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

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

The case involves a property owned by Indiana Land Trust #3082, located in Hammond, Indiana, which houses a lucrative fireworks and tobacco business operated by Omar and Haitham Abuzir. The City of Hammond seeks to use its eminent domain power to take this property to build a road connecting Indianapolis Boulevard and the Water Gardens neighborhood. The Abuzirs allege that the City’s actions are part of a conspiracy involving political motives and favoritism towards competitors who support the mayor.The Hammond Redevelopment Commission initially offered to purchase the property in 2018, but the Abuzirs declined. Consequently, the Commission initiated a condemnation action in Indiana state court under the state’s eminent domain statute. The Abuzirs objected, arguing that the taking was for a private purpose and motivated by ill will. Unable to assert counterclaims in state court, they filed a federal lawsuit alleging constitutional and federal law violations, including claims under the Fourteenth Amendment and 42 U.S.C. § 1983.The United States District Court for the Northern District of Indiana dismissed the Abuzirs' third amended complaint with prejudice, finding that the City had a legitimate government interest in building a road and that the Abuzirs failed to state a claim for equal protection, substantive due process, or civil conspiracy. The court noted that the Abuzirs' complaint itself provided a rational basis for the City’s actions.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The appellate court held that the Abuzirs failed to state a class-of-one equal protection claim because the City’s actions had a rational basis. The court also found that the proposed substantive due process claim was futile as the Abuzirs did not allege a deprivation of a protected interest. Lastly, the court upheld the denial of leave to add a § 1983 conspiracy claim, as the Abuzirs failed to establish any underlying constitutional violation. View "Indiana Land Trust #3082 v. Hammond Redevelopment Commission" on Justia Law

The case revolves around a dispute over attorney's fees in a Social Security disability benefits case. The plaintiff, Christian Arnold, was represented by the law firm Binder & Binder. After Arnold was determined to be disabled and entitled to past-due benefits, the law firm requested attorney's fees under 42 U.S.C. § 406(b), based on a contingency fee agreement Arnold had signed. However, the district court reduced the requested fees by nearly sixty percent, arguing that the full request would result in a "windfall" for the law firm, which was prohibited by statute. Binder & Binder appealed this decision.The case was initially heard by an administrative law judge (ALJ) who concluded that Arnold was not disabled. Arnold appealed this decision to the district court, which remanded the case back to the ALJ. On remand, the ALJ ruled in Arnold's favor, and the Social Security Administration issued a Notice of Award to Arnold for past-due benefits. Binder & Binder then moved for attorney's fees in the district court under 42 U.S.C. § 406(b), based on their contingency fee agreement with Arnold. The district court, however, reduced the requested fees.The United States Court of Appeals for the Seventh Circuit reviewed the case and concluded that the district court had abused its discretion by not basing its analysis primarily on the contingency agreement before considering the reasonableness of the request. The Court of Appeals vacated the district court's decision and remanded the case for further proceedings consistent with its opinion. The court emphasized that the contingency fee agreement should be the starting point for determining reasonableness under § 406(b), and any reduction should be justified based on relevant factors such as the claimant's satisfaction with their attorney's representation, the attorney's expertise and efforts expended, and the uncertainty of recovery and risks of an adverse outcome. View "Arnold v. O'Malley" on Justia Law

A mortgage company, Approved Mortgage Corporation, initiated two wire transfers, but the instructions for the transactions were altered by a third party. The funds were transferred to Truist Bank, which deposited the funds into an account it had previously flagged as suspicious. The funds were then withdrawn in the form of cashier’s checks. Approved Mortgage sued Truist, seeking damages in the amount of the transfers. The company asserted two claims under the Indiana Uniform Commercial Code (UCC), which governs the rights, duties, and liabilities of banks and their customers with respect to electronic funds transfers, and a common law negligence claim.The district court dismissed the UCC claims due to lack of privity between Approved Mortgage and Truist, and dismissed the negligence claim as preempted by the UCC. The court held that the UCC does not establish an independent remedy and must be read with another section of the UCC, which entitles a sender to a refund only from the bank which received its payment.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the dismissal of the UCC claims, agreeing with the lower court that the UCC does not establish an independent remedy and must be read with another section of the UCC. However, the appellate court reversed the dismissal of the negligence claim, holding that to the extent the negligence claim arises from Truist’s issuance of the cashier’s checks after Truist credited the funds to the suspicious account, the claim is not preempted by the UCC. The case was remanded to the district court for further proceedings. View "Approved Mortgage Corporation v. Truist Bank" on Justia Law

Minosa Echols, a civil detainee in an Illinois facility, was seriously injured when another resident attacked him. Echols filed a lawsuit under 42 U.S.C. § 1983, alleging that three security officers present during the assault violated his rights under the Fourteenth Amendment’s Due Process Clause by failing to protect him. The case went to trial, and the jury returned a verdict in favor of the defense. Echols appealed, arguing that the district court committed a legal error in its jury instruction.The district court had instructed the jury that to succeed on a failure-to-protect claim, Echols needed to show that the officer in question was subjectively aware that the other resident presented a risk of harm to Echols. On appeal, the United States Court of Appeals for the Seventh Circuit agreed that the jury instruction was erroneous. The court stated that Echols did not need to prove subjective awareness of the risk of harm to establish liability. Instead, the jury should have been instructed to determine whether a reasonable officer in the defendant’s position would have appreciated that the conditions within the dayroom put Echols at risk of harm, and whether the defendant acted in an objectively unreasonable way in addressing that risk.However, to prevail on appeal, Echols also needed to show that the error prejudiced him. The court found that Echols failed to do so. The court concluded that the attack was so unexpected that no reasonable officer, in the circumstances before them, would have anticipated the surprise attack or taken different measures to protect Echols. Therefore, the court affirmed the lower court's decision. View "Echols v. Johnson" on Justia Law

Raynard Jackson, a prisoner at the Wisconsin Secure Program Facility (WSPF), was placed in a cell without running water for five days. He alleged that Lieutenant Dane Esser, among other WSPF staff, knew that he did not have water and yet failed to turn the water on. After Jackson showed another staff member that he did not have water, the water was promptly turned on; however, he claimed Lt. Esser and other WSPF staff failed to provide him with medical care for his dehydration. Jackson filed grievances pertaining to these issues. After he exhausted his administrative remedies within the WSPF, he sued Lt. Esser and other WSPF staff under 42 U.S.C. § 1983 for violating his Eighth and Fourteenth Amendment rights.The district court, only considering the processed grievances, and without holding an evidentiary hearing, found that Jackson had not exhausted his administrative remedies as to certain claims and defendants. Additional defendants, Nurse Beth Edge and Captain Dale Flannery, were dismissed at summary judgment, leaving only the claims against Lt. Esser for trial. The jury found for Lt. Esser on both claims.The United States Court of Appeals for the Seventh Circuit agreed with Jackson that the district court should not have disregarded his allegedly unprocessed grievances without holding an evidentiary hearing. However, the court found no error in the district court’s conclusion that Jackson’s processed grievances did not exhaust remedies as to all his claims. The court also found no error in the district court’s grant of summary judgment to Nurse Edge or its evidentiary rulings before trial. The court affirmed in part, reversed in part, and remanded for a hearing on the allegedly unprocessed grievances. View "Jackson v. Esser" on Justia Law

The case involves Angela Flowers, who had a car loan with Kia Motors Finance. One morning, Flowers and her son were followed by a truck, which she suspected was an attempt by Kia to repossess her car due to late payments. Flowers sued Kia, alleging unlawful collection practices. However, she was unable to provide any evidence linking Kia to the truck that followed her and her son.Previously, the district court granted Kia summary judgment. Flowers had attempted to include an earlier repossession in her amended complaint, but the court found that she had unduly delayed this attempt. Furthermore, she could not provide any evidence that would allow a reasonable jury to conclude that Kia was involved in the incident with the truck.In the United States Court of Appeals for the Seventh Circuit, Flowers argued that she did not need the district court's approval to file an amended complaint, as Kia had consented in writing to the amendment. However, the court found that Flowers had unduly delayed her attempt to amend the complaint and had not provided a sound excuse for this delay. Therefore, the court denied her motion to amend the complaint.The court also affirmed the district court's grant of summary judgment to Kia. Flowers had failed to present any evidence linking Kia to the unidentified truck and driver. Her theory of liability was based on speculation and conjecture, which are insufficient to defeat a summary judgment motion. Therefore, the court concluded that there was no genuine dispute of material fact and that Kia was entitled to judgment as a matter of law. View "Flowers v. Kia Motors Finance" on Justia Law