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

A group of employees sued their employer, Metalcraft of Mayville, for not paying them for time spent working just before or after their shifts. The employees alleged that Metalcraft's timekeeping system, which allowed clocking in up to 15 minutes before and after shifts, did not accurately reflect the time they worked. They claimed that adjustments to their clock-in times were made even when they performed compensable work during these periods.The United States District Court for the Eastern District of Wisconsin decertified the collective action in April 2020, leading to 24 additional cases being filed and consolidated. Nine cases were dismissed for various reasons, and the district court granted summary judgment to Metalcraft in the four selected cases, ruling that the employees' evidence was speculative and insufficient. The remaining 12 plaintiffs voluntarily dismissed their cases, acknowledging that the summary judgment ruling likely determined their claims. Metalcraft then moved for sanctions against the plaintiffs' counsel, arguing that the lawsuits were frivolous.The United States Court of Appeals for the Seventh Circuit reviewed the case and upheld the district court's denial of sanctions. The appellate court found that the plaintiffs had enough factual and legal support for their claims to avoid sanctions. The court noted that FLSA claims can be based on reconstructed memories when an employer's record-keeping is inadequate. The court also determined that the plaintiffs' legal arguments regarding the Portal-to-Portal Act and the de minimis doctrine were not baseless. The appellate court emphasized that the standard for summary judgment is different from the standard for Rule 11 sanctions and that the plaintiffs' failure to win on summary judgment did not make their cases frivolous. Therefore, the denial of sanctions was affirmed. View "Farina v. Metalcraft of Mayville, Inc." on Justia Law

The case involves Michelle Gilbank, who lost custody of her daughter, T.E.H., in state court proceedings in Wisconsin. Gilbank alleged that various officials involved in those proceedings violated her federal constitutional rights. The events began when Gilbank, who had a history of drug use, moved into her ex-partner Ian Hoyle's apartment. Following an anonymous tip, police and social workers investigated and found evidence of Gilbank's drug use. On August 21, 2018, Gilbank was arrested for drug possession, and her daughter was temporarily placed with Hoyle. Subsequent state court hearings resulted in the continued placement of T.E.H. with Hoyle until Gilbank regained custody in March 2020.In the United States District Court for the Western District of Wisconsin, the court granted summary judgment for the defendants. The court found that some of Gilbank’s claims were barred by the Rooker-Feldman doctrine, which prevents federal courts from reviewing state court judgments. The court also ruled that the remaining claims failed on the merits, including claims of unreasonable search, denial of due process, and unlawful eviction.The United States Court of Appeals for the Seventh Circuit reviewed the case en banc. The court affirmed the district court's judgment, agreeing that the Rooker-Feldman doctrine barred claims based on injuries caused by state court judgments. The court also affirmed summary judgment on the merits for claims not barred by Rooker-Feldman, including those related to the urinalysis, interrogation without an attorney, and the removal of T.E.H. The court found that Gilbank had consented to the urinalysis, that her Fifth Amendment rights were not violated as her statements were not used in a criminal proceeding, and that there was no seizure of T.E.H. by government actors. The court also rejected the existence of a "fraud exception" to the Rooker-Feldman doctrine. View "Gilbank v. Wood County Department of Human Services" on Justia Law

Thompson Corrugated Systems, Inc. (TCS) entered into an oral agreement in 2004 to act as the North American sales representative for Engico, S.r.l., an Italian manufacturer of corrugated box machinery. TCS was to receive an 8% commission on sales, later modified to a sliding scale in 2012. Despite low sales, TCS procured two significant sales for Engico in 2005 and 2017. In 2016, Engico attempted to terminate the agreement due to low sales, but TCS resisted, citing market conditions. The parties renegotiated in 2018, agreeing that TCS would remain the representative until 2021 and continue to receive commissions. However, disputes arose over commissions for sales made in 2019 and 2020, leading TCS to sue Engico for breach of contract and other state law claims.The United States District Court for the Southern District of Illinois granted partial summary judgment in favor of TCS, finding the 2004 oral agreement valid and enforceable. The court determined that the essential terms of the agreement, including the commission structure, territory, and services, were sufficiently definite. The court also found that the agreement was terminable at will under Illinois law. The remaining claims were left to the jury, which found Engico liable for breach of contract and awarded TCS damages.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s grant of partial summary judgment de novo. The appellate court affirmed the district court’s decision, agreeing that the 2004 oral agreement contained sufficiently definite terms and that the Statute of Frauds did not bar enforcement of the 2018 agreement. The court concluded that the essential terms of the agreement were clear and that the deposition testimony satisfied the Statute of Frauds’ writing requirement. Thus, the judgment of the district court was affirmed. View "Thompson Corrugated Systems, Inc. v. Engico S.r.l." on Justia Law

Jessica Gehner was implanted with a Cook Medical inferior vena cava (IVC) filter in Ohio. She later experienced abdominal pain, and a CT scan in March 2013 revealed that the filter had perforated her IVC. Her doctors recommended the filter's removal, which occurred in April 2013, but a fragment was left behind due to the filter fracturing. Gehner filed a lawsuit in May 2016 against Cook Incorporated, Cook Medical LLC, and William Cook Europe APS, alleging products liability and implied warranty claims. The defendants argued that her claims were time-barred under Ohio’s two-year statute of limitations.The United States District Court for the Southern District of Indiana granted the defendants' motion for judgment on the pleadings, which was converted to a summary judgment motion. The court concluded that Gehner's claims were time-barred, as she was informed by her doctors in March 2013 that the IVC filter caused her injury, starting the statute of limitations clock. Gehner contended that she was unaware of the defect until 2016 when her mother saw a television commercial about defective IVC filters.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court held that under Ohio law, the statute of limitations for product liability claims begins when the plaintiff is informed by competent medical authority of an injury related to the product or when the plaintiff should have known of the injury through reasonable diligence. The court found that Gehner was aware of her injury and its relation to the IVC filter by April 2013 at the latest. The court rejected Gehner's argument that the statute of limitations should start when she learned of the defect, noting that awareness of the injury itself was sufficient to start the clock. The court affirmed the district court's summary judgment in favor of the defendants, concluding that Gehner's claims were indeed time-barred. View "Gehner v. Cook Medical, LLC" on Justia Law

Robert Decker, a federal inmate, requested electronic access to the full, daily editions of the Federal Register from his prison law library. The Bureau of Prisons (BOP) denied his request, prompting Decker to file a pro se lawsuit under the Administrative Procedure Act. He claimed that the denial violated his First Amendment rights to receive information and petition the government. The BOP argued that its policy was justified by the need to conserve limited resources.The United States District Court for the Southern District of Illinois granted summary judgment in favor of the BOP. The court applied the framework from Turner v. Safley, concluding that the BOP’s policy was reasonably related to its legitimate penological interest in conserving resources. The district court also denied Decker’s motions for the recruitment of counsel, finding that he was competent to litigate his case despite the challenges of incarceration.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s decision, agreeing that the BOP’s policy was reasonably related to its legitimate interest in conserving resources. The court noted that the BOP provided access to documents pertaining to the Bureau and the U.S. Parole Commission and allowed inmates to receive print copies of the Federal Register through the mail. The court found that Decker had alternative means to exercise his First Amendment rights, although they were less convenient. The court also upheld the district court’s denial of Decker’s motions for the recruitment of counsel, concluding that the district court did not abuse its discretion.In summary, the Seventh Circuit held that the BOP’s policy of providing limited electronic access to the Federal Register was constitutionally valid under Turner v. Safley and that the district court did not err in denying Decker’s request for appointed counsel. View "Decker v. Sireveld" on Justia Law

Irma Leibas, a correctional officer at the Cook County Department of Corrections (DOC), has pre-existing medical conditions requiring workplace accommodations, including up to three additional breaks per shift. After the DOC denied her request for these accommodations, Leibas sued, alleging violations of the Americans with Disabilities Act (ADA).The United States District Court for the Northern District of Illinois initially denied the defendants' motion for summary judgment on Leibas’s accommodation and discrimination claims. However, upon reconsideration and after both parties supplemented the record, the district court granted summary judgment in favor of the defendants, concluding that Leibas was not a qualified individual under the ADA.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision de novo. The appellate court examined whether Leibas could perform the essential functions of her position with or without reasonable accommodation. The court found that maintaining the safety and security of the DOC is an essential function of a correctional officer. Leibas’s requested accommodation of additional breaks, including rest periods, was deemed unreasonable given the unpredictable and violent environment of the DOC, which requires officers to be able to stand for long periods and respond to emergencies without delay. The court also noted that the DOC’s staffing shortages and the need for continuous coverage further complicated the feasibility of Leibas’s requested accommodations.The Seventh Circuit affirmed the district court’s judgment, holding that Leibas did not provide sufficient evidence to create a genuine dispute of material fact that she could perform the essential functions of her position with the requested accommodations. View "Leibas v. Dart" on Justia Law

In 2015, two plaintiffs sued the Chicago Board of Education and various officials, alleging violations of their First Amendment rights and state law. During a deposition in 2017, a confrontation occurred between plaintiffs' attorney Caryn Shaw and opposing counsel Lisa Dreishmire. Shaw allegedly assaulted Dreishmire, leading to police involvement and a complaint to the Illinois Attorney Registration and Disciplinary Commission (ARDC). The district court held an evidentiary hearing and found that Shaw misled the court about the incident, prolonging the litigation.The United States District Court for the Northern District of Illinois sanctioned Shaw by removing her from the case and ordering "Plaintiffs' counsel" to reimburse the defendants for reasonable attorneys' fees and costs. Shaw and her co-counsel, Anne Shaw and Donald Villar, appealed the sanctions. The district court's sanctions were based on findings that Shaw intentionally pushed Dreishmire and misrepresented the incident to the court.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the sanctions against Caryn Shaw, finding that she had adequate notice and opportunity to respond to the potential sanctions. However, the court vacated the sanctions against Anne Shaw and Donald Villar, concluding that they did not have sufficient notice or opportunity to respond. The court also found that the district court did not abuse its discretion in calculating the fee award against Caryn Shaw. The case was remanded for further proceedings consistent with the opinion. View "Vega v. Chicago Board of Education" on Justia Law

RCBA Nutraceuticals, LLC, a Florida-based nutritional supplements company, contracted with Western Packaging, Inc. for the manufacture of plastic zipper pouches to hold its protein powder. These pouches were produced by PolyFirst Packaging, Inc. in Wisconsin, which was later acquired by ProAmpac Holdings, Inc. The pouches were shipped to companies in New York and Texas for filling. RCBA discovered that the pouches were defective, with seams splitting and spilling the protein powder, leading to a lawsuit against ProAmpac in federal court in Wisconsin. RCBA's claims included breach of contract, breach of implied warranties, negligence, civil conspiracy, and fraudulent misrepresentation.The United States District Court for the Eastern District of Wisconsin dismissed RCBA’s complaint. The court found that the claims were "foreign" under Wisconsin’s borrowing statute, WIS. STAT. § 893.07, and applied the statutes of limitations from New York and Texas for the contract claims, and Florida for the negligence claim. The court concluded that the contract claims were time-barred under the four-year statutes of limitations of New York and Texas, and the negligence claim was time-barred under Florida’s statute of limitations. The remaining tort claims were precluded by the economic loss doctrine. RCBA’s motion to reconsider was denied, with the court ruling that RCBA had waived its equitable arguments by not raising them earlier.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The appellate court agreed that the final significant event for the contract claims occurred where the defective pouches were delivered, in New York and Texas, making the claims foreign and subject to those states' statutes of limitations. The court also upheld the district court’s decision to deny the motion to reconsider, noting that RCBA had waived its equitable arguments by not presenting them in response to the motion to dismiss. The court concluded that RCBA’s claims were either time-barred or precluded. View "RCBA Nutraceuticals, LLC v. ProAmpac Holdings, Inc." on Justia Law

Paula Emerson, a former Cook County Corrections Officer, was terminated in 2019 after being on disability leave since 2012 due to anxiety, depression, and PTSD. Emerson claimed her termination was in retaliation for filing a workers' compensation claim in 2014 and a Title VII lawsuit against Cook County and its employees, which she lost. She alleged that the same attorneys represented the County in both her workers' compensation proceedings and the Title VII case, and discussed her cases with those responsible for her termination.The United States District Court for the Northern District of Illinois dismissed Emerson's initial complaint for failure to state a claim, allowing her to amend it. Emerson's amended complaint was also dismissed with prejudice for failing to cure deficiencies. The court found that filing a workers' compensation claim was not a protected activity under the ADA and that Emerson did not adequately allege that her workers' compensation claim caused her termination. Emerson's request for limited discovery was denied due to lack of specific allegations.The United States Court of Appeals for the Seventh Circuit affirmed the district court's dismissal. The appellate court held that Emerson's complaint did not plausibly allege that her workers' compensation claim caused her termination, noting the five-year gap between the claim and her firing. The court also upheld the denial of Emerson's discovery request, deeming it speculative, and found no abuse of discretion in denying her Rule 59(e) motion for reconsideration, as she presented no new evidence or manifest error of law or fact. The judgment of the district court was affirmed. View "Emerson v. Dart" on Justia Law

Stanford Clacks, an African American truck driver, was employed by Kwik Trip, Inc. and experienced racial harassment from fellow employees. During his training, Clacks was harassed by two trainers, Tom Roerkohl and Brett Nechkash, who used racial epithets and made derogatory remarks. Clacks reported these incidents to his supervisor, Sean Clements, but did not initially specify the racial nature of the harassment. After completing his training, Clacks continued to face sporadic racial harassment, including receiving a racially charged note from Nechkash. Clacks went on voluntary pandemic leave in March 2020 and later reported the harassment to Kwik Trip’s Human Resources department, prompting an investigation that led to the termination of the offending employees. Kwik Trip offered Clacks his job back or a severance package, both of which he declined.The United States District Court for the Western District of Wisconsin granted summary judgment in favor of Kwik Trip on all claims. The court applied the sham-affidavit rule to exclude parts of an affidavit Clacks submitted in opposition to summary judgment, finding it contradicted his earlier deposition testimony. The court found that Clacks did not present sufficient evidence to support his claims of a hostile work environment and retaliation.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that the district court properly applied the sham-affidavit rule and that Clacks did not provide sufficient evidence to support his claims. Specifically, the court found that Kwik Trip took reasonable steps to address the harassment once it was reported and that Clacks did not suffer an adverse employment action as he was offered his job back. The court concluded that no reasonable jury could find Kwik Trip liable for a hostile work environment or retaliation. View "Clacks v. Kwik Trip, Incorporated" on Justia Law