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

Thirteen Black male defendants were tried together in the Central District of Illinois on charges related to alleged gang activities, including drug trafficking and violent crimes. During jury selection, the government used peremptory challenges to remove two prospective jurors: Juror 26, a Black man employed by the Peoria Housing Authority, and Juror 58, a Hispanic woman who taught at a local charter school. The defendants objected, contending that the government impermissibly struck the only two non-white members of the jury panel.The United States District Court for the Central District of Illinois initially overruled the Batson objections at step one, finding the defendants failed to establish purposeful discrimination. On appeal, the United States Court of Appeals for the Seventh Circuit determined that the district court had misapplied the Batson framework, particularly by imposing too high a burden at step one and by failing to make adequate findings at step three. The appellate court remanded the case for the district court to properly apply all three Batson steps.Upon remand, the district court reconsidered the Batson challenges, conducted a new analysis of all three steps, and found that while the defendants made a prima facie case as to Juror 26, the government provided credible, race-neutral reasons for striking both Juror 26 and Juror 58. The court concluded there was no purposeful discrimination.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s findings for clear error and found none. The appellate court affirmed the district court’s conclusion that the government’s peremptory strikes were not motivated by racial discrimination, thus rejecting the defendants’ Batson claims and affirming the judgment. View "USA v Watkins" on Justia Law

A Milwaukee County Sheriff’s deputy, while on duty and driving his unmarked vehicle, caused a fatal collision after running a red light at a controlled intersection. The deputy failed to notice the light change because he was distracted—looking at either his cellphone or his dashboard computer—for over 15 seconds as he approached the intersection. He was traveling at or just below the speed limit at the time. The victim, Ceaser Stinson, was lawfully passing through the intersection when his vehicle was struck and he was killed. Investigations confirmed the deputy’s inattention as the cause of the accident.Following the crash, Stinson’s estate filed a lawsuit in state court against the deputy, Milwaukee County, and the county’s insurer, alleging, among other claims, a violation of Stinson’s substantive due process rights under 42 U.S.C. § 1983. After removal to the United States District Court for the Eastern District of Wisconsin, the court dismissed some claims but permitted the estate’s § 1983 claim against the deputy to proceed. The defendants moved for summary judgment, arguing that the deputy’s conduct did not meet the threshold for a constitutional violation and that he was entitled to qualified immunity. The district judge denied the motion, concluding that a jury should decide whether the conduct was egregious enough to violate due process and deferred ruling on qualified immunity until after a jury verdict.The United States Court of Appeals for the Seventh Circuit reviewed the case and held that the estate failed to show the deputy acted with deliberate indifference to a known and imminent harm, as required for a substantive due process violation. The court further held that it was not clearly established that distracted driving by a law enforcement officer violates due process. Accordingly, the court reversed the district court’s judgment and ordered entry of judgment in favor of the deputy, finding him entitled to qualified immunity. View "Estate of Stinson v. Streicher" on Justia Law

Union Pacific Railroad operated intermodal facilities in Illinois where truck drivers were required to scan their fingerprints for identification between 2013 and 2021. Twelve truck drivers filed suit, alleging that this practice violated Illinois’s Biometric Information Privacy Act (BIPA). Union Pacific argued that it was exempt from BIPA due to its contracts with the State of Illinois and its subdivisions, including operating commuter trains for Metra and performing design work on overpasses and grade crossings. The plaintiffs countered that these contracts were unrelated to the intermodal freight operations where their biometric data was collected.The United States District Court for the Northern District of Illinois reviewed Union Pacific’s motion for summary judgment. The court found in favor of the plaintiffs, holding that the statutory exemption in BIPA only applied when a contractor was working in the course of fulfilling a state or local government contract, not merely because the contractor had any contract at the time. The district court denied summary judgment, and later certified its decision for interlocutory appeal under 28 U.S.C. §1292(b), prompting the Seventh Circuit to accept the appeal.The United States Court of Appeals for the Seventh Circuit considered whether the BIPA exemption for contractors of state agencies or local units applied broadly or only when the contractor is working in fulfillment of relevant contracts. The court looked to recent Illinois appellate decisions, which uniformly interpreted the exemption to mean “in the course of” working for the government. Concluding that the Illinois Supreme Court would likely adopt this interpretation, the Seventh Circuit affirmed the district court’s decision, holding that Union Pacific was not exempt from BIPA for its intermodal freight operations simply because it had unrelated contracts with government entities. View "Payton v Union Pacific Railroad Company" on Justia Law

Brooke Mason, a hospital pharmacist employed by Cook County Health at John H. Stroger Jr. Hospital, was terminated after refusing to comply with a mandatory COVID-19 vaccination policy, citing her Christian beliefs. The County had implemented the vaccine mandate in August 2021 to reduce virus transmission among staff and vulnerable patients. Employees could seek religious exemptions, but only those whose jobs could be performed fully remotely were eligible. Mason requested an exemption but was denied, given her in-person role, and was subsequently fired after being unable to secure a remote position.The United States District Court for the Northern District of Illinois, Eastern Division, granted summary judgment in favor of Cook County. The court assumed Mason could establish a prima facie case for religious discrimination under Title VII but concluded that no reasonable jury could find the County could accommodate her without undue hardship. The County provided evidence that allowing unvaccinated staff to work in-person during the pandemic would jeopardize safety and disrupt operations. The court also dismissed Mason’s disparate treatment claim, finding that the comparator employee (Sanitarian I) worked in a different department, location, and under different circumstances.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision de novo and affirmed the judgment. The Seventh Circuit held that the County met its burden to show that granting Mason’s requested accommodation would have resulted in undue hardship, considering Mason’s in-person role and the heightened risks in a hospital setting. The court also determined that Mason failed to identify a similarly situated employee for her disparate treatment claim. The district court’s grant of summary judgment was affirmed. View "Mason v Cook County" on Justia Law

A man who served as a confidential informant for the Department of Homeland Security became involved in criminal activity by continuing to deal drugs while cooperating with law enforcement. He developed a corrupt relationship with his handler, a special agent, who was later convicted of federal corruption charges. The informant’s unauthorized criminal conduct was uncovered when he became the target of two separate narcotics sting operations. Following his arrest, law enforcement searched his home and cell phone, and he was charged with multiple drug-related crimes.In proceedings before the United States District Court for the Northern District of Illinois, the defendant moved to suppress his post-arrest statements and evidence obtained from the warrantless searches of his home and cell phone. The district court suppressed his post-arrest statements as involuntary but denied suppression of the physical evidence, holding it admissible under the inevitable discovery doctrine. The court also denied his motions to dismiss for vindictive prosecution, sever various counts for trial, and quash a subpoena to his former handler, who invoked his Fifth Amendment right against self-incrimination. The case proceeded to a jury trial, where the defendant was convicted on three drug counts but acquitted on one. His post-trial motions for acquittal or a new trial were denied, and he was sentenced to 156 months in prison.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s rulings. The appellate court held that the district court did not abuse its discretion in quashing the subpoena, that the inevitable discovery doctrine applied to the search evidence, and that the evidence was sufficient to support the convictions. The court also determined that the defendant’s other claims were either waived or without merit, and it found no abuse of discretion in the sentence imposed. View "USA v Howard" on Justia Law

Employees at a truck dealership in Summit, Illinois, worked under a collective bargaining agreement through Laborforce and M&K Employee Services. In 2023, a union steward in the Parts Department, dissatisfied with union representation, initiated a decertification petition. Nineteen out of thirty-one Parts Department employees signed, but no Service Department employees did. Laborforce, responding without encouraging or interfering in the process, announced its intention to withdraw union recognition for the Parts Department after the three-year bar in the collective bargaining agreement expired. Laborforce also filed a unit clarification petition with the National Labor Relations Board (NLRB), which was denied. Nevertheless, Laborforce withdrew recognition and improved wages and benefits for Parts Department employees. In 2024, a second, broader decertification petition was signed by a majority of both Parts and Service Departments, prompting Laborforce to withdraw union recognition for all affected employees and again change compensation and benefits.The union filed multiple unfair labor practice charges with the NLRB, and the Board’s Regional Director issued an administrative complaint in June 2024. The complaint argued that the first withdrawal was unlawful due to lack of majority support and that the second withdrawal was tainted by the prior removal. An administrative law judge (ALJ) held a hearing in October 2024 and subsequently found Laborforce had committed unfair labor practices.Seeking immediate relief, the Director petitioned the United States District Court for the Northern District of Illinois for a preliminary injunction under NLRA § 10(j), requesting reinstatement of union recognition and reversal of wage and benefit changes. The district court denied the injunction, finding insufficient evidence of irreparable harm, likelihood of success, or public interest.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed. It held that the Director failed to show specific irreparable harm warranting the “extraordinary” § 10(j) remedy, especially given employee-initiated decertification and improved compensation. The delay in seeking an injunction further undermined the request. View "Hamada v Laborforce, LLC" on Justia Law

Consumers Concrete Corp. participated in a multiemployer pension plan administered by Central States Southeast and Southwest Areas Pension Fund. After making a partial withdrawal from the plan in 2017, Consumers fully withdrew in 2019, triggering statutory withdrawal liability for the complete withdrawal. The dispute focused on how to apply a credit for the prior partial withdrawal liability when determining the amount owed for the subsequent complete withdrawal. The parties agreed on the underlying figures for unfunded vested benefits and annual payments, but disagreed on whether the credit should be applied before or after the statutory cap limiting payments to twenty annual installments.Following Consumers’s challenge, an arbitrator adopted the Fund’s approach, applying the partial withdrawal credit at the second step of the statutory calculation process. Consumers appealed to the United States District Court for the Northern District of Illinois, Eastern Division. The district court consolidated the competing actions and vacated the arbitration award, siding with Consumers. It held that the credit should be applied after completing all four statutory steps, including the twenty-year payment limitation.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s legal conclusions de novo. It determined that the statutory language and structure favored Consumers’s interpretation, concluding that the partial withdrawal liability credit must be applied after the four-step process outlined in 29 U.S.C. § 1381(b), rather than at step two. The court’s holding was that the credit for prior partial withdrawal liability under 29 U.S.C. § 1386(b)(1) should reduce the fully-adjusted withdrawal liability amount determined after the application of all steps, including the twenty-year cap. The Seventh Circuit affirmed the district court’s judgment. View "Consumers Concrete Corp. v Central States, SE and SW Areas Pension Fund" on Justia Law

A mail carrier employed by the United States Postal Service in Carpentersville, Illinois, alleged that he was subjected to discrimination and retaliation based on his race and national origin, as well as a hostile work environment. The central incident occurred after a heated dispute over overtime with his supervisor, which escalated to yelling and profanity. The supervisor called police, who escorted the employee from the facility, after which he was placed on emergency leave without pay for two days. The employee later filed a grievance under the collective bargaining agreement, resulting in rescission of the emergency placement and compensation for lost pay. The employee identified additional workplace incidents, including timekeeping errors and a supervisor’s presence during a route observation, as part of an alleged pattern of discriminatory treatment.The United States District Court for the Northern District of Illinois granted summary judgment for the Postal Service on all claims. Because the employee failed to properly dispute the Postal Service’s Statement of Facts as required by local rule, the district court deemed those facts admitted. The court reviewed the evidence submitted, including deposition transcripts, and concluded that the employee had not established a prima facie case of discrimination, retaliation, or hostile work environment under Title VII.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision de novo. The Seventh Circuit found that the district court properly enforced its local rules and did not abuse its discretion. On the merits, the appellate court held that the employee failed to present evidence showing similarly situated comparators, a causal link for retaliation, or harassment based on a protected characteristic. The court affirmed the district court’s entry of summary judgment in favor of the Postal Service on all claims. View "Ismail v Steiner" on Justia Law

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