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

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

Phillip Robbin was removing a tree from a residential lot in the City of Berwyn when he was confronted by Sarah Lopez, a city inspector. Lopez berated Robbin using racial slurs, which led Robbin to demand disciplinary action against her. The Mayor of Berwyn denied Robbin's request for Lopez's termination, leading Robbin to sue the City, the Mayor, and Lopez for violations of his substantive due process rights under the Fourteenth Amendment and state law.The United States District Court for the Northern District of Illinois dismissed Robbin’s complaint under Federal Rule of Civil Procedure 12(b)(6), finding that he failed to state a federal claim. The court also declined to exercise supplemental jurisdiction over the state law claims, leading to Robbin's appeal.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court held that Robbin failed to allege a violation of a fundamental right and that the conduct described did not "shock the conscience," which are necessary elements for a substantive due process claim under the Fourteenth Amendment. The court noted that while Lopez's use of racial slurs was deplorable, it did not rise to the level of a constitutional violation. Consequently, the Seventh Circuit affirmed the district court's dismissal of Robbin's complaint. View "Robbin v. City of Berwyn" on Justia Law

Reginald Pittman, a pretrial detainee at the Madison County jail, attempted suicide and suffered a severe brain injury. He claimed that two guards ignored his requests for crisis counseling before his suicide attempt. Pittman sued Madison County and various jail officials under 42 U.S.C. § 1983, alleging a violation of the Fourteenth Amendment for failing to provide adequate medical care. The case has a lengthy procedural history, including three appeals and three trials.The United States District Court for the Southern District of Illinois initially granted summary judgment for the defendants, but this was reversed in part by the Seventh Circuit in Pittman I. After a first trial, the Seventh Circuit in Pittman II reversed and remanded for a new trial due to the erroneous exclusion of evidence. In Pittman III, the Seventh Circuit found a jury instruction error and remanded for a third trial. In the third trial, the district court instructed the jury in line with Pittman III, requiring proof that the officers were subjectively aware or strongly suspected a high likelihood of self-harm. The jury returned a verdict for the defendants.The United States Court of Appeals for the Seventh Circuit reviewed the case and found that the jury instruction was erroneous. The court clarified that Pittman did not need to prove subjective awareness of the risk of harm. Instead, the jury should have been instructed to determine whether the defendants made an intentional decision regarding Pittman’s conditions of confinement and whether they acted objectively unreasonably by failing to mitigate the risk. Despite this error, the court concluded that the erroneous instruction did not prejudice Pittman, as the case was presented as a credibility contest between the testimony of the guards and an inmate. Therefore, the Seventh Circuit affirmed the verdict for the defendants. View "Pittman v. Madison County, Illinois" on Justia Law

Jebari Craig, a black employee, worked for Wrought Washer Manufacturing, Inc. from 2010 until his termination in April 2019. Craig, who became the union president in 2018, filed a racial discrimination grievance against Wrought. He alleged that his termination was in retaliation for this grievance. The incident leading to his termination involved a disagreement with a supervisor and subsequent use of his cell phone on the shop floor, which violated company policy. Craig was suspended and later offered a "Last Chance Agreement" to return to work, which he refused to sign, leading to his termination.The United States District Court for the Eastern District of Wisconsin granted summary judgment to Wrought on Craig's claim that his termination was retaliatory. The court found that Craig had not established a prima facie case of retaliation for his written warning and allowed his claim regarding his suspension to proceed. However, it granted summary judgment on the termination claim, crediting Wrought's explanation that the "Last Chance Agreement" did not require Craig to relinquish his discrimination claims, contrary to Craig's later assertions.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court affirmed the district court's judgment, agreeing that Schaefer, Wrought's plant manager, was confused during his deposition about the terms of the "Last Chance Agreement" and the severance agreement. The court found that Craig's declaration, which contradicted his earlier statements, did not create a genuine issue of material fact. The court concluded that no reasonable litigant would have withheld the information Craig later provided, supporting the district court's decision to grant summary judgment to Wrought. View "Craig v. Wrought Washer Manufacturing, Inc." on Justia Law

Lorenzo Davis, a pretrial detainee at the McLean County Detention Facility, suffered serious eye injuries after being attacked by fellow detainees Wanyae Massey and Terrell Hibbler. Davis had reported threats and requested a transfer, but the identity of the officer he spoke to is unknown. On the morning of the attack, Officer Christopher Gibson placed cleaning supplies in the common area and left to supervise the recreation room. Massey and Hibbler used the cleaning supplies to beat Davis. Officer Gibson learned of the fight from a hall worker and passed the keys to Officer Billy Rook, who called for assistance and waited for backup before intervening.Davis sued Officers Gibson and Rook under 42 U.S.C. § 1983, alleging they violated the Due Process Clause of the Fourteenth Amendment by failing to protect him. The United States District Court for the Central District of Illinois granted summary judgment for the officers, finding that the evidence did not support the claim that a reasonable officer would have appreciated the risk to Davis. The court also found that Officer Rook acted reasonably by waiting for backup before intervening. The court did not address the defendants' qualified immunity defense.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s grant of summary judgment de novo. The court affirmed the lower court’s decision, holding that a reasonable officer in Officer Gibson’s position would not have perceived the risk of harm to Davis, as there was no evidence that Gibson knew about the threats or Davis’s request for a transfer. Additionally, the court found that Officer Rook acted reasonably by waiting for backup before intervening in the fight, as it was a standard and safe procedure. The court concluded that neither officer acted in an objectively unreasonable way under the circumstances. View "Davis v. Rook" on Justia Law

Henry Beverly, a financial analyst at Abbott Laboratories, took a personal leave of absence during which he began working for Cook County without informing Abbott. His leave was extended twice, but when he requested a third extension, Abbott had already filled his position and terminated his employment. Beverly sued Abbott, alleging racial discrimination and defamation, among other claims.The United States District Court for the Northern District of Illinois granted summary judgment in favor of Abbott on some of Beverly’s claims, including those related to his termination, while allowing others to proceed to trial. The jury found in favor of Abbott on the remaining claims. Beverly appealed, challenging several pretrial, trial, and post-trial rulings.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 the reduction in Beverly’s job duties did not amount to a constructive discharge and that Abbott’s reason for terminating Beverly’s employment was not pretextual. The court also upheld the district court’s mid-trial judgment as a matter of law on Beverly’s defamation claim, finding that the statement in question was a non-actionable opinion. Additionally, the appellate court found no abuse of discretion in the district court’s trial rulings, including those related to impeachment attempts and the exclusion of certain evidence. The court concluded that Beverly’s arguments did not warrant a new trial and affirmed the district court’s judgment in full. View "Beverly v. Abbott Laboratories" on Justia Law