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

Ferida H. Moy suffers from severe PTSD due to her experiences during the Yugoslav Wars. She applied for disability insurance benefits and supplemental security income, citing her PTSD and related mental health issues. An administrative law judge (ALJ) denied her application, finding that she had the residual functional capacity to perform simple, routine tasks with minimal contact with supervisors and co-workers. This decision was upheld by the district court, leading Moy to appeal.The ALJ found that Moy had moderate limitations in concentrating, persisting, or maintaining pace but concluded that she could work at a consistent production pace. The ALJ's decision was based on the testimony of a vocational expert who stated that a person with Moy's limitations could work as a dining room attendant, bus person, scrap sorter, industrial cleaner, or dishwasher. However, the vocational expert also testified that regular absences or being off-task for more than 15% of the workday would result in job loss. The ALJ's decision was affirmed by the district court.The United States Court of Appeals for the Seventh Circuit reviewed the case and found that the ALJ failed to build a logical bridge between Moy's limitations and the conclusion that she could work at a consistent production pace. The court noted that the ALJ's determination did not adequately account for Moy's limitations in concentration, persistence, and pace. The court emphasized that the ALJ's reasoning was internally inconsistent and did not reflect Moy's documented symptoms and treatment needs. Consequently, the Seventh Circuit vacated the judgment and remanded the case to the Commissioner of Social Security for further consideration consistent with its opinion. View "Moy v Bisignano" on Justia Law

Salvatore Ziccarelli, a former employee of the Cook County Sheriff's Office, used intermittent FMLA leave to manage his PTSD. In 2016, after his condition worsened, he discussed taking block leave with the FMLA coordinator, Wylola Shinnawi, who allegedly warned him against using more FMLA leave. Ziccarelli took one more day of leave and then resigned. He filed a lawsuit alleging FMLA interference and retaliation. The district court granted summary judgment for the Sheriff's Office on both claims, but the Seventh Circuit reversed and remanded the interference claim for trial.At trial, the jury awarded Ziccarelli $240,000. The Sheriff's Office moved for judgment as a matter of law under Rule 50(b), arguing that Ziccarelli could not show prejudice from the alleged interference since he took an additional day of FMLA leave after the phone call. The district court granted the motion and conditionally granted a new trial, reasoning that Ziccarelli's post-call leave negated any reasonable inference of prejudice.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court reversed the district court's entry of judgment as a matter of law, finding that the grounds for the Rule 50(b) motion were not properly presented before the verdict. However, the court affirmed the district court's alternative decision to grant a new trial, agreeing that the evidence did not support a finding of prejudice. The case was remanded for further proceedings consistent with the opinion. View "Ziccarelli v Dart" on Justia Law

Mary Ann Arnold worked for United Airlines from 1994 to 2020. She alleged age discrimination, retaliation, hostile work environment, and constructive discharge after experiencing changes in her job responsibilities and being placed on a Performance Improvement Plan (PIP). Arnold claimed these actions were due to her age and previous complaints about discrimination and harassment.The United States District Court for the Northern District of Illinois granted summary judgment in favor of United Airlines on Arnold's claims of discrimination, retaliation, and hostile work environment. The court dismissed her constructive discharge claim without prejudice, citing failure to exhaust administrative remedies.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's decision, holding that Arnold did not provide sufficient evidence to show that she suffered adverse employment actions due to age discrimination. The court also found that her retaliation claim failed because the actions taken by United were not materially adverse and were not shown to be causally connected to her complaints. Additionally, the court held that Arnold did not demonstrate a hostile work environment based on age, as the incidents she described were not severe or pervasive enough to meet the legal standard. The court also upheld the dismissal of her constructive discharge claim due to failure to exhaust administrative remedies. View "Arnold v. United Airlines, Inc." on Justia Law

Eric Holmes, an Indiana state prisoner, filed a lawsuit against the Marion County Sheriff’s Office under 42 U.S.C. § 1983, alleging unlawful imprisonment in violation of the Fourteenth Amendment. Holmes sought to proceed in forma pauperis, but the Prison Litigation Reform Act (PLRA) restricts this ability for prisoners who have had three prior civil actions or appeals dismissed as frivolous, malicious, or for failing to state a claim.The United States District Court for the Southern District of Indiana found that Holmes had incurred three strikes under the PLRA. The court determined that a previous case dismissed for failure to state a claim because it was barred by Heck v. Humphrey counted as Holmes’s third strike. Holmes did not contest the validity of his first two strikes. He filed a notice of appeal and moved to proceed in forma pauperis on appeal, but a motions panel of the Seventh Circuit denied his motion, identifying a different case dismissed due to judicial immunity as his third strike.The United States Court of Appeals for the Seventh Circuit reviewed whether dismissals based on affirmative defenses, such as those barred by Heck or due to judicial immunity, count as strikes under the PLRA. The court held that a case dismissed for failure to state a claim because it was barred by Heck counts as a strike if the Heck bar is clear from the face of the complaint. Similarly, a case dismissed on judicial immunity grounds incurs a strike if the immunity defense is clear from the face of the complaint. The court affirmed the district court’s dismissal of Holmes’s current suit, concluding that both the Heck dismissal and the judicial immunity dismissal counted as strikes. View "Holmes v Marion County Sheriff's Office" on Justia Law

Carl and Roberta Culp filed a lawsuit alleging federal and state law claims against various defendants, including Fort Wayne and Allen County police officers. The claims included excessive force under 42 U.S.C. § 1983, intentional and negligent infliction of emotional distress, assault and battery, criminal mischief, and violations of the Rehabilitation Act and the Americans with Disabilities Act (ADA). The incident in question occurred on August 20, 2018, when Carl Culp, a double amputee, expressed suicidal intentions during a psychiatric appointment, leading to police intervention.The United States District Court for the Northern District of Indiana granted summary judgment in favor of the defendants on most claims, leaving only Carl Culp’s § 1983 excessive force claim and state law claims against Officers Woods and Schulien for trial. A jury found in favor of the defendants on all claims except for Roberta Culp’s state law battery claim against Officer Woods, awarding her nominal damages of $1. The Culps appealed the summary judgment decision, and Woods and Schulien cross-appealed the denial of costs.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the district court did not err in granting summary judgment to the defendants, as the defendants’ brief complied with the local rules. The court also found that the Culps failed to present evidence of discrimination or failure to accommodate under the ADA and Rehabilitation Act. The court assumed, without deciding, that these laws applied to law enforcement actions but concluded that the evidence did not support the Culps' claims.Regarding the cross-appeal, the Seventh Circuit upheld the district court’s decision to deny costs to both parties, recognizing the mixed outcome of the case. The court affirmed the district court’s judgment in its entirety. View "Culp v. Caudill" on Justia Law

Jacqueline Sterling failed to pay $500 in gym membership fees to Southlake Nautilus Health and Racquet Club, leading to a default judgment against her in the Superior Court of Lake County, Indiana. Despite a bankruptcy court discharging her debt, Southlake continued to enforce the judgment. Sterling did not notify the Lake County court of her bankruptcy or appear at a hearing, resulting in a bench warrant for her arrest. A year later, she was arrested during a traffic stop and spent a weekend in jail, missing work and suffering emotional distress.The bankruptcy court found Southlake in civil contempt for violating the discharge order and contributing to Sterling's arrest and resulting damages. The court also found Sterling partially at fault for not notifying the Lake County court of her bankruptcy. Applying comparative fault principles, the court allocated half the liability for Sterling's lost wages, emotional distress, and attorney’s fees to each party. Sterling was awarded $9,724.50 in compensatory damages and $99,355 in attorney’s fees.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that while compensatory damages in civil contempt proceedings must be awarded if the complainant proves the defendant's actions caused the injury, the court has broad discretion in awarding attorney’s fees. The bankruptcy court erred by not recognizing this distinction and improperly applied comparative fault principles to reduce the attorney’s fees award. The Seventh Circuit vacated the judgment in part and remanded the case to the bankruptcy court to reassess the attorney’s fees in light of its broad discretion. The court also clarified that costs should be allowed and directed the bankruptcy court to set a deadline for Sterling to file a bill of costs. View "Sterling v Southlake Nautilus Health & Racquett Club, Inc." on Justia Law

Brian J. Murphy, a former employee of Caterpillar Inc., alleged that he was constructively discharged due to age discrimination and retaliation for previous legal actions against the company. Murphy, who began working for Caterpillar in 1979, had a long history of positive performance reviews and promotions. In 2000, he was placed on a performance action plan and subsequently fired after complaining about age discrimination. He sued Caterpillar, won a retaliation claim, and was reinstated in 2005. In 2018, after successfully leading a significant project, Murphy was placed on another performance action plan that he argued was designed for him to fail.The United States District Court for the Central District of Illinois granted summary judgment in favor of Caterpillar on all claims. The court found that Murphy did not provide sufficient evidence to support his claims of age discrimination and retaliation. Murphy appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that Murphy presented enough evidence to support a reasonable inference of pretext and unlawful intent regarding his age discrimination claim. The court noted that the performance action plan was flawed, as it included a deadline that had already passed and was signed off as failed before Murphy had a chance to comply. This, along with Murphy's consistent positive performance reviews, suggested that the plan was a pretext for discrimination. However, the court affirmed the summary judgment on Murphy's retaliation claim, citing the long gap between his previous lawsuit and the adverse action, and the lack of evidence of retaliatory animus.The Seventh Circuit reversed the district court's decision on the age discrimination claim, allowing it to proceed to trial, but affirmed the decision on the retaliation claim. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Murphy v Caterpillar Inc." on Justia Law

Verizon Wireless sought permits from the City of Milwaukee to install small cells and matching utility poles in a downtown plaza next to a major arena. The City denied most of the permits, initially citing aesthetic concerns and proximity to existing poles. Later, it claimed it lacked authority to grant the permits because the plaza was leased to Deer District LLC. Verizon sued the City, arguing the denials violated the Telecommunications Act (TCA) and Wisconsin state law. The district court ruled in favor of Verizon, finding the City's justifications insufficient and ordered the City to issue the permits. Verizon installed the poles, and the City accepted the ruling.The district court found that the City's initial reasons for denial were not supported by substantial evidence and violated the TCA. It also found the City's later rationale, based on the lease with Deer District, untimely and unconvincing. The court held that the City violated Wisconsin state law as well, and ordered the City to issue the permits. The City complied and did not appeal the decision. Deer District, an intervening defendant, appealed, challenging the district court's interpretation of the lease and state law, but not the TCA holding.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court dismissed Deer District's appeal for lack of Article III standing, as Deer District could not demonstrate that its injury would be redressed by a favorable decision. The court noted that the City did not join the appeal and that the injunction ran exclusively against the City. Therefore, even if the court ruled in Deer District's favor, it would not change the City's obligations under the district court's order. The appeal was dismissed for want of jurisdiction. View "Cellco Partnership v Deer District LLC" on Justia Law

TWD, LLC filed a complaint against Grunt Style LLC in 2018, alleging trademark infringement. Both companies sell goods with military-related trademarks. Grunt Style counterclaimed, asserting TWD was infringing on its prior trademark. The district court granted Grunt Style's motion for partial summary judgment in April 2022, dismissing all of TWD's claims. The case was reassigned to Judge Hunt, who held a bench trial in 2024 and ordered TWD to pay Grunt Style $739,500. Grunt Style moved to amend the judgment to include interest and permanent injunctive relief, which the district court granted in January 2025.TWD filed a notice of appeal from the amended judgment, which was docketed as appeal No. 25-1305. During a preliminary review, the Seventh Circuit identified a potential jurisdictional issue because the district court's judgment did not explicitly address TWD's counterclaims. The court directed the parties to address whether the judgment was deficient. TWD filed an amended notice of appeal, which was docketed as a new appeal, No. 25-1341. The district court later issued an indicative ruling, signaling its intent to correct the judgment if the case was remanded.The United States Court of Appeals for the Seventh Circuit agreed with the district court's solution and decided to remand the case for correction of the clerical mistake in the judgment. The court retained jurisdiction over the appeal and dismissed the second appeal (No. 25-1341) as unnecessary, without collecting an additional fee. The court emphasized the importance of clear and complete judgments to avoid jurisdictional issues and ensure appellate jurisdiction is clear. View "Grunt Style LLC v TWD, LLC" on Justia Law

A transgender girl, D.P., and her mother challenged a new policy by the Mukwonago Area School District that required D.P. to use the boys’ bathroom or a gender-neutral alternative. They argued that the policy violated Title IX of the Education Amendments of 1972 and the Fourteenth Amendment’s Equal Protection Clause. They filed an emergency motion for a temporary restraining order and a preliminary injunction to prevent the policy's enforcement during litigation, citing the precedent set by Whitaker v. Kenosha Unified School District No. 1 Board of Education.The United States District Court for the Eastern District of Wisconsin granted the temporary restraining order and, shortly after, converted it to a preliminary injunction without holding a hearing. The judge found that the case was controlled by the Whitaker precedent and concluded that D.P. was likely to succeed on the merits of her claims. The school district appealed, arguing that the judge erred by not holding an evidentiary hearing and urging the court to overrule Whitaker and a related case, A.C. v. Metropolitan School District of Martinsville.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The appellate court held that an evidentiary hearing is not always required before issuing a preliminary injunction, especially when the opponent does not request one or identify material factual disputes. The court also declined to revisit or overrule Whitaker and Martinsville, reaffirming that the district judge did not abuse his discretion in granting the preliminary injunction based on binding circuit precedent. The court concluded that the slight differences in D.P.'s case did not warrant a different outcome. View "Doe v Mukwonago Area School District" on Justia Law