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

Reginald Chapman was convicted by an Illinois state court jury of murdering Angela Butler and her son, C.B., in 1998. After his conviction, Chapman sought post-conviction DNA testing on evidence collected during the investigation that had not been tested or could be tested with new technology. He filed a motion under 725 Ill. Comp. Stat. 5/116-3, the Illinois statute governing post-conviction DNA testing. Although the county prosecutor’s office initially agreed to DNA testing, the state court rejected the agreement and dismissed Chapman’s motion, finding the evidence at trial was overwhelming and that further testing would not have altered the verdict. Chapman appealed, but the Illinois Appellate Court affirmed the dismissal, and the Illinois Supreme Court denied his request for review.Following the denial in state court, Chapman filed a suit in the United States District Court for the Northern District of Illinois against the Cook County State’s Attorney, Eileen O’Neill Burke. He challenged the constitutionality of the Illinois post-conviction DNA testing statute on its face under the Fourteenth Amendment’s Due Process Clause and the Sixth Amendment’s right to a jury trial. The district court dismissed the case for lack of subject matter jurisdiction, citing the Rooker-Feldman doctrine, which bars lower federal courts from reviewing state court judgments.On appeal, the United States Court of Appeals for the Seventh Circuit found that Chapman had standing to sue, as his injury was fairly traceable to Burke’s refusal to allow DNA testing. The court also held that the Rooker-Feldman doctrine did not bar Chapman’s federal claim because he was challenging the constitutionality of the statute itself, not seeking to overturn the state court judgment. Therefore, the Seventh Circuit reversed the district court’s dismissal and remanded the case for further proceedings. View "Chapman v Burke" on Justia Law

A railroad company operates lines throughout Indiana, holding various property interests in its corridors, such as easements and fee simple ownership. A telecommunications utility installed fiber optic cables above and below some of these railroad tracks without the railroad’s permission, safety review, or payment of licensing fees required by the railroad. The railroad claimed that under Indiana law, its easements gave it exclusive rights to the airspace and subsurface, including the right to exclude third parties and charge for installations.In the United States District Court for the Southern District of Indiana, the railroad asserted claims including trespass, theft, and unjust enrichment. The district court dismissed all claims related to Illinois sites for lack of personal jurisdiction. For the Indiana properties where the railroad held only easements, the district court ruled that the railroad lacked standing to assert trespass and rent claims, finding that its easements did not necessarily include the right to exclude others from the air or subsurface where there was no interference with railroad operations. The court also held that claims based on older installations were time-barred, determining these did not constitute continuing trespasses under Indiana law.Before the United States Court of Appeals for the Seventh Circuit, the railroad argued its easements included exclusion and licensing rights, and that the installations were continuing trespasses. The Seventh Circuit held that, under Indiana law, railroad easements do not necessarily include the right to exclude third parties from the air or ground below the tracks, nor the right to charge licensing fees for such installations unless the railroad’s operations are disturbed. The court also affirmed that these installations are not continuing trespasses and that claims outside the applicable statute of limitations are barred. The Seventh Circuit affirmed the judgment of the district court. View "CSX Transportation, Inc. v Zayo Group, LLC" on Justia Law

On the evening of June 24, 2018, following Chicago’s Pride Parade, Breah Bedford and her friends were on the sidewalk outside a bar owned by Joseph Plewa. After Plewa and his staff ordered the group to move and a confrontation ensued, Plewa dragged one of Bedford’s friends into the bar’s vestibule. Bedford attempted to intervene using objects she had on hand. Chicago police officers arrived, and Officer Brandon DeWitt approached Bedford from behind and shoved her to the ground, after which she suffered seizure-like symptoms. Bedford was taken to a hospital, where she was diagnosed with psychogenic non-epileptiform seizures. During her admission, a nurse reported that Bedford was combative and made a threatening racial comment.Bedford and her friend later sued Plewa, his business, Officer DeWitt, and others, alleging excessive force and state-law claims. The United States District Court for the Northern District of Illinois, Eastern Division, dismissed some claims at summary judgment and narrowed the issues for trial. At trial, the jury found in favor of Bedford’s friend against Plewa and his business, awarding damages, but rejected all of Bedford’s claims. Bedford appealed, arguing that five evidentiary rulings by the district court undermined the verdict.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s evidentiary decisions for abuse of discretion and found none. The court held that admitting expert testimony regarding malingering, nurse testimony about Bedford’s hospital behavior, evidence of the police use-of-force model, and the exclusion of certain video audio and prior use-of-force incidents were all within the district court’s discretion and did not affect the trial’s outcome. Accordingly, the Seventh Circuit affirmed the district court’s judgment. View "Bedford v Dewitt" on Justia Law

Two software development companies became involved in a dispute after a UK bank, Metro Bank PLC, hired one company, Arkeyo LLC, to create software for its coin-counting machines. Years later, as Arkeyo’s product became outdated, Metro Bank engaged Saggezza UK (a subsidiary of Saggezza, Inc.) to build replacement software. During development, Metro Bank provided Saggezza with an Arkeyo-operated touchscreen computer for reference. Arkeyo later alleged that Saggezza, Inc. infringed its copyrights and trade secrets, interfered with its contract and business relationship with Metro Bank, and converted Arkeyo’s property.The United States District Court for the Northern District of Illinois granted summary judgment for Saggezza, Inc. on all claims, ruling that Arkeyo did not show Saggezza, Inc. was responsible for the alleged infringement or tortious acts—these, if they occurred, were committed by Saggezza UK, which was not a defendant. The district court also denied Arkeyo’s motions for sanctions and for reconsideration based on purportedly new evidence, and it awarded attorney’s fees to Saggezza, Inc. under federal statutes.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s decisions. The appellate court held that Arkeyo’s copyright claims failed because there was no evidence of copying. The trade secret claims failed due to Arkeyo’s public disclosure of its software and the generic nature of the alleged secrets. The tortious interference claims were rejected because Saggezza’s competitive conduct was not “wrongful” under Illinois law, and the conversion claim failed since Arkeyo did not own or demand the property. The appellate court also affirmed the denial of sanctions, the denial of reconsideration, and the award of attorney’s fees. View "Arkeyo LLC v Saggezza, Inc." on Justia Law

Several parents whose premature infants developed necrotizing enterocolitis (NEC) after being fed cow’s milk-based formula at Pennsylvania Hospital sued the manufacturers of the formula, as well as the hospital, in Pennsylvania state court. The parents alleged that the manufacturers’ products caused NEC and that the hospital failed to warn of the risks and implement policies to protect patients. Some plaintiffs were Pennsylvania citizens and others from New Jersey. The hospital and its related entities were named as defendants, and the claims against them were based on state law.After the lawsuits were filed, the manufacturers removed the cases to federal court. The United States District Court for the Eastern District of Pennsylvania transferred the cases to a multidistrict litigation proceeding in the Northern District of Illinois. The plaintiffs’ initial motion to remand was granted after the district court found that the claims against the hospital were potentially viable, defeating removal on diversity grounds. The cases returned to Pennsylvania state court, where discovery proceeded and the hospital was later dismissed with prejudice after the state court sustained preliminary objections. The plaintiffs did not immediately appeal. The manufacturers then removed the cases a second time, arguing that the hospital had been fraudulently joined solely to defeat diversity jurisdiction. The district court denied the plaintiffs’ motion to remand, this time concluding that the plaintiffs’ lack of active pursuit of claims against the hospital showed “no real intention in good faith to prosecute the action,” amounting to fraudulent joinder.On interlocutory appeal, the United States Court of Appeals for the Seventh Circuit reversed. The Seventh Circuit held that fraudulent joinder exists only where a plaintiff makes false jurisdictional allegations or has no chance of success against the non-diverse defendant, taking all facts and law in the plaintiff’s favor. The court held that the plaintiffs’ litigation conduct and subjective intent are not proper bases for finding fraudulent joinder. The case was remanded for further proceedings. View "Abdullah v Mead Johnson & Company LLC" on Justia Law

Several related companies, along with an individual, operated the Inn of Chicago. After purchasing the property, they assumed an existing collective bargaining agreement (CBA) with a labor union. When the City of Chicago approached them to use the Inn to house displaced migrants, the operation resumed, but the employers did not use union members for typical hotel functions. Instead, these tasks were handled by an outside staffing agency and later by another company managed by the same people. The labor union learned of this arrangement, filed grievances alleging violations of the CBA, and submitted the dispute to arbitration. The union also filed an unfair labor practice charge with the National Labor Relations Board, which was consolidated with the arbitration.The United States District Court for the Northern District of Illinois, Eastern Division, reviewed the arbitration award. The arbitrator had found that the Inn was operating as a “hotel” within the meaning of the CBA while housing migrants, that the related companies and individual were a “single employer” under the CBA, and that they violated both the CBA and the National Labor Relations Act by failing to use union employees and failing to provide notice or bargain with the union. The district court confirmed the arbitration award, rejecting the employers’ arguments regarding arbitrability, notice, and authority.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s confirmation of the arbitration award. The court held that the employers were bound by the arbitration because they participated without reserving objections, and the arbitrator’s findings drew from the CBA and issues submitted by the parties. The court found no due process or public policy violation and affirmed the district court’s confirmation of the award. View "Elmar Hotel Management, LLC v Unite Here Local 1" on Justia Law

The case involves a lawsuit filed in March 2024 by the City of Chicago against several major fossil fuel companies and a trade association. Chicago alleges the defendants misrepresented the effects of fossil fuel emissions on climate change, leading consumers to use more fossil fuels, which resulted in harm to the city such as increased illness, property damage, and environmental degradation. The city seeks damages only for harm attributable to increased fossil fuel usage due to the alleged misinformation, and specifically excludes claims related to federal property or specialized fuel sales to the federal government.After the complaint was filed in Illinois state court, the defendants removed the case to the United States District Court for the Northern District of Illinois, invoking the federal officer removal statute (28 U.S.C. § 1442(a)(1)). They argued that their work producing and supplying fossil fuels for the federal government brought the case within federal jurisdiction. The district court disagreed, finding the connection between the alleged misconduct and the defendants’ federal work too attenuated, and remanded the case to state court.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s remand order de novo. The Seventh Circuit held that the federal officer removal statute did not support removal here because the defendants’ federal work was not sufficiently connected to Chicago’s claims, which focus on alleged misrepresentations to consumers and resulting non-federal harm. The court noted that the city’s complaint expressly disclaimed injuries related to federal activities, and agreed with the reasoning of other circuits in similar cases. The Seventh Circuit therefore affirmed the district court’s remand order. View "City of Chicago v BP P.L.C." on Justia Law

After threatening his ex-wife and her nephew with what appeared to be a firearm while intoxicated, an individual left his home and fell asleep at a neighbor’s house. Police were alerted, and, believing him to be inside and armed, surrounded the residence with S.W.A.T. teams and other tactical units. Negotiators eventually reached him by phone, during which he threatened self-harm and was reported to have threatened the officers, though he denied threatening the officers directly. When he exited the house, police fired non-lethal projectiles after he refused commands to come off the porch, seriously injuring his arm. After briefly retreating indoors, he reemerged and was shot three more times with similar ammunition when he acted aggressively and shouted threats at the officers.The United States District Court for the Northern District of Illinois, Eastern Division, granted summary judgment in favor of the officers and the City, holding that the plaintiff failed to show the police violated clearly established constitutional rights under the Fourth Amendment. The district court distinguished the facts of this case from prior circuit precedent, including Phillips v. Community Insurance Corp., and found that the officers’ actions did not clearly contravene established law.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the summary judgment ruling de novo. The appellate court held that qualified immunity shielded the officers because no binding precedent placed the unconstitutionality of their specific actions beyond debate, given the circumstances—namely, threats involving firearms and knives and the plaintiff’s aggressive behavior. The court also noted that the plaintiff failed to articulate a viable claim against the City of Elgin. The Seventh Circuit therefore affirmed the district court’s grant of summary judgment for all defendants. View "Davis v. City of Elgin, Illinois" on Justia Law

Clayton Creason worked as an engineer for Elanco US from November 2017 to November 2021. During his employment, Elanco offered a standard paid vacation benefit and an optional “vacation buy” program that allowed employees to purchase an extra week of paid leave by accepting a reduction in weekly salary. Creason participated in this program, reducing his pay by approximately $84 per week for the additional vacation week. After resigning, he filed suit under the Indiana Wage Payment Statute, claiming Elanco owed him the amount of the salary reduction, arguing the program required a written assignment of wages with notice of the right to rescind, as specified by Indiana law.The suit was initially filed in Indiana state court, with Creason seeking class certification for similarly situated employees. Elanco removed the case to the United States District Court for the Southern District of Indiana under the Class Action Fairness Act. The district court denied Creason’s belated motion to remand, finding his delay in seeking remand unreasonable after substantial progress in federal court. The court then dismissed some claims on the pleadings and granted summary judgment to Elanco on the remaining issues, concluding the vacation buy program did not constitute an assignment of wages and that Elanco’s policies concerning unused pandemic-related vacation hours did not violate Indiana law.The United States Court of Appeals for the Seventh Circuit reviewed the case. It held that the district court acted within its discretion in denying the remand request due to Creason’s unreasonable delay. On the merits, the Seventh Circuit affirmed that the vacation buy program was not an assignment of wages under Indiana law and that Elanco was not obligated to pay out unused COVID-related vacation hours. The district court’s decision was affirmed. View "Creason v Elanco US Inc." on Justia Law

The plaintiff, a New Zealand citizen who currently resides in Scotland, alleged that the defendant, a United Kingdom citizen and lawful permanent resident of Wisconsin, repeatedly sexually assaulted her while she was employed as a live-in nanny for the defendant’s family in New Zealand. The plaintiff claimed she was economically distressed and intermittently unhoused at the time, and accepted the job for secure employment and housing. She brought federal claims under the Trafficking Victims Protection Act and Wisconsin common law claims, seeking damages for the alleged assaults and related harms.After the plaintiff filed suit in the United States District Court for the Western District of Wisconsin, the defendant moved to dismiss the case on two grounds: forum non conveniens, arguing that New Zealand was a more appropriate forum, and failure to state a federal claim, contending the civil-remedy provision of the Act does not apply extraterritorially. The district court granted the motion to dismiss under forum non conveniens, finding that New Zealand was an available, adequate, and more convenient forum with a stronger connection to the dispute. The district court did not address the extraterritoriality issue. The plaintiff appealed the dismissal to the United States Court of Appeals for the Seventh Circuit.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal under forum non conveniens. The appellate court concluded there was no abuse of discretion in the district court’s findings that New Zealand was both an available and adequate forum, and it properly balanced public and private interest factors. The Seventh Circuit held that New Zealand’s connection to the dispute was stronger than that of the United States and that international comity concerns supported dismissal. The judgment was affirmed and the action dismissed without prejudice. View "Pavlovich v. Gaiman" on Justia Law