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

American Airlines contracted with a uniform manufacturer to provide new apparel for its employees. After distribution, many employees reported health issues, including skin and respiratory symptoms, allegedly connected to wearing or being near the uniforms. The airline allowed employees to stop wearing the uniforms, ultimately replacing them. Laboratory and government testing found low levels of chemicals in the uniforms but concluded these were unlikely to cause the reported symptoms. Multiple alternative causes were identified, and the scientific evidence did not support the employees' claims.A group of employees sued American Airlines, the manufacturer, and others in the United States District Court for the Northern District of Illinois, initially seeking class certification under the Class Action Fairness Act (CAFA). After several amended complaints and significant discovery disputes, the plaintiffs dropped their request for class certification, briefly raising questions about the court’s subject matter jurisdiction under CAFA. They later re-pled their class allegations in a fourth amended complaint, and the district court determined it retained jurisdiction. The defendants moved for summary judgment and to exclude the plaintiffs’ expert witnesses, arguing these experts were essential to prove defect and causation.The United States Court of Appeals for the Seventh Circuit reviewed the case. It held that the district court properly retained jurisdiction under CAFA after plaintiffs reasserted class claims. The Seventh Circuit affirmed the exclusion of the plaintiffs’ experts due to unreliable methodologies. It further held that, without expert evidence, the plaintiffs could not establish a defect or causation under strict or negligent products liability. The court also held that neither the Tweedy doctrine nor res ipsa loquitur provided an evidentiary shortcut under the case facts, since the alleged injuries did not inherently indicate a product defect or negligence. The judgment for the defendants was affirmed. View "Zurbriggen v Twin Hill Acquisition, Inc." on Justia Law

A man was reported by a caller to have exposed himself in a public area of the Forest Preserve. The caller provided a description of the suspect and his vehicle. Officer Jackson responded, met the complainant at the scene, and was told the suspect was still present. Officer Jackson then located the plaintiff, who substantially matched the description and was driving the specified vehicle. The plaintiff was detained, cited for public indecency, and his vehicle was authorized to be towed. The plaintiff exhibited signs of distress and told the officer he suffered from PTSD. The complainant later left the scene, so the only evidence of the alleged offense was the initial call. The citation was dismissed for lack of evidence.The plaintiff brought suit in the United States District Court for the Northern District of Illinois, Eastern Division, alleging Fourth Amendment violations for unreasonable seizure of his person and property, a Monell claim against the Forest Preserve, intentional infliction of emotional distress, and malicious prosecution under Illinois law. The district court granted summary judgment to the defendants on all counts. The court deemed the defendants’ statements of fact admitted because the plaintiff failed to properly respond under Local Rule 56.1, and found that probable cause existed for the detention and vehicle seizure. The court also held the officer’s comments did not rise to the level of extreme and outrageous conduct required for an emotional distress claim.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s grant of summary judgment de novo, accepting the defendants’ facts as admitted. The Seventh Circuit held that probable cause existed to detain the plaintiff and seize his vehicle under the applicable ordinance, defeating the Fourth Amendment and malicious prosecution claims. The court also found no basis for intentional infliction of emotional distress under Illinois law. The judgment was affirmed. View "Echevarria v. Jackson" on Justia Law

The case centers on two former executives, one the CEO of an Illinois utility company and the other a lobbyist, who were involved in a series of transactions with the Speaker of the Illinois House of Representatives and his associates. These transactions included setting up contracts, some of which were for no-show jobs, that funneled over $1.3 million to the Speaker's associates over several years. The prosecution alleged that these payments were made in exchange for favorable legislative actions, and that the defendants falsified corporate books and records to conceal these arrangements, in violation of federal statutes including the Foreign Corrupt Practices Act.In the United States District Court for the Northern District of Illinois, Eastern Division, the jury convicted both defendants on all counts, including conspiracy, bribery under 18 U.S.C. § 666, and falsification of books and records. The jury’s verdict was general, without specifying which object of the conspiracy formed the basis for conviction. After the trial, but before sentencing, the Supreme Court decided Snyder v. United States, which limited the scope of § 666 to quid pro quo bribery, excluding illegal gratuities. Based on Snyder, the district court vacated the § 666 convictions and denied the defendants' motions for acquittal or a new trial on the remaining conspiracy and FCPA counts.The United States Court of Appeals for the Seventh Circuit reviewed the case and vacated the conspiracy and FCPA convictions. The court held that because the jury instructions allowed conviction based on legally invalid objects (now invalid under Snyder), and it was unclear on which theory the jury relied, the convictions could not stand. The court further rejected the argument that recent case law required acquittal on the FCPA counts, finding sufficient evidence for a properly instructed jury to convict. The court remanded for possible retrial at the government’s discretion. View "USA v Pramaggiore" on Justia Law

In 1977, Louise Betts was kidnapped, raped, and murdered in Boone County, Illinois. The county coroner, Wesley Hyland, conducted an autopsy and returned her body to her family for burial. Decades later, it was revealed that Hyland had secretly kept Louise’s skull, along with the skulls of other deceased individuals, as macabre trophies. In 2022, after Hyland’s death, the coroner’s office notified Louise’s brothers, Gary and Earl, of the skull’s existence, which led the family to exhume her casket to reunite her remains.The Betts brothers filed a lawsuit in the United States District Court for the Northern District of Illinois, Western Division, against Boone County and the current coroner, alleging that the county, through Hyland’s actions, violated their Fourteenth Amendment due process rights by retaining Louise’s skull without notice. They pursued their claim under 42 U.S.C. § 1983, arguing that Hyland’s conduct constituted an official county policy of unconstitutionally retaining property. The district court allowed them to amend their complaint several times but ultimately dismissed the case for failure to state a claim, concluding that Hyland’s actions did not represent official county policy under Monell v. Department of Social Services of City of New York.Upon review, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The Seventh Circuit held that the county was not liable under Monell because Illinois law expressly requires coroners to return all bodily remains to the next of kin. Hyland’s actions were contrary to, rather than representative of, official county policy. The court concluded that a municipality cannot be held liable under § 1983 when its official acts in direct violation of state law, and thus, no official policy of unconstitutional retention was established by Hyland’s conduct. View "Betts v Boone County" on Justia Law

Police in Milwaukee received information from a confidential informant identifying a drug dealer known as “Blessed,” who was described as armed and driving a red BMW. Investigation linked the BMW to Latia Johnson at a residence on North 42nd Street, and records showed Johnson was the girlfriend of Fernando Bolden, whom the informant identified as “Blessed.” Surveillance video captured Bolden arriving at the residence with a gun and entering the house. A few days later, police obtained a warrant to search the residence, finding firearms, ammunition, large amounts of cash, fentanyl, and other drugs.Bolden was initially prosecuted in Wisconsin state court, but after it was discovered he continued drug activity while on bail, a federal grand jury indicted him on multiple drug and firearm charges. He moved to suppress the evidence from the search, arguing that the affidavit for the warrant did not establish sufficient ties between him and the residence and contained material misrepresentations or omissions. A magistrate judge in the United States District Court for the Eastern District of Wisconsin concluded that the affidavit established probable cause or, at a minimum, that the officers acted in good faith reliance on the warrant. The district court found the affidavit lacking in probable cause but still denied the suppression motion, applying the good-faith exception, and also denied Bolden’s request for a Franks hearing. Bolden then entered a conditional guilty plea, reserving his right to appeal.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s denial of the suppression motion de novo, and its factual findings for clear error. The court held that, even if probable cause was lacking, the good-faith exception applied because the officers reasonably relied on the warrant and there was no evidence of deliberate or reckless misrepresentation or omission in the affidavit. The court affirmed Bolden’s convictions. View "USA v Bolden" on Justia Law

A customer was injured at a retail pharmacy when numerous beverage bottles fell from a cooler shelf, striking him and causing him to fall. The coolers in the store were stocked by both employees and independent beverage vendors, with vendors responsible for the majority of products and annual “resets” involving shelf removal and cleaning. Employees did not oversee these resets or move shelves due to their weight, and had limited interaction with the shelves apart from maintaining CVS products and general cleaning. On the day of the incident, the customer saw nothing unusual about the cooler shelf, but when he removed a bottle, many others fell, resulting in his injuries. Store staff responded promptly, but neither had ever seen such an incident or received reports of defective shelves.The customer filed a negligence claim in the Cook County Circuit Court, alleging the pharmacy was responsible for his injuries. The case was removed to the United States District Court for the Northern District of Illinois based on diversity jurisdiction. Following discovery, including expert testimony limitations, the district court held a bench trial. The court found the plaintiff failed to prove negligence under the doctrine of res ipsa loquitur because the evidence did not establish that the pharmacy had exclusive control over the cooler shelves, given the substantial involvement of third-party vendors.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s legal conclusions de novo and factual findings for clear error. The appellate court affirmed the district court’s judgment, holding that res ipsa loquitur did not apply since the plaintiff did not show that the defendant was more likely than not responsible for the injury. The court also found no abuse of discretion in the district court’s evidentiary rulings and limitations on expert testimony. View "Khouri v Highland Park CVS, L.L.C." on Justia Law

This appeal concerns attorney fee allocation following the settlement of multidistrict litigation related to alleged injuries caused by Seresto flea and tick collars. Plaintiffs across the country, including Laura Revolinsky, brought class actions against Bayer and Elanco, claiming the products harmed their pets. Revolinsky’s attorneys sought to have these cases consolidated in New Jersey, while other plaintiffs’ counsel advocated for centralization in Missouri. The Judicial Panel on Multidistrict Litigation ultimately transferred the cases to the Northern District of Illinois, where the district court appointed lead and liaison counsel, but did not appoint Revolinsky’s attorneys to leadership positions. The court entered a case management order requiring counsel to seek advance approval for compensable work and to submit monthly reports; it generally limited compensation to work performed after leadership was appointed, though it allowed lead counsel some discretion to compensate earlier work if it benefited the class.After settlement was reached and a fund established, lead counsel applied for attorney fees, excluding pre-transfer and untimely work by Revolinsky’s attorneys. The district court approved the settlement and fee allocation, and Revolinsky’s attorneys later discovered their compensation was much less than anticipated. They did not timely object to the allocation or procedures. Instead, months after the deadline, they filed a separate motion seeking additional compensation for pre-transfer and untimely work.The United States Court of Appeals for the Seventh Circuit reviewed only the denial of this later motion. The court held that the district court did not abuse its discretion in denying the untimely motion because the procedures and deadlines for fee submissions were clear and had been reasonably enforced. The court affirmed the district court’s order, emphasizing that objections to fee allocations must be raised in a timely manner under court-established protocols. View "Revolinsky v Bayer Corporation" on Justia Law

Two individuals filed Chapter 13 bankruptcy petitions, each proposing repayment plans that prioritized payment of their attorneys’ fees before distributing funds to nonpriority unsecured creditors, such as the City of Chicago. Both debtors had below-median incomes and lived in Illinois. One plan proposed to pay secured and priority creditors, the trustee, and attorneys’ fees, with any leftover funds distributed pro rata to nonpriority unsecured creditors. The other plan left no remaining funds for nonpriority unsecured creditors after paying attorneys’ fees.The City of Chicago objected to both plans in the United States Bankruptcy Court for the Northern District of Illinois. The City argued that these plans violated 11 U.S.C. § 1325(b)(1)(B) because they allocated projected disposable income to attorneys’ fees, claiming that bankruptcy attorneys are not unsecured creditors, and thus should not receive such payments. Alternatively, the City argued that even if attorneys are unsecured creditors, they were ineligible for payment because they had not filed proofs of claim. The bankruptcy court overruled the City’s objections, confirming both plans. The court adopted its reasoning from previous cases, finding that attorneys’ fees could be paid during the commitment period and that attorneys did not need to file proofs of claim for payment.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the bankruptcy court’s decision. The Seventh Circuit held that Chapter 13 plans may provide for the payment of attorneys’ fees before or at the same time as payments to nonpriority unsecured creditors during the commitment period, as required by other sections of the Bankruptcy Code. The court also held that bankruptcy attorneys, as holders of administrative priority claims, are not required to file proofs of claim to receive payment under the plan. View "City of Chicago v Falkner" on Justia Law

Jewel Sanitary Napkins, a Georgia-based company, sells feminine hygiene products that it claims provide health benefits, including products containing graphene. The company developed a market among the Amish community and advertised its products through Busy Beaver Publications, which circulates regional advertising papers to that community. In August 2022, Busy Beaver published an ad submitted by a reader, Betty Lantz, that questioned the safety of Jewel's products, suggesting that graphene could attract electrical waves or radiation and pose health risks. The ad was published anonymously at Lantz’s request. Jewel asserted that the ad contained false statements and damaged its reputation.After the ad’s publication, Jewel contacted Busy Beaver to request a retraction, but Busy Beaver instead offered free advertising, consistent with its policy of not issuing retractions. Jewel declined and sued in the United States District Court for the Western District of Wisconsin for libel and trade libel. During discovery, Jewel sought the original ad submission. Busy Beaver initially believed the form had been destroyed per company practice, but later obtained it from Lantz and provided it to Jewel. Jewel withdrew a related spoliation motion but then sought sanctions over the delay. The district court denied Jewel’s motions, including a request to reopen summary judgment briefing, and granted summary judgment to Busy Beaver.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. It held that, under Wisconsin law and the First Amendment standard for public figures, Jewel failed to present evidence that Busy Beaver acted with actual malice when publishing the ad. The appellate court also found no abuse of discretion in denying sanctions against Busy Beaver. The court affirmed the district court’s judgment in favor of Busy Beaver. View "Jewel Sanitary Napkins, LLC v Busy Beaver Publications, LLC" on Justia Law

Joshua Schatz was charged with possessing child pornography in violation of federal law and pled guilty, reserving his right to appeal the application of a statutory enhanced mandatory minimum sentence. The enhancement applies to defendants with a prior state conviction “relating to aggravated sexual abuse, sexual abuse, or abusive sexual conduct involving a minor or ward.” Schatz’s prior conviction was for child molesting under Indiana Code § 35-42-4-3(b), which prohibits sexual contact with children under fourteen. He argued that Indiana’s statute, protecting victims up to fourteen years old and lacking certain federal requirements (like an age-difference between offender and victim), was not sufficiently congruent with federal sex-abuse statutes, which generally protect children under twelve absent an age difference.The U.S. District Court for the Southern District of Indiana applied recent Seventh Circuit precedent, including United States v. Liestman and United States v. Kraemer, which interpreted “relating to” in the enhancement provision broadly. The district court found that the Indiana statute triggered the enhancement, holding that differences in victim ages and other elements were immaterial under a broad reading of “relating to.” Schatz was sentenced to the mandatory minimum of ten years’ imprisonment, which was higher than the guidelines range he would have faced without the enhancement.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the statutory interpretation de novo. Applying the categorical approach and following its prior decision in Liestman, the court held that “relating to” should be read broadly, so Indiana’s child molesting statute categorically relates to the conduct described in the federal enhancement provision. The court affirmed the district court’s judgment, ruling that the enhancement was properly applied to Schatz’s sentence. View "United States v. Schatz" on Justia Law