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

Eido Hussam Al-Nahhas, an Illinois resident, took out four loans from Rosebud Lending LZO, operating as ZocaLoans, with interest rates up to nearly 700%, far exceeding Illinois law limits. Al-Nahhas alleged that ZocaLoans was a front for two private equity firms, 777 Partners, LLC, and Tactical Marketing Partners, LLC, to evade state usury laws by claiming tribal sovereign immunity through the Rosebud Sioux Tribe. He sued ZocaLoans and the firms for violating Illinois usury statutes and the federal Racketeer Influence and Corrupt Organizations Act.The defendants participated in litigation for fourteen months, including filing an answer, engaging in discovery, and attending status conferences. They later sought to compel arbitration based on an arbitration provision in the loan agreements. The United States District Court for the Northern District of Illinois denied the motion, finding that the defendants had waived their right to compel arbitration by participating in litigation.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's decision, holding that the defendants waived their right to arbitrate through their litigation conduct. The court also found that the case was not moot despite the settlement between Al-Nahhas and ZocaLoans, as punitive damages were still at issue. The court granted the parties' motions to file documents under seal. View "Hussam Al-Nahhas v 777 Partners LLC" on Justia Law

Dale Staten, a coal miner for nearly thirty years, retired in 2000 and passed away in January 2017 from respiratory failure after a two-week hospitalization. His widow, Bernadette Staten, filed for survivor benefits under the Black Lung Benefits Act. A Department of Labor administrative law judge (ALJ) awarded benefits, concluding that Bernadette qualified for a statutory presumption that Dale died from black lung disease due to his extensive underground mining work and total disability at the time of his death. The Benefits Review Board affirmed the ALJ's decision in a divided ruling.Consolidation Coal Company (CONSOL), Dale's former employer, challenged the ALJ's award, arguing that the 15-year presumption should only apply to chronic pulmonary conditions, not acute illnesses like Dale's respiratory failure. CONSOL contended that Dale's total disability was due to an acute condition rather than a chronic one. The ALJ had credited Dr. Sanjay Chavda's opinion that Dale was totally disabled at the time of his death, while discounting the opinions of CONSOL's experts, Dr. James Castle and Dr. Robert Farney, who argued that Dale was not disabled based on his medical history before his hospitalization.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the ALJ's award of benefits. The court held that the Black Lung Benefits Act does not require a claimant to prove that a miner's total disability arose from a chronic pulmonary condition to invoke the 15-year presumption. The court found that the ALJ acted within its authority in crediting Dr. Chavda's opinion and concluding that CONSOL failed to rebut the presumption that Dale's death was due to pneumoconiosis. The court denied CONSOL's petition for review and affirmed the judgment of the Benefits Review Board. View "Consolidation Coal Company v OWCP" on Justia Law

Manuel Antonio Herrera Hernandez, an inmate at Waupun Correctional Institution, alleged that his legal paperwork was misplaced during his temporary transfer to restrictive housing in October 2021. Before entering restrictive housing, Hernandez surrendered his personal property, including legal documents. Upon return, he signed a form indicating receipt of all his property but later realized his legal paperwork was missing. Hernandez claimed that Sergeant Theresa Lee assured him he would receive his paperwork once he returned to the general population, but it remained missing. Hernandez filed a grievance, which was rejected as untimely by the complaint examiner, and the warden affirmed this decision.Hernandez then filed a lawsuit in federal court under 42 U.S.C. § 1983, claiming that Sergeant Lee and other prison officials deprived him of his right of access to the courts. The United States District Court for the Eastern District of Wisconsin granted summary judgment for the defendants, ruling that Hernandez failed to exhaust administrative remedies.The United States Court of Appeals for the Seventh Circuit reviewed the case. Hernandez argued that his time in restrictive housing complicated his ability to file a timely grievance and that he was not provided a handbook explaining the grievance process in Spanish. The court found that Hernandez did not preserve the handbook issue in the district court. However, the court determined that there were genuine disputes regarding whether Hernandez had any reason to file a grievance before learning his paperwork was missing and whether Sergeant Lee's assurances excused his failure to exhaust administrative remedies.The Seventh Circuit reversed the district court's summary judgment and remanded the case for an evidentiary hearing to resolve the factual disputes regarding the exhaustion of administrative remedies. The court also noted the need to determine the personal involvement of the other defendants in the alleged deprivation. View "Hernandez v Lee" on Justia Law

Michael Wood incurred credit card debt with Pentagon Federal Credit Union (PenFed) and defaulted. PenFed reported the debt to credit reporting agencies, but Wood disputed the debt in writing. PenFed investigated and concluded the debt was valid. Later, Security Credit Services, LLC (SCS) purchased Wood's debt from PenFed and reported it as delinquent to a credit reporting agency without noting Wood's dispute. Wood alleged that SCS violated the Fair Debt Collection Practices Act (FDCPA) by failing to communicate that he disputed the debt.The United States District Court for the Northern District of Illinois granted summary judgment in favor of SCS. The court found that Wood had standing to sue but concluded that PenFed reasonably interpreted Wood's lack of response to its letter as an indication that he no longer disputed the debt. Therefore, the court determined that SCS did not know and should not have known that Wood still disputed the debt.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that Wood had standing because the harm he alleged was analogous to defamation, a recognized common law injury. The court also found that there was a genuine issue of material fact regarding whether SCS should have known about Wood's dispute. Specifically, the court noted conflicting evidence about SCS's understanding of what constitutes a disputed account and whether SCS shared PenFed's interpretation that Wood's silence meant he no longer disputed the debt. The court concluded that SCS's failure to communicate Wood's dispute could be considered negligent under the FDCPA. Consequently, the Seventh Circuit reversed the district court's summary judgment and remanded the case for further proceedings. View "Wood v. Security Credit Services, LLC" on Justia Law

Shawn Riley, a former prisoner at the Wisconsin Secure Program Facility (WSPF), filed a lawsuit under 42 U.S.C. § 1983 against WSPF’s Health Services Manager, Jolinda Waterman, and Nurse Practitioner Sandra McArdle. Riley alleged that they were deliberately indifferent to his serious medical needs, violating the Eighth Amendment. Riley experienced chronic pain and sought specific medical treatments, including high-top shoes recommended by specialists. Despite receiving various treatments, including medications, physical therapy, and custom orthotics, Riley claimed that his pain persisted and that the defendants ignored specialist recommendations.The United States District Court for the Eastern District of Wisconsin granted summary judgment in favor of the defendants and denied Riley’s motions to appoint counsel. The court found that the defendants were not deliberately indifferent to Riley’s medical needs, noting that they provided extensive medical care and followed many of the specialists' recommendations. The court also concluded that Riley’s requests for special shoes were reviewed and denied by the Special Needs Committee (SNC) and that the defendants' actions did not amount to deliberate indifference.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s decision, holding that the defendants did not ignore the specialists' recommendations and provided adequate medical care. The court also found that the defendants' refusal to allow Riley to purchase shoes from outside the approved catalog did not constitute deliberate indifference. Additionally, the court upheld the denial of Riley’s motion to appoint counsel, determining that Riley was competent to litigate his case and that the case did not present complexities that necessitated appointed counsel. The judgment of the district court was affirmed. View "Riley v. Waterman" on Justia Law

An inmate at Green Bay Correctional Institution, who is a practicing Muslim, filed a lawsuit under the Religious Land Use and Institutionalized Persons Act (RLUIPA) against the Wisconsin Department of Corrections (WDOC). He challenged WDOC's policy prohibiting inmates from leading religious programs when no outside religious leader or volunteer is available, claiming it resulted in unnecessary cancellations of religious programs. He also alleged that the cancellation of these programs breached a prior settlement agreement with WDOC.The United States District Court for the Western District of Wisconsin granted summary judgment in favor of WDOC on the RLUIPA claim, finding that the policy was the least restrictive means of furthering the compelling interest of maintaining prison safety and security. The court also granted summary judgment in favor of the inmate on the state law breach-of-contract claim as to liability but relinquished supplemental jurisdiction over the request for injunctive relief.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's summary judgment in favor of WDOC on the RLUIPA claim, agreeing that the policy was the least restrictive means to ensure prison safety and security. However, the appellate court vacated the district court's partial judgment on the state law breach-of-contract claim. The court held that the district court abused its discretion by relinquishing jurisdiction over the remedy portion of the claim while retaining jurisdiction over liability. The case was remanded to the district court to determine whether to retain or relinquish jurisdiction over the entire state law claim. View "West v Hoy" on Justia Law

Kevin Johnson, an inmate in Indiana, filed a pro se lawsuit under 42 U.S.C. § 1983, alleging that he received inadequate dental and mental health care while incarcerated. The case was complicated by the COVID-19 pandemic and Johnson's frequent transfers between prisons in Indiana, Ohio, and Virginia, which disrupted his mail service. Johnson claimed he never received the defendants' summary judgment motions due to these mail issues.The United States District Court for the Southern District of Indiana initially denied the defendants' summary judgment motions without prejudice, recognizing potential mail delivery problems. The court allowed the defendants to refile their motions and instructed them to notify the court if Johnson did not receive the filings. Despite these measures, Johnson did not respond to the refiled motions within the given 28-day period. Consequently, the district court granted summary judgment in favor of the defendants and dismissed the case. Johnson later filed a motion to vacate the judgment, asserting he never received the refiled motions, but the district court denied this motion.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court acknowledged the procedural complexities but focused on whether Johnson had constructive notice of the summary judgment motions. The court concluded that Johnson had constructive notice because he received the district court's order resetting the briefing schedule and instructing him on how to proceed. The court found no substantive or procedural error in the district court's decision and affirmed the summary judgment in favor of the defendants. View "Johnson v Purdue" on Justia Law

Clarence Lewis, an inmate at Hill Correctional Center, sued various medical staff members, alleging they were deliberately indifferent to his health issues, violating the Eighth Amendment. Lewis claimed misdiagnosis and mistreatment of diabetes, COPD, irritable bowel syndrome, and Hepatitis C. He also contended that his grievance about a delay in diabetes medication was not properly addressed.The United States District Court for the Central District of Illinois denied Lewis's motions for recruited counsel, stating he could represent himself and obtain relevant documents. The court granted summary judgment in favor of Dr. Sood, Dr. Bautista, Nurse Vollmer, and Administrator Lindor, concluding no reasonable juror could find deliberate indifference. The court also granted summary judgment for Dr. Paul, citing claim splitting due to a similar prior lawsuit.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the judgment in favor of Dr. Sood, Dr. Bautista, Nurse Vollmer, and Administrator Lindor, finding no reasonable likelihood that recruited counsel would have changed the outcome. The court noted that Lewis's disagreement with his diagnoses and treatments did not constitute deliberate indifference. As for Administrator Lindor, her limited role and the lack of harm from the medication delay further supported the judgment.However, the court vacated the judgment in favor of Dr. Paul, agreeing with Lewis that the district court's application of claim splitting was erroneous. Dr. Paul had raised this defense too late, effectively acquiescing to the claim. The case was remanded for further proceedings regarding Dr. Paul, with the district court advised to reconsider Lewis's request for recruited counsel if the claim proceeds to trial. View "Lewis v Sood" on Justia Law

Michael Gifford, a beneficiary of the Operating Engineers 139 Health Benefit Fund, sought reimbursement for out-of-network medical expenses incurred during his treatment for a stroke and subsequent brain aneurysm surgery. The Fund denied the claim, stating the services were not provided in an emergency and were not medically necessary. Gifford's wife, Suzanne, appealed the decision, but the Fund upheld the denial after consulting two independent medical reviewers who concluded the surgery was not an emergency and not medically necessary.The United States District Court for the Eastern District of Wisconsin granted the Fund's motion for summary judgment, agreeing that the Fund's decision was not arbitrary and capricious. The court also granted the Fund's motion for a protective order, limiting discovery to the administrative record. The Estate of Michael Gifford, represented by Suzanne, appealed the decision, arguing that the Fund failed to conduct a full and fair review by not considering a surgical note from Dr. Ahuja, which was not included in the administrative record.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court held that the Fund's denial of benefits was not arbitrary and capricious, as the Fund reasonably relied on the independent medical reviewers' reports and the administrative record. The court also found that the Fund was not required to seek out additional information not provided by the claimant. Additionally, the court upheld the district court's grant of the protective order, finding no abuse of discretion in limiting discovery to the administrative record. The court concluded that the Fund provided a full and fair review of the claim, and the denial of benefits was reasonable. View "Estate of Gifford v Operating Engineers 139 Health Benefit Fund" on Justia Law

Linda Thompson filed a putative class action against the Army and Air Force Exchange Service (the "Exchange") in Illinois state court, alleging that the Exchange printed her credit card’s expiration date on purchase receipts, violating the Fair and Accurate Credit Transactions Act (FACTA). The Exchange removed the case to federal court under 28 U.S.C. § 1442(a)(1), which allows federal agencies to remove cases to federal court. Thompson moved to remand the case to state court, arguing lack of Article III standing, while the Exchange moved to dismiss under Federal Rule of Civil Procedure 12(b)(1).The United States District Court for the Southern District of Illinois denied Thompson’s motion to remand and granted the Exchange’s motion to dismiss for lack of subject matter jurisdiction. The court held that the Exchange, as a federal entity, could remove the case without asserting a colorable federal defense and had an absolute right to litigate in federal court.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court agreed that the Exchange did not need to present a federal defense to remove the case. However, it found that the district court erred in dismissing the suit. The Seventh Circuit held that under 28 U.S.C. § 1447(c), when a federal court lacks subject matter jurisdiction over a removed case, it must remand the case to state court. The court noted that Thompson’s lack of Article III standing did not preclude state court jurisdiction, as state courts are not bound by Article III constraints. Consequently, the Seventh Circuit vacated the district court’s judgment and remanded the case with instructions to remand it to state court. View "Thompson v Army and Air Force Exchange Service" on Justia Law