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

Ashley Energy, an energy company in Missouri, experienced flooding at its plant and leased a boiler and water treatment trailer from Indeck Power Equipment to maintain operations. The lease required Indeck to provide a “like-new” boiler and new trailer, and Ashley to operate and maintain the equipment according to industry standards, specifically ABMA guidelines, and pay for repairs beyond ordinary wear and tear. After the boiler was returned, Indeck discovered scale and debris, attempted to clean it, and ultimately sued Ashley, alleging breach of contract and seeking over $3 million in damages. Ashley had previously sued Indeck in Missouri state court, but that case was dismissed due to a forum selection clause.The United States District Court for the Northern District of Illinois conducted a jury trial. The jury found that Indeck had performed its contractual obligations and that Ashley had breached the contract. However, the jury concluded that Indeck failed to prove it had sustained damages as a result of Ashley’s breach, finding insufficient evidence that Ashley’s actions directly caused damage beyond normal wear and tear. Indeck’s post-trial motions for a new trial and for attorneys’ and experts’ fees were denied, with the district court explaining that the verdict could be rationally explained by evidence that Indeck’s own actions or equipment contributed to any damage or that no damage beyond ordinary wear and tear occurred.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The appellate court held that the jury’s verdict was not irreconcilably inconsistent and was supported by plausible explanations from the record, and that Indeck was not entitled to attorneys’ fees as a non-prevailing party under the lease’s provisions. View "Indeck Power Equipment Co. v Ashley Energy LLC" on Justia Law

The case concerned the rights to publish an unpublished article, “Psychopathology of Awareness,” written by Dr. Frederick Perls. Dr. Perls’s widow, Laura Perls, inherited the copyright to this article. In 1991, her estate entered an agreement with the Center for Gestalt Development, granting the Center exclusive rights to publish a collection of Dr. Perls’s unpublished manuscripts, which included the article. However, the Center did not publish the collection until 2021. In the mid-2010s, Charles Bowman acquired a copy of the article and, together with Jean-Marie Robine, decided to publish it with additional commentary. Before publishing, Bowman and Robine sought and received permission from Dr. Perls’s children, who had inherited the copyright to the article itself, to include it in their book.After learning of Bowman and Robine’s plans, the Center contacted them to assert its own purported rights, but the Center refused their offers of collaboration. Bowman and Robine then obtained an oral license from the Perls siblings, communicated through Leslie Gold, authorizing them to use the article. In 2021, following litigation, the Perls siblings assigned their rights in the article to the Center until the conclusion of this lawsuit.The Center sued Bowman and Robine for copyright infringement in the United States District Court for the Southern District of Indiana. The district court found that the Center’s 1991 agreement conveyed rights only in the collection as a whole, not in the article individually. It further determined that Bowman and Robine had an irrevocable oral license to use the article before the Center acquired the copyright.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s entry of summary judgment for Bowman and Robine. The main holding was that ownership of a compilation copyright does not confer rights in the individual components, and the oral license granted to Bowman and Robine precluded infringement claims by the Center. View "Center for Gestalt Development, Inc. v Bowman" on Justia Law

Mary Jane Sweet Spot, LLC and its principal, Ashley McCoy, applied for a business license to operate a bakery in Blue Island, Illinois. After initially positive interactions with city officials, the license was denied based on the City’s finding that the applicants had hosted unapproved, paid events involving “infused” treats and entertainment, which the City deemed inconsistent with the intended bakery business. The City also cited evasive conduct by McCoy during inspections. The denial was sustained after an administrative hearing, and the applicants did not pursue further administrative review before the City Council as required by municipal code.Instead of completing the administrative review, the plaintiffs sought judicial review in the Circuit Court of Cook County, which dismissed the petition for failure to exhaust administrative remedies and for untimely filing. The Illinois Appellate Court affirmed the dismissal based on failure to exhaust administrative remedies. While that appeal was pending, the plaintiffs filed a federal suit in the United States District Court for the Northern District of Illinois, raising constitutional and state-law claims stemming from the license denial.The district court dismissed the federal suit for lack of subject matter jurisdiction, relying on the Rooker-Feldman doctrine, concluding that the plaintiffs were seeking review of a state-court judgment. On appeal, the United States Court of Appeals for the Seventh Circuit held that Rooker-Feldman did not apply because the plaintiffs’ alleged injuries resulted from the City’s administrative action, not the state-court judgment. The appellate court vacated the dismissal and remanded for further proceedings, noting that claim preclusion, not Rooker-Feldman, might bar the suit, but left that issue for the district court if raised by defendants. View "Mary Jane Sweet Spot, LLC v City of Blue Island" on Justia Law

Several candidates, including Georgia’s Lieutenant Governor and Secretary of State, sought the Republican nomination for Governor in Georgia’s 2026 primary. Under Georgia law, only certain officeholders, such as the incumbent Lieutenant Governor, could establish “leadership committees,” which allowed them to raise and spend unlimited funds and coordinate directly with their campaigns. Safe Affordable Georgia, a hybrid PAC chaired by Secretary Raffensperger, could not coordinate with his campaign or raise unlimited funds to support him.Safe Affordable Georgia filed suit in the United States District Court for the Northern District of Georgia against state officials, arguing that Georgia’s campaign finance scheme violated the First Amendment by treating it differently from leadership committees. The PAC sought a preliminary injunction to bar enforcement of contribution and coordination limits against it, aiming to support Raffensperger in the ongoing primary. The district court denied the request for emergency injunctive relief, and the PAC appealed to the United States Court of Appeals for the Eleventh Circuit.While the appeal was pending, the primary election concluded and Raffensperger’s campaign ended. The United States Court of Appeals for the Eleventh Circuit determined that, because the election was over and the PAC’s requested relief focused specifically on the 2026 primary, federal courts could no longer offer meaningful relief. The court held that the case was moot and did not qualify for the “capable of repetition, yet evading review” exception because there was no reasonable expectation the same situation would recur for the same party. The Eleventh Circuit dismissed the appeal and remanded the case to the district court with instructions to dismiss it as moot. View "USA v. Waeckerle" on Justia Law

The plaintiff, a former web designer with an associate’s degree in computer programming, sought supplemental security income and disability insurance benefits, claiming that depression, anxiety, and obsessive-compulsive disorder rendered him unable to work. He had received both inpatient and outpatient mental health treatment prior to his application. During two administrative hearings, he described significant difficulty with social interaction, compulsive behaviors, and daily functioning, although he managed some tasks independently and engaged in therapy and medication management.After his application was denied, the plaintiff requested a hearing before an Administrative Law Judge (ALJ). The ALJ found severe impairments, including depressive disorder, anxiety disorder, autism spectrum disorder, and ADHD, but ultimately concluded that the plaintiff did not meet the criteria for disability under the relevant statutory and regulatory framework. The ALJ determined that the plaintiff retained the mental capacity to perform simple, routine, repetitive tasks with accommodations and could work in jobs available in the national economy. The ALJ discounted certain expert opinions that found greater limitations, concluding those were inconsistent with the overall medical evidence and the plaintiff’s activities. The plaintiff then challenged this decision in the United States District Court for the Eastern District of Wisconsin, arguing that the ALJ failed to properly consider his OCD and related limitations. The district court affirmed the ALJ’s decision.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s ruling de novo, applying a deferential standard to the ALJ’s findings. The appellate court held that the ALJ’s decision was supported by substantial evidence and complied with applicable regulations and precedents. The court rejected the plaintiff’s arguments regarding the treatment of his OCD and the weighing of medical opinions. The judgment of the district court was affirmed. View "Lewis v Bisignano" on Justia Law

Two individuals loaned money to entities for which a third person guaranteed repayment. When those loans went unpaid, the lenders obtained a default judgment of approximately $4.5 million against the guarantor. The guarantor did not pay the judgment, leading the lenders to initiate post-judgment proceedings to discover and collect his assets. They issued a citation on funds previously held in escrow by a lender as security for loans on properties owned by entities the guarantor controlled. After property sales fully repaid the loans, the escrowed funds remained frozen pending resolution of who was entitled to them. Several limited liability companies (LLCs) associated with the guarantor, as well as his estranged wife, intervened, each asserting claims to the funds.The United States District Court for the Northern District of Illinois appointed a Special Master to determine the ownership of the escrowed funds. After discovery and a hearing, the Special Master found that the funds belonged to the guarantor, not the LLCs, based on evidence that he exercised complete control over similar proceeds and used them for personal expenses without objection from the LLCs. The district court adopted these findings and ordered further proceedings to determine if the wife’s claim for unpaid child and spousal support had priority. Before those proceedings concluded, the wife and the lenders agreed to split the funds, and the district court approved this resolution, over objections from the LLCs.On appeal, the United States Court of Appeals for the Seventh Circuit held that it had jurisdiction over the LLCs’ appeal and dismissed the guarantor’s appeal for lack of standing. The court affirmed the district court’s determination that the escrowed funds belonged to the guarantor and could be used to satisfy the judgment. It also rejected the argument that the proceedings improperly pierced the corporate veil or violated procedural requirements under Illinois law. View "Zhu Zhai Holdings Limited v Ivankovich" on Justia Law

Several patients brought class action lawsuits against Indiana health care providers, alleging that their medical information was improperly shared with Facebook through the use of the Meta Pixel embedded in online patient portals. The plaintiffs asserted state law claims including breach of implied contract, unjust enrichment, and violations of the Indiana Deceptive Consumer Sales Act and Indiana Wiretapping Act. The health care providers had established these online portals to comply with federal regulations encouraging electronic health records, which offered incentive payments and imposed penalties for non-compliance.The health care providers removed the cases from Indiana state court to the United States District Court for the Southern District of Indiana, arguing that federal jurisdiction was proper under 28 U.S.C. § 1442(a)(1). They claimed they were “acting under” the Department of Health and Human Services when creating and maintaining their portals. District courts in multiple consolidated cases rejected this argument, finding that the providers did not meet the statutory requirements for removal under § 1442(a)(1). The courts concluded that while the providers were highly regulated and incentivized by federal policies, their actions did not amount to performing basic governmental tasks or operating under the direction of a federal officer.The United States Court of Appeals for the Seventh Circuit reviewed the consolidated appeals de novo. It held that compliance with federal regulations and incentives for patient portals did not constitute “acting under” a federal officer. The court found that the health care providers’ relationship to the federal government lacked the unusually close supervision and delegation required for federal officer removal. The court affirmed the district courts’ remand orders, holding that federal subject matter jurisdiction was not established under § 1442(a)(1). View "Chiaro v Methodist Hospitals, Inc." on Justia Law

Eric Holmes was convicted by an Indiana jury in 1992 of two counts of murder, attempted murder, robbery, and conspiracy to commit robbery, stemming from an incident at a restaurant. During sentencing, the jury could not unanimously recommend the death penalty, so the trial judge, as allowed by Indiana law at the time, found aggravating circumstances and imposed a death sentence. Holmes exhausted his direct appeals and post-conviction relief in state court, then filed a federal habeas corpus petition.While that federal petition was pending, Indiana amended its death penalty statute in 2002 to require jury findings on aggravating circumstances, in response to Apprendi v. New Jersey and Ring v. Arizona. In Saylor v. Indiana, the Indiana Supreme Court vacated a death sentence for a defendant whose jury had unanimously recommended against death, holding it inappropriate to execute someone sentenced under the old procedure. Holmes sought similar relief in state court, but the Indiana Supreme Court denied his request, distinguishing his case because his jury had not reached a recommendation at all, as opposed to Saylor’s unanimous recommendation against death.Holmes then filed a second federal habeas petition in the United States District Court for the Southern District of Indiana, claiming the Indiana Supreme Court’s decision violated his Fourteenth Amendment rights to equal protection. The district court dismissed the petition as “second or successive,” lacking jurisdiction. On appeal, the United States Court of Appeals for the Seventh Circuit disagreed with the district court’s procedural ruling, finding Holmes’s equal protection claim was not “second or successive” because it was not ripe during his first petition. However, the court affirmed the dismissal on the merits, holding the Indiana Supreme Court had a rational basis for treating Holmes differently, since his jury had not reached a unanimous recommendation, and thus there was no Equal Protection violation. View "Holmes v Neal" on Justia Law

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