm. The court found that the bad-faith exception to Younger abstention applied based on the district court’s factual findings, and that jurisdiction and venue in Illinois were appropriate given the circumstances. The injunction against the Florida enforcement action remains in effect pending appeal. View "American Academy of Pediatrics v Uthmeier" on Justia Law

After serving a prison sentence for conspiracy to manufacture methamphetamine, the defendant began a term of supervised release, which included a condition that he refrain from any use of alcohol. The defendant, who is a practicing Messianic Jew, asked the court to modify this condition to allow him to drink a glass of wine during religious ceremonies on his Sabbath, arguing that the complete alcohol ban violated his rights under the Religious Freedom Restoration Act (RFRA) and imposed a greater deprivation of liberty than necessary under 18 U.S.C. § 3553(a). The defendant had a lengthy history of alcohol abuse intertwined with criminal behavior, including prior convictions related to intoxication and repeated violations of probation and supervised release conditions. Medical reports and court findings noted his inability to control alcohol consumption and recommended complete abstinence.The United States District Court for the Central District of Illinois denied the defendant’s motion to modify the supervised release condition. The court found that the government had a compelling interest in prohibiting the defendant from consuming alcohol entirely, given his history of rapid escalation from initial drinking to dangerous behavior. The court also found that alternatives—such as monitoring with breathalyzers—were not feasible for ensuring compliance and public safety, and therefore, a total ban was the least restrictive means to further the government’s interests.Reviewing the case, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The Seventh Circuit held that, under RFRA, the complete alcohol ban was the least restrictive means to further the government’s compelling interests in public safety, rehabilitation, and preventing recidivism, given the defendant’s history. The court also held that the condition did not involve a greater deprivation of liberty than necessary under § 3553(a). The district court’s denial of the motion to modify supervised release was affirmed. View "USA v Broadfield" on Justia Law

A university professor submitted requests under the Freedom of Information Act (FOIA) to a federal agency, seeking the files of three named immigration detainees. The agency was slow to respond, leading the professor to file a lawsuit in the United States District Court for the Northern District of Illinois. Over the course of the litigation, the agency provided some documents but was criticized for delays and for the quality of its responses, particularly concerning certain categories of records like grievances, commissary accounts, and work program participation. The agency’s explanations for its searches and redactions—detailed in a Vaughn index—were found lacking by the district judge, who was especially critical of redactions that seemed baseless or were applied to information already in the public domain. The judge questioned the good faith of the agency and its FOIA director, ordered all contested pages released without redaction, and required additional searches and explanations.After the agency appealed, the district judge entered an injunction intended to require release of the records, but the injunction was vague and did not specify precisely what documents had to be produced or by whom they were identified. This lack of clarity made enforcement problematic.The United States Court of Appeals for the Seventh Circuit reviewed the case. It held that while sanctions against the agency for its mishandling of the FOIA requests may be justified, the district court abused its discretion by ordering wholesale release of all documents, including information potentially affecting third parties and law enforcement interests, without adequate explanation or consideration of less drastic alternatives. The appellate court vacated the injunction for lack of sufficient detail and remanded the case with instructions to reconsider the sanction and limit disclosures to information about the agency’s own operations or privileges that the agency itself could waive. View "Stevens v. ICE" on Justia Law

Cornelius M. Jackson was investigated after Milwaukee police responded to reports involving a woman, AV-4, who initially denied any wrongdoing but later disclosed that Jackson had choked her, threatened her, and forced her into commercial sex work. AV-4 described Jackson’s control over her activities and earnings, and her account was corroborated by pole camera footage and a bystander’s report. Based on AV-4’s statements, Waukesha police sought and received a search warrant for Jackson’s residence, where they recovered multiple electronic devices and evidence linking him to sex trafficking. Jackson was indicted for four counts of sex trafficking by force, fraud, or coercion, and one count of conspiracy to engage in sex trafficking.In the United States District Court for the Eastern District of Wisconsin, Jackson moved to suppress evidence from his electronic devices, asserting the search warrant lacked probable cause and that the supporting affidavit omitted material facts, entitling him to a Franks hearing. He also objected to the admission of expert testimony regarding sex trafficking dynamics. The district court denied Jackson’s motions, found probable cause for the warrant, determined the omissions were not material, and permitted the expert to testify with limitations. After a jury convicted Jackson on all counts, he was sentenced to concurrent terms totaling 30 years’ imprisonment.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The court held that the warrant affidavit established probable cause, the omitted facts were not material enough to require a Franks hearing, and the district court did not abuse its discretion in admitting the government’s expert witness under Daubert and Rule 702. The judgment of conviction and sentence was thus affirmed. View "USA v. Jackson" on Justia Law

An industrial facility in Richmond, Indiana, owned by both private parties and the City of Richmond, caught fire in April 2023 and burned for more than a week. The fire caused the evacuation of nearby residents and allegedly released hazardous substances that damaged hundreds of properties and caused various injuries. Plaintiffs—both individuals and businesses—claimed that the private property owners’ failure to maintain the site and the City’s failure to remediate hazardous conditions after acquiring part of the property led to the fire. The lawsuit sought compensatory and punitive damages under several tort theories, including negligence, nuisance, trespass, and emotional distress.The plaintiffs initially filed their suit in the Wayne County, Indiana Circuit Court, but the defendants removed the action to the United States District Court for the Southern District of Indiana, arguing it qualified as a “mass action” under the Class Action Fairness Act (CAFA), and thus belonged in federal court. The district court, after briefing on whether the action fell within the CAFA “local event or occurrence” exception, concluded that the exception applied. The court found that all claims arose from the single fire event, which occurred in Indiana, and remanded the case to state court for lack of federal subject matter jurisdiction.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s remand order. The court held that the local event or occurrence exception in CAFA is jurisdictional, meaning it can be raised at any time and by the court sua sponte. The appellate court determined that all claims indeed arose from the single fire event and that the exception applied. Therefore, federal jurisdiction was lacking under CAFA. The Seventh Circuit affirmed the district court’s order remanding the case to state court. View "Craig v City of Richmond" on Justia Law

The Office of the Special Deputy Receiver (OSD), an Illinois non-profit that manages receiverships for insolvent insurance companies, purchased a Financial Institution Bond from Hartford Fire Insurance Company. The bond included coverage for computer systems fraud and for electronic mail initiated transfer fraud, subject to certain exclusions. Hackers infiltrated OSD’s Chief Financial Officer’s email account via a spear phishing attack, impersonated the CFO, and sent fraudulent instructions to other OSD employees, resulting in unauthorized wire transfers and a loss of nearly $4 million.OSD filed claims with both Hartford and another insurer. Hartford denied coverage, asserting that an exclusion in the bond applied to the loss. OSD sued both insurers in the United States District Court for the Northern District of Illinois, seeking declaratory relief and alleging breach of contract. The district court granted Hartford’s motion to dismiss under Rule 12(b)(6), finding that the policy’s exclusion for losses resulting from fraudulent instructions sent to OSD by email applied, and denied the other insurer’s motion. OSD later voluntarily dismissed its claims against the second company, and judgment was entered.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the dismissal de novo. The court held that the exclusion in Rider 17 of the Hartford bond unambiguously barred coverage for losses resulting from fraudulent email instructions sent to OSD—even if the sender was impersonating an internal employee—because the exclusion focused on the recipient, not the sender. The court found no ambiguity or conflict between the exclusion and other coverage provisions, and concluded that OSD’s losses fell outside the scope of coverage. The Seventh Circuit affirmed the district court’s dismissal of OSD’s claims against Hartford. View "Office of the Special Deputy Receiver v Hartford Fire Insurance Company" on Justia Law