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

Many years ago, a class of plaintiffs sued, alleging that the Clerk of the Circuit Court of Cook County was engaging in unlawful political patronage in violation of the First and Fourteenth Amendments. In 1972, the Clerk and the plaintiffs entered into a consent decree that prohibited the Clerk from discriminating against the office’s employees for political reasons; in 1983, a separate judgment extended that prohibition to hiring practices. Litigation has continued. In 2018, a magistrate judge appointed a special master to monitor the Clerk’s compliance. The special master sought to observe the conduct of the Clerk’s office managers at employee grievance meetings. The employees’ union sent the special master a cease-and-desist letter purporting to bar her from the room.The plaintiffs sought a declaratory judgment clarifying that the 2018 supplemental relief order authorized the special master to observe the grievance meetings. The union—which was not a party to the suit and did not seek to become one—filed a memorandum opposing the motion, arguing that the 1972 consent decree did not provide a basis for the supplemental relief order and that the special master’s presence violated Illinois labor law and the union’s collective bargaining agreement. The magistrate agreed with the plaintiffs. The Seventh Circuit affirmed without addressing the merits of the union’s argument. Party status is a jurisdictional requirement. View "Shakman v. International Brotherhood of Teamsters" on Justia Law

The Wisconsin Public Service Commission issued a permit authorizing the construction of a $500 million electricity transmission line in southwestern Wisconsin. Two environmental groups sued under 42 U.S.C. 1983, seeking to invalidate the permit. The permit holders moved to intervene. The district court denied the motion. The permit holders appealed and moved for expedited review because the case continues without them in the district court.The Seventh Circuit granted the motion, reversing the district court. The permit holders are entitled to intervene under Rule 24(a)(2) of the Federal Rules of Civil Procedure; “this is a paradigmatic case for intervention as of right.” The three basic criteria for intervention are satisfied: the intervention motion was timely; the transmission companies hold a valuable property interest in the permit that is under attack; and their interest will be extinguished if the plaintiffs prevail. The only disputed question was whether the existing defendants adequately represent their interests. The Commission regulates the transmission companies, it does not advocate for them or represent their interests. The transmission companies cannot be forced to rely entirely on their regulators to protect their investment in this enormous project, which they stand to lose if the plaintiffs are successful. View "Driftless Area Land Conservancy v. Huebsch" on Justia Law

Named plaintiffs filed a putative class action in Illinois, alleging that defendants made false claims about dietary supplements. The parties negotiated a settlement. Over the objection of class member Frank, the district court approved it. The Seventh Circuit reversed. In 2015, the parties submitted “the Pearson II settlement.” Three class members objected to the Pearson II settlement.Nunez had filed his own putative class action against the defendants in California. After the Seventh Circuit vacated the first Pearson settlement, Nunez wanted to represent a Pearson subclass. The Pearson parties refused to include Nunez’s counsel in their negotiations. Nunez objected to the Pearson II settlement. The district court approved it. All three objectors appealed, then dismissed their appeals. Frank moved for disgorgement of any payments made to objectors in exchange for those dismissals. Discovery showed that the objectors had received side payments in exchange for dismissing their appeals. The district court denied disgorgement.The Seventh Circuit reversed. The district court had the equitable power to order the settling objectors to disgorge for the benefit of the class the proceeds of their private settlements. “Falsely flying the class’s colors, these three objectors extracted $130,000 in what economists would call rents from the litigation process simply by showing up and objecting" to the settlement.” Settling an objection that asserts the class’s rights in return for a private payment to the objector is inequitable and disgorgement is the most appropriate remedy. Those objectors are, in essence, “not paid for anything they owned.” View "Frank v. Target Corp." on Justia Law

Gunn brought a putative class action against Continental, which had issued a group long-term care insurance policy to Gunn’s employer, the federal judiciary, in Washington D.C. Gunn alleged that Continental breached its contract, committed torts, and violated consumer protection laws by raising his premiums dramatically. The district court dismissed the case on the pleadings based on Continental’s assertion of a filed-rate defense, relying on the Washington state Insurance Commissioner’s approval of the new, higher premiums for individual insureds in Washington.The Seventh Circuit reversed, noting that choice of law is critical in this case, which involves employees in every state. It is unclear which state’s or states’ law creates Gunn’s causes of action, whether that jurisdiction recognizes an applicable filed-rate defense and within what contours, and which state or states have authority to approve premium rates under the group policy. The court remanded to allow the district court to address those questions. View "Gunn v. Continental Casualty Co." on Justia Law

RYZE, an Indiana business, employs remote workers across the U.S., including Billings, who signed an employment agreement with a forum‐selection clause providing for litigation in an Indiana state court or in the Southern District of Indiana. Billings filed suit in California state court. alleging state law claims and violations of the Fair Labor Standards Act, on behalf of himself and other current and former RYZE employees nationwide.RYZE removed the action to the Eastern District of California, which concluded that Billings had failed to show why the forum‐selection clause should not control and transferred venue under 28 U.S.C. 1404(a) to the Southern District of Indiana. That court granted RYZE summary judgment on Billings’s federal claims. The district court then, sua sponte, returned the case to the Eastern District of California, explaining that its docket was congested and that the California court was familiar with California labor law. When the case was docketed again in the Eastern District of California, RYZE petitioned the Seventh Circuit for a writ of mandamus directing the Southern District of Indiana to request that the Eastern District of California return the action to the Southern District of Indiana. The Seventh Circuit granted that petition, noting that forum‐selection clauses should be given “‘controlling weight in all but the most exceptional cases.’” No exceptional circumstances exist here. View "Ryze Claims Solutions, LLC v. Magnus-Stinson" on Justia Law

Mitze unsuccessfully appealed the denial of her application for social security benefits. Several years later, Mitze moved to seal her medical information and all other information pertaining to her case, citing “harassing phone calls from solicitors” who knew her personal medical information because the courts had “publicized” it by issuing opinions. She claims that she and her children have experienced social stigma and that thieves broke into her home to steal pain medication, which publicly available documents revealed that she had been prescribed.The Seventh Circuit affirmed the denial of Mitze’s motion. A strong presumption exists in favor of publishing dispositional orders, even in cases involving substantial privacy interests such as state secrets, trade secrets, and attorney-client privilege. The court acknowledged that the existing remedies of proceeding anonymously, requesting redactions, or sealing records may be inadequate in the social security context. News outlets have the right to publish information obtained from public court records and cannot be ordered to remove articles reporting on the decisions in her case. The court rejected an argument under the Health Insurance Portability and Accountability Act, 42 U.S.C. 1320d-6, which regulates the disclosure of information by only healthcare providers and their affiliates. View "Mitze v. Saul" on Justia Law

In 2018, Democrats were elected as the governor and attorney general of Wisconsin, replacing Republicans. Immediately after the election, the Republican-controlled legislature enacted Act 369 and Act 370, which strip the incoming governor and attorney general of various powers and vest legislative committees that remained under Republican control with formerly-executive authority. The changes include prohibiting the governor from re-nominating potential appointees who have been rejected once by the legislature; giving the legislature authority to suspend an administrative rule multiple times; removing the governor’s ability to appoint the CEO of the Wisconsin Economic Development Corporation; adding legislative appointees to the Economic Development Corporation; requiring that the attorney general obtain legislative approval before withdrawing from a lawsuit filed by the state government or settling a lawsuit for injunctive relief; and granting the legislature unrestricted rights to intervene in litigation to defend the constitutionality or validity of state law.The Seventh Circuit affirmed the dismissal of a suit under 42 U.S.C. 1983 claiming violations of the First Amendment, the Equal Protection Clause, and the Guarantee Clause of Article IV, Section 4 of the United States Constitution. The plaintiffs have not pointed to any concrete harms they have suffered or will suffer because of the Acts and are not entitled to any remedy under the Constitution. Any judicial remedy for the alleged harms must come from the courts of Wisconsin. View "Democratic Party of Wisconsin v. Vos" on Justia Law

After his development plan fell through and he went into bankruptcy, Hinterberger sued the city for failure to provide promised financial support. Discovery proceeded for almost two years. The city moved for summary judgment. The Southern District of Indiana’s Local Rule 56‐1 requires that a party seeking summary judgment include a “Statement of Material Facts Not in Dispute.” The opposing party must respond with a “Statement of Material Facts in Dispute” that “identifies the potentially determinative facts and factual disputes that the party contends demonstrate a dispute of fact precluding summary judgment.” The Rule prohibits the inclusion of any argument and requires that all asserted material facts be supported by specific citations. The movant’s facts are admitted unless the non‐ movant “specifically controverts” them in its factual statement, shows them to be unsupported, or demonstrates that reasonable inferences can be drawn in its favor.The district court rejected Hinterberger’s statement in its entirety for failing to comply with Local Rule 56‐1, entered summary judgment for the city, and ordered Hinterberger’s attorneys to show cause why they should not be sanctioned. The Seventh Circuit affirmed. Hinterberger’s statement misrepresented the evidence, contained inaccurate and misleading citations to the record, and presented improper arguments rather than materially disputed facts. View "Hinterberger v. Indianapolis" on Justia Law

Bosch, an engineering company, asked J.S.T. to design and manufacture a connector that Bosch could incorporate into a part that it builds for GM. For a time, Bosch retained J.S.T. as its sole supplier of those connectors. Then, according to J.S.T., Bosch wrongfully acquired J.S.T.’s proprietary designs and provided them to J.S.T.’s competitors, who used the stolen designs to build knockoff connectors and eventually to displace J.S.T. from its role as Bosch’s supplier. After filing various lawsuits against Bosch, J.S.T. filed suit in Illinois against the competitors, alleging misappropriation of trade secrets and unjust enrichment. The Seventh Circuit affirmed the dismissal of the case for lack of personal jurisdiction. The competitors’ only link to Illinois is that they sell their connectors to Bosch, knowing that the connectors will end up in GM cars and parts that are sold in Illinois. For personal jurisdiction to exist, though, there must be a causal relationship between the competitors’ dealings in Illinois and the claims that J.S.T. has asserted against them. No such causal relationship exists. View "J.S.T. Corp. v. Foxconn Interconnect Technology, Ltd." on Justia Law

Their father set up a trust for the benefit of Elizabeth and Thomas, giving the siblings equal interests; if either died without children, the other would receive the remainder of the deceased sibling’s share. Thomas approached Elizabeth after their father's death, wanting to leave a portion of his share to his wife, Polly. In 1998, Elizabeth retained the defendants to terminate the trust; the representation letter made no mention of a life estate for Polly or a subsequent remainder interest for Elizabeth. The settlement agreement did not mention Polly or a life estate, nor did it restrict what either sibling could do with the trust funds. The agreement contained a liability release and stated that it was the only agreement among the parties. In 1999, Elizabeth signed the agreement and the petition to dissolve the trust. In 2000, the probate court granted the petition. Elizabeth and Thomas each received more than a million dollars. Thomas died in 2009 without children; his will devised his assets to Polly. When Polly died in 2015, she left her estate to her children. Elizabeth filed a malpractice claim.The Seventh Circuit affirmed summary judgment for the defendants, holding that the two-year Indiana statute of limitations began running no later than 2000 and that if Elizabeth had practiced ordinary diligence, she could have discovered then that her wishes had not been followed. View "Ruckelshaus v. Cowan" on Justia Law