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

Jaryan Gills, an inmate at East Moline Correctional Center, was assaulted by another prisoner, suffering a broken arm that required two surgeries. Following the incident, Gills was placed in medical segregation for a month in a cell lacking a sink or toilet, relying on guards for bathroom access and provided with portable urinals and waste bags. He alleges that prison staff frequently denied him timely bathroom access, resulting in unsanitary conditions. Gills also contends that he received delayed or inadequate medical care for his injuries and other health issues, and that a prison doctor and staff were deliberately indifferent to these needs.The United States District Court for the Central District of Illinois reviewed cross-motions for summary judgment. In its decision, the district court disregarded Gills’s declarations, which largely repeated allegations from his complaint and added details not disclosed in his deposition, and granted summary judgment to the defendants. The court determined that Gills failed to present sufficient evidence to establish genuine disputes of material fact regarding his Eighth Amendment claims for unconstitutional conditions of confinement and inadequate medical care, as well as his conspiracy and intentional infliction of emotional distress claims.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s rulings. The Seventh Circuit held that the district court did not abuse its discretion in excluding Gills’s declarations under the sham affidavit rule. While the conditions Gills experienced may have been unpleasant, the appellate court found that the evidence did not support a finding of deliberate indifference by prison officials or the medical director. The court also concluded that Gills’s conspiracy claim failed because no underlying constitutional violation was proven and there was no non-speculative evidence of an agreement among defendants. The judgment in favor of the defendants was affirmed. View "Gills v. Hamilton" on Justia Law

Matthew Metzler, an undergraduate student at Loyola University Chicago, was expelled in January 2017 after a university hearing board found him responsible for sexual misconduct involving another student, referred to as Jane Roe. The university’s Title IX process began after Roe reported feeling pressured into sexual acts without her consent. Initially, Roe declined to file a formal complaint, but later decided to do so after continuing distress. The university investigated, interviewed both parties, and considered evidence, including text messages and witness names provided by Metzler. The hearing board credited Roe’s account over Metzler’s based on the perceived consistency and credibility of her statements and found him responsible, resulting in expulsion. Metzler’s appeal was unsuccessful.Metzler filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, asserting claims under Title IX for unlawful sex discrimination and breach of contract due to alleged procedural irregularities in the disciplinary process. The district court granted summary judgment for Loyola, finding insufficient evidence that Metzler had been discriminated against based on sex or that contractual standards had been violated in a manner lacking rational basis. The case was briefly remanded for jurisdictional review and to determine anonymity, after which the district court reaffirmed its decision for Loyola.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. It held that Metzler failed to present sufficient evidence for a reasonable factfinder to conclude that Loyola discriminated against him on the basis of sex under Title IX, even when considering generalized public pressure and procedural errors. The court further found that Metzler’s breach of contract claim failed because Loyola had a rational basis for its disciplinary decision. The judgment of the district court was affirmed. View "Metzler v Loyola University Chicago" on Justia Law

In June 2021, police officers in Aurora, Illinois responded to a 911 call from a woman who reported, based on information from her nephew, that Antron Cannon was violently assaulting a woman inside his home. Officers arrived to find Cannon and a companion inside the house. There were discrepancies between Cannon’s account and that of other witnesses regarding what occurred, but responding officers heard loud noises, received confirmation that no one had left the home, and were told a side door was unlocked. They entered the home without a warrant, detained Cannon, and interviewed his companion, who alleged that Cannon had assaulted her. Physical evidence of injuries was documented, and Cannon was arrested for domestic battery, though the charges were later dropped.The United States District Court for the Northern District of Illinois, Eastern Division, reviewed Cannon’s subsequent civil lawsuit against the officers and the city. Cannon claimed the officers unlawfully entered his home and arrested him without probable cause. The district court granted summary judgment for the defendants, concluding that exigent circumstances justified the warrantless entry and probable cause supported the arrest. The court also dismissed Cannon’s indemnification claim against the city and awarded defendants their costs, rejecting Cannon’s argument that his indigency should exempt him from the cost award.The United States Court of Appeals for the Seventh Circuit reviewed the appeal. The appellate court affirmed the district court’s decisions. It held that the officers’ warrantless entry was reasonable under the emergency aid exception to the Fourth Amendment, given the information available to them at the time. It further held that probable cause existed for Cannon’s arrest based on statements and observed injuries. Finally, it found no abuse of discretion in awarding costs, as Cannon did not demonstrate inability to pay now or in the future. View "Cannon v. Filip" on Justia Law

A former lieutenant in a county sheriff’s office was accused of using excessive force during two arrests. After an internal investigation was initiated, he was suspended and scheduled for a public hearing before a merit board, which is required under Indiana law for disciplinary actions. The lieutenant alleged that the sheriff manipulated both the investigation and the merit board to ensure an unfavorable outcome for him. Faced with the possibility of an unfair hearing and negative publicity, the lieutenant negotiated a severance agreement with the sheriff: he would resign and waive his hearing in exchange for withdrawal of the charges and a promise of a neutral reference.Despite the agreement, on the day the resignation became effective, two county prosecutors and the sheriff broadly disclosed the excessive-force allegations to local legal professionals and the lieutenant’s current and prospective employers, including through Brady/Giglio disclosures. The disclosures described the alleged misconduct and claimed issues with the lieutenant’s credibility, leading to his suspension from his part-time job and the loss of other employment opportunities. The lieutenant claimed these actions were part of a premeditated scheme to render him unemployable in law enforcement.In the United States District Court for the Northern District of Indiana, the complaint was dismissed. The district court found that absolute and qualified immunity protected the prosecutors and that the sheriff could not be liable because the lieutenant had voluntarily resigned, waiving his due process rights. On appeal, the United States Court of Appeals for the Seventh Circuit held that the prosecutors were entitled to absolute immunity only for Brady/Giglio disclosures made in pending criminal cases. For disclosures to the bar association and employers, neither absolute nor qualified immunity applied at this stage because the alleged coercion through misrepresentation could constitute a procedural due process violation. The appellate court reversed in part, affirmed in part, and remanded for further proceedings. View "Martin v. Goldsmith" on Justia Law

Israel Ruiz was convicted by an Illinois jury of first-degree murder and aggravated discharge of a firearm for an offense he committed at age 18 in 1998. In 2000, he received a 40-year prison sentence without the possibility of parole for murder and a concurrent 15-year sentence for the firearm offense. In 2019, Illinois enacted a law (Public Act 100-1182) allowing parole eligibility for young adults convicted of first-degree murder committed under age 21, but only for those sentenced on or after June 1, 2019. Ruiz, sentenced before that date, is ineligible for parole under the Act.Ruiz filed a lawsuit under 42 U.S.C. § 1983 in the United States District Court for the Northern District of Illinois, Eastern Division, against Illinois’s governor and other state officials. He alleged that the Act’s prospective application violated his rights under the Equal Protection Clause and the Eighth Amendment. The district court granted the defendants’ motion to dismiss, holding that established Seventh Circuit precedent foreclosed Ruiz’s Fourteenth Amendment claim and that the Act’s prospective-only application did not render his sentence cruel or unusual under the Eighth Amendment. Ruiz appealed.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s dismissal de novo. It held that the Act’s limitation to offenders sentenced on or after its effective date did not violate the Equal Protection Clause, as rational-basis review permits such prospective legislative distinctions, consistent with prior circuit decisions such as United States v. Speed and United States v. Sanders. The court also held that Ruiz’s sentence was not unconstitutional under the Eighth Amendment, as Supreme Court precedent limiting life without parole for offenders under 18 did not apply to Ruiz. The Seventh Circuit affirmed the district court’s judgment. View "Ruiz v. Pritzker" on Justia Law

Stericycle, Inc. reorganized its sales department in 2021, creating a new position called Key Account Director (KAD) in both its national and hospital divisions. Cheryl Lane and Adrienne Hause, both female employees, were promoted to the National KAD role. Prior to being promoted, Lane and Hause were National Account Managers with base salaries of $92,784 and $95,026. After expressing concerns about salary disparities between themselves and male Hospital KADs, they received raises increasing their salaries to $98,000. The male Hospital KADs, some promoted and some transferred, generally received higher salaries, with promoted males receiving immediate raises and transferred males retaining their previous, often higher, salaries.The United States District Court for the Northern District of Illinois, Eastern Division, granted summary judgment to Stericycle, finding that Lane and Hause had established a prima facie case under the Equal Pay Act but that Stericycle’s pay practices were justified by a sex-neutral factor: prior salary history. The court found Stericycle had satisfied its affirmative defense for all comparators, concluding that salary disparities were not based on sex. The court also granted summary judgment on the Title VII claim, holding that Lane and Hause had failed to show intentional discrimination.On appeal, the United States Court of Appeals for the Seventh Circuit found genuine disputes of material fact regarding whether Lane and Hause received raises at the time of promotion, as their male counterparts did. The court held that summary judgment was improper in relation to the two promoted male Hospital KADs, as Stericycle failed to prove its affirmative defense as a matter of law, and there was a material factual dispute as to pretext under Title VII. The Seventh Circuit reversed the district court’s judgment and remanded the case for further proceedings. View "Lane v Stericycle, Inc." on Justia Law

Karl Rabenhorst, a former Navy officer employed by FEMA, alleged that he was subjected to age and sex discrimination, a hostile work environment, and retaliation after being removed from a Puerto Rico disaster relief operation and later suspended without pay. The incidents leading to these adverse actions included reprimands for inappropriate interactions with state officials and insubordination, such as sending unauthorized emails and making disrespectful remarks. During the Puerto Rico deployment, Rabenhorst used derogatory language toward younger female coworkers, which prompted his removal from the operation.After his removal, Rabenhorst filed internal complaints, including a grievance with the DHS Office of Equal Rights, alleging discrimination and retaliation. FEMA investigated and ultimately denied his claims, issuing a final agency decision in 2021. Rabenhorst then brought suit in the United States District Court for the Northern District of Illinois, Eastern Division, asserting violations of Title VII and the Age Discrimination in Employment Act (ADEA).The United States District Court for the Northern District of Illinois granted summary judgment for the Secretary of Homeland Security, finding that Rabenhorst failed to establish a prima facie case of discrimination, as he did not meet his employer’s legitimate expectations and could not show that similarly situated employees outside his protected classes were treated more favorably. The court also concluded that Rabenhorst provided no evidence of an objectively hostile work environment or that any adverse conduct was based on his age or sex. Regarding retaliation, the court found no causal link between his protected activity and the suspension decision. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision de novo and affirmed, holding that Rabenhorst did not provide sufficient evidence to support claims of discrimination, hostile work environment, or retaliation. View "Rabenhorst v. Noem" on Justia Law

Ryan O’Donnell and Michael Goree each had their vehicles disposed of by the City of Chicago after failing to pay multiple traffic tickets. The City acted under a municipal code provision that allows for immobilization, towing, and eventual disposition of vehicles registered to owners with outstanding violations. O’Donnell’s vehicle was sold to a towing company at scrap value; Goree’s vehicle was relinquished to a lienholder. Neither was compensated or had proceeds offset against their ticket debt.After these events, O’Donnell and Goree filed a putative class action in the United States District Court for the Northern District of Illinois, Eastern Division. Their complaint alleged that the City’s forfeiture scheme was facially unconstitutional under the Fifth Amendment’s Takings Clause and the Illinois constitution, and included a state-law unjust enrichment claim. They also asserted a Monell claim against the towing company, URT United Road Towing, Inc. The district court dismissed all claims for failure to state a claim, finding that the vehicle forfeiture under the traffic code was not a taking.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s dismissal de novo. The appellate court held that the City’s graduated forfeiture scheme is an exercise of its police power to enforce traffic laws rather than a taking for public use. The court reasoned that this type of law enforcement forfeiture does not trigger the Takings Clause of either the federal or Illinois constitutions. The court further found that because there was no constitutional violation, the plaintiffs’ Monell and unjust enrichment claims also failed. The Seventh Circuit affirmed the district court’s dismissal of all claims. View "O'Donnell v City of Chicago" on Justia Law

Plaintiffs filed a class action against the Department of Homeland Security and Immigration and Customs Enforcement, alleging that the agencies were arresting noncitizens without a warrant in violation of 8 U.S.C. § 1357(a)(2). After years of litigation, the parties entered into a Consent Decree in 2021, approved by the United States District Court for the Northern District of Illinois in 2022. The Decree required the agencies to issue a policy statement, train officers, and document compliance with § 1357(a)(2). It also outlined procedures for enforcement and modification if violations were alleged.Prior to the Decree’s scheduled expiration in May 2025, Plaintiffs moved to enforce its terms and to extend its duration, asserting substantial noncompliance by Defendants. While these motions were pending, a DHS official declared the Decree terminated. On October 7, 2025, the district court found Defendants had violated the Decree, extended its term by 118 days, and ordered compliance-related relief. Later, Plaintiffs sought release or alternative detention for hundreds of individuals allegedly arrested in violation of the Decree. On November 13, 2025, the district court ordered the release of 13 individuals whom both parties agreed were arrested unlawfully, and additionally ordered release or alternatives for approximately 442 “potential class members,” pending determinations of violation.The United States Court of Appeals for the Seventh Circuit reviewed Defendants’ emergency motion to stay the district court’s October 7 and November 13 orders. The Seventh Circuit denied the request to stay the extension of the Consent Decree, holding that Defendants were unlikely to succeed on the merits of their argument that the extension violated 8 U.S.C. § 1252(f)(1). However, the court granted the stay as to the November 13 release order for those arrested pursuant to I-200 warrants and for “potential class members” pending individualized determinations under the Decree. The ruling sets forth the standards for stays and clarifies the limitations of § 1252(f)(1) in the context of class-wide injunctive relief and consent decree enforcement. View "Castanon Nava v. Department of Homeland Security" on Justia Law

A Palestinian American tenant displayed a Palestinian flag in her apartment window to express solidarity with her heritage. In response to a complaint from another resident, the property manager, following a building-wide “neutrality” policy regarding the Israel-Palestine conflict, instructed her to remove the flag. The tenant informed management that her actions reflected pride in her heritage, but was told this was “unacceptable” and warned of eviction if she did not comply. After refusing to remove the flag, she received a notice terminating her tenancy, which cited a lease violation for hanging the flag outside the window. The tenant alleged this justification was pretextual, as management had indicated the flag would not be allowed anywhere, even inside the window. She also claimed other tenants displayed flags or decorations in their windows without consequence, but did not specify that any involved the Israel-Palestine conflict.She filed suit in the Circuit Court of Cook County, alleging violations of the Fair Housing Act (FHA) and state laws. The defendants removed the case to the United States District Court for the Northern District of Illinois, Eastern Division, and moved to dismiss most claims. The district court granted the motion, holding that her complaint did not plausibly allege national origin discrimination, as it did not show the policy was motivated by her national origin or that it had a disparate impact on Palestinians.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The Seventh Circuit held that the tenant failed to allege facts showing intentional national origin discrimination or disparate impact under the FHA. The court also found her interference claim under § 3617 of the FHA insufficient, and determined that the district court properly dismissed the state law claims without prejudice after dismissing the federal claims. View "Farhan v. 2715 NMA LLC" on Justia Law