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

Plaintiff is confined at a treatment and detention facility in Illinois as a result of his designation as a sexually violent person for purposes of Illinois’s Sexually Violent Persons Commitment Act. Plaintiff filed this lawsuit against a facility employee and the facility’s rehabilitation director, arguing that the employee abused him because he is a homosexual and that the rehabilitation director suspended his treatment for complaining about it. The district court dismissed the case for failure to state a claim. The Seventh Circuit vacated the judgment and remanded, holding that Plaintiff stated a claim against both defendants under the Fourteenth Amendment. View "Hughes v. Farris" on Justia Law

Plaintiff applied for disability benefits, listing eight impairments. The Social Security Administration denied Plaintiff’s application and did so again on reconsideration. The next year, Plaintiff testified before an Administrative Law Judge (ALJ). The ALJ disbelieved Plaintiff’s testimony that she could not sit, stand, or walk for extended periods of time and denied Plaintiff’s application for Disability Insurance Benefits and Supplemental Security Income. The Appeals Council denied review, making the ALJ’s decision the final decision of the Commissioner of Social Security. Plaintiff challenged the ALJ’s adverse credibility finding on appeal. The Seventh Circuit reversed, holding that the ALJ’s analysis was flawed in several respects, and the ALJ’s mistakes in evaluating Plaintiff’s credibility were not harmless. Remanded. View "Hill v. Colvin" on Justia Law

Plaintiff worked for United Airlines as a ramp serviceman at O’Hare International Airport. Plaintiff twice injured his back at work. When he returned for the second time, he had several permanent work restrictions. United subsequently assigned Plaintiff to the Matrix position as part of the Product Sort work area. United later placed Plaintiff on extended illness status. Plaintiff filed suit against United for discrimination and retaliation under the Americans with Disabilities Act. Thereafter, Plaintiff returned to work for United in the Matrix position. Plaintiff then waived his retaliation claim and focused instead on whether United discriminated against him by failing to reasonably accommodate his disability. The district court granted summary judgment in favor of United. The Seventh Circuit affirmed, holding that United did not fail to reasonably accommodate Plaintiff’s disability. View "Dunderdale v. United Airlines, Inc." on Justia Law

Defendant was indicted for possession with intent to distribute 500 grams or more of cocaine. Defendant was released on a $200,000 bond secured by real property owned by his parents. When Defendant violated a condition of his release, the district court revoked his bond. After the bond revocation hearing, Defendant fled. Two days later, the government moved for a declaration of bond forfeiture. The district court subsequently entered an order of default judgment on the forfeiture agreement. The Seventh Circuit affirmed, holding that the district court did not abuse its discretion by refusing to set aside the bond forfeiture with Defendant still at large. View "United States v. Torres" on Justia Law

Plaintiff, an inmate at the Illinois Stateville Prison, filed a complaint against members of the prison staff, claiming that a prison prohibition against inmates receiving any magazine that “includes sexually explicit material that by its nature or content poses a threat to security, good order, or discipline” violates his First Amendment rights. The district judge granted summary judgment in favor of Defendants. The Seventh Circuit affirmed, holding that the prison regulation is valid because it is reasonably related to legitimate penological interests, and Defendant made no valid case against the district judge’s grant of Defendants’ motion for summary judgment. View "Payton v. Cannon" on Justia Law

Plaintiff was arrested for an alleged sexual assault, which allegation turned out to be false. Plaintiff brought this lawsuit against Defendants, Polk County and a Polk County investigator, advancing claims under 42 U.S.C. 1983 for false arrest and false imprisonment, and state common law claims for false imprisonment, malicious prosecution, negligence, and defamation. The district court granted summary judgment in favor of Defendants, concluding that the investigator had arguable probable cause to effect Plaintiff’s arrest and was entitled to qualified immunity and that Polk County could not be held liable under Monell v. Dep’t of Soc. Servs. The court declined to assert supplemental jurisdiction over Plaintiff’s state law claims and dismissed them without prejudice. The Seventh Circuit affirmed, holding (1) the investigator was entitled to qualified immunity because she reasonably believed probable cause existed to arrest Plaintiff; (2) there was no dispute as to any material fact with regard to Plaintiff’s Monell claims; (3) the district court did not abuse its discretion in dismissing without prejudice Plaintiff’s state law claims; and (4) the district court did not abuse its discretion in denying Plaintiff’s motion to alter or amend the judgment. View "Burritt v. Ditlefsen" on Justia Law

Backpage.com provides an online forum for classified ads and includes an “adult section.” The Sheriff of Cook County initiated a campaign to extinguish Backpage’s adult section - and, by extension, all of Backpage - by demanding that credit card companies prohibit the use of their credit cards to purchase any ads on Backpage since the ads might be for illegal sex-related services or products. Backpage sought a preliminary injunction to stop the sheriff’s actions, arguing that the sheriff was violating the First Amendment by curtailing freedom of expression. The district judge denied the motion for a preliminary injunction. The Seventh Circuit reversed, holding that the sheriff, in his capacity as a public official, violated the First Amendment by issuing and publicizing threats against credit card companies that process payments made through Backpage’s website, including threats of prosecution, in an effort to shut down Backpage. View "Backpage.com, LLC v. Dart" on Justia Law

Plaintiff was fired from her employment with the Fox Valley Workforce Development Board, Inc., a state job-training agency serving central Wisconsin with funding from the federal government. Approximately two years later, Plaintiff filed a qui tam action alleging that the Board violated the False Claims Act by improperly contracting services through a subsidiary corporation. Plaintiff also alleged that the Board fired her in retaliation for engaging in activity protected by the Act. The district court entered summary judgment in favor of the Board, concluding that Plaintiff’s claims lacked factual support. Plaintiff appealed. The Seventh Circuit (1) dismissed the qui tam claim for lack of jurisdiction, holding that the qui tam action was based on publicly disclosed information and was therefore barred by the Act; and (2) affirmed the judgment in all other respects, holding that Plaintiff’s retaliation claim failed on the merits. View "Ziebell v. Fox Valley Workforce Dev. Bd., Inc." on Justia Law

Plaintiff, an occasional employee of the Federal Emergency Management Agency, which is part of the Department of Homeland Security (DHS), filed an administrative claim of discrimination on the basis of her race, age, and sex. While the suit began as an administrative proceeding within the DHS, it molted into a judicial proceeding. Both the lawsuit and the administrative proceeding were based on Title VII of the Civil Rights Act of 1964. The federal district court granted DHS’s motion for judgment on the pleadings, concluding that Plaintiff had failed to exhaust her administrative remedies by failing to amend her original administrative complaint to add her retaliation claim. The Seventh Circuit reversed, holding that the district court erred in dismissing Plaintiff’s suit because it was the fault of the Equal Employment Opportunity Commission that the retaliation claim did not become part of the original case. Remanded. View "Moreland v. Johnson" on Justia Law

Mathew Neisler worked as a stockman in food service during his incarceration at the Waupun Correctional Institution. Three months after Neisler suffered work-related injury, he was fired for “medical” reasons. Neisler filed suit against defendant prison administrators, alleging that he had been fired because of a disability in violation of Title II of the Americans with Disabilities Act (ADA). Defendants filed motion for summary judgment, arguing, inter alia, that Neisler was not entitled to pursue an employment-discrimination claim under Title II. The district court granted summary judgment in favor of Defendants, concluding that Title II of the ADA covered Neisler’s claim but that no rational finder of fact could find disability discrimination. The Seventh Circuit affirmed but on different grounds, holding that Title II does not apply to a prisoner’s claim of employment discrimination in a prison job. View "Neisler v. Tuckwell" on Justia Law