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

Jonathan Peoples pleaded guilty to felony possession of a controlled substance and was sentenced to one year of incarceration plus one year of mandatory supervised release. He received credit for time served, effectively completing his incarceration term. However, due to Illinois Department of Corrections (IDOC) policies, he was detained at Cook County Jail for four additional days until he could be transferred to IDOC for processing and release.Peoples filed a Section 1983 claim against Cook County and Sheriff Thomas J. Dart, alleging that his detention beyond his sentence violated his constitutional rights. The U.S. District Court for the Northern District of Illinois granted summary judgment in favor of the defendants, concluding that neither the Fourth nor the Fourteenth Amendments applied to Peoples's claim and that he failed to present a triable Eighth Amendment claim.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court determined that the Fourth Amendment did not apply to Peoples's post-conviction detention. Instead, the Eighth Amendment, which prohibits incarceration beyond the end of a sentence without penological justification, was applicable. The court found that the Cook County Sheriff's Office had a penological justification for detaining Peoples until IDOC could process him, as required by Illinois law and the court's commitment order.The Seventh Circuit affirmed the district court's decision, holding that Peoples failed to establish that the Sheriff acted with deliberate indifference, a necessary element for an Eighth Amendment violation. Consequently, without a constitutional injury, Peoples's Section 1983 claim could not succeed. View "Peoples v Cook County" on Justia Law

Waukegan Potawatomi Casino, LLC (WPC) alleged that its Fourteenth Amendment rights were violated when the City of Waukegan did not advance its casino proposal for licensing consideration. WPC claimed it experienced intentional discrimination during the application process as a "class of one." The City of Waukegan certified three other applicants but not WPC, which alleged that the process was rigged to benefit another applicant, Lakeside Casino, LLC. WPC pointed to the relationship between the City's mayor and a founding partner of Lakeside, as well as the City's handling of supplemental information from applicants, as evidence of discrimination.The United States District Court for the Northern District of Illinois granted summary judgment for the City. The court concluded that WPC, as an arm of a sovereign Native American tribe, could not maintain a claim under 42 U.S.C. § 1983. Additionally, the court found that WPC's class-of-one equal protection claim failed because WPC was not similarly situated to the other applicants and there were multiple conceivable rational bases for the City's conduct.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court held that WPC could not carry its heavy burden as a class-of-one plaintiff. The court noted that there were several rational bases for the City's decision, including differences in the casino proposals and the applicants' experience. The court also found that WPC failed to identify a similarly situated comparator who was treated more favorably. The court concluded that the City's conduct throughout the review process, including its handling of supplemental information, had rational justifications. Thus, WPC's class-of-one claim failed under both prongs of the analysis. View "Waukegan Potawatomi Casino, LLC v City of Waukegan" on Justia Law

Manuel Antonio Herrera Hernandez, an inmate at Waupun Correctional Institution, alleged that his legal paperwork was misplaced during his temporary transfer to restrictive housing in October 2021. Before entering restrictive housing, Hernandez surrendered his personal property, including legal documents. Upon return, he signed a form indicating receipt of all his property but later realized his legal paperwork was missing. Hernandez claimed that Sergeant Theresa Lee assured him he would receive his paperwork once he returned to the general population, but it remained missing. Hernandez filed a grievance, which was rejected as untimely by the complaint examiner, and the warden affirmed this decision.Hernandez then filed a lawsuit in federal court under 42 U.S.C. § 1983, claiming that Sergeant Lee and other prison officials deprived him of his right of access to the courts. The United States District Court for the Eastern District of Wisconsin granted summary judgment for the defendants, ruling that Hernandez failed to exhaust administrative remedies.The United States Court of Appeals for the Seventh Circuit reviewed the case. Hernandez argued that his time in restrictive housing complicated his ability to file a timely grievance and that he was not provided a handbook explaining the grievance process in Spanish. The court found that Hernandez did not preserve the handbook issue in the district court. However, the court determined that there were genuine disputes regarding whether Hernandez had any reason to file a grievance before learning his paperwork was missing and whether Sergeant Lee's assurances excused his failure to exhaust administrative remedies.The Seventh Circuit reversed the district court's summary judgment and remanded the case for an evidentiary hearing to resolve the factual disputes regarding the exhaustion of administrative remedies. The court also noted the need to determine the personal involvement of the other defendants in the alleged deprivation. View "Hernandez v Lee" on Justia Law

Shawn Riley, a former prisoner at the Wisconsin Secure Program Facility (WSPF), filed a lawsuit under 42 U.S.C. § 1983 against WSPF’s Health Services Manager, Jolinda Waterman, and Nurse Practitioner Sandra McArdle. Riley alleged that they were deliberately indifferent to his serious medical needs, violating the Eighth Amendment. Riley experienced chronic pain and sought specific medical treatments, including high-top shoes recommended by specialists. Despite receiving various treatments, including medications, physical therapy, and custom orthotics, Riley claimed that his pain persisted and that the defendants ignored specialist recommendations.The United States District Court for the Eastern District of Wisconsin granted summary judgment in favor of the defendants and denied Riley’s motions to appoint counsel. The court found that the defendants were not deliberately indifferent to Riley’s medical needs, noting that they provided extensive medical care and followed many of the specialists' recommendations. The court also concluded that Riley’s requests for special shoes were reviewed and denied by the Special Needs Committee (SNC) and that the defendants' actions did not amount to deliberate indifference.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s decision, holding that the defendants did not ignore the specialists' recommendations and provided adequate medical care. The court also found that the defendants' refusal to allow Riley to purchase shoes from outside the approved catalog did not constitute deliberate indifference. Additionally, the court upheld the denial of Riley’s motion to appoint counsel, determining that Riley was competent to litigate his case and that the case did not present complexities that necessitated appointed counsel. The judgment of the district court was affirmed. View "Riley v. Waterman" on Justia Law

In February 2018, two men invaded a home in Rockford, Illinois, resulting in the death of Julian Young, Jr. and the escape of Jasmine Meneweather. Meneweather initially provided general descriptions of the assailants but no specific identities. Later, she sent a photo of one perpetrator to Detective Eric Harris, but the person was not identified. Over a year later, Harris received another photo from Young’s aunt, identifying the assailants as brothers Cortez and Shawnqiz Lee. Meneweather later identified Shawnqiz Lee in a photo array. Despite Lee’s alibi of being at work during the crime, he was arrested in November 2019 based on a criminal complaint and a judge-issued arrest warrant. A grand jury indicted Lee, but subsequent DNA evidence did not match him. Lee was released in December 2020 after the charges were dismissed.The United States District Court for the Northern District of Illinois granted summary judgment to the police officers, reasoning that probable cause existed based on Meneweather’s identification, which is an absolute defense to Lee’s claims. Lee appealed, arguing that the officers lacked probable cause and that they recklessly withheld material facts.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court’s decision. The court held that probable cause existed based on Meneweather’s identification, which was sufficient to support the arrest warrant. The court also found that the officers did not recklessly withhold material facts that would have negated probable cause. Additionally, the grand jury indictment provided prima facie evidence of probable cause, which Lee failed to rebut. Consequently, the court affirmed the summary judgment in favor of the police officers, concluding that probable cause was an absolute defense to Lee’s Fourth Amendment and state-law claims. View "Lee v Harris" on Justia Law

Caroline Retzios was terminated by Epic Systems Corporation after she refused to be vaccinated against COVID-19, citing religious objections. She filed a lawsuit under Title VII of the Civil Rights Act of 1964, claiming that Epic was required to accommodate her religious beliefs. Epic requested the district court to compel arbitration based on an agreement Retzios had signed, which the court granted, subsequently dismissing the suit.The United States District Court for the Northern District of Illinois dismissed the case after referring it to arbitration, despite Epic's request for a stay. According to the Federal Arbitration Act, a stay should have been issued instead of a dismissal when arbitration is requested. This dismissal allowed Retzios to appeal the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case and determined that the district court erred in dismissing the suit instead of staying it. However, the appellate court proceeded with the case due to the district court's actions. The appellate court found that Retzios's claims fell within the scope of the arbitration agreement she had signed with Epic. The court rejected Retzios's arguments against the enforceability of the arbitration agreement, including her claims of promissory estoppel and waiver. The court also found her objections to arbitration to be frivolous and granted Epic's motion for sanctions, directing Retzios to reimburse Epic for its legal expenses incurred on appeal. The decision of the district court was affirmed, with sanctions imposed on Retzios. View "Retzios v Epic Systems Corp." on Justia Law

Blake Stewardson was arrested for driving under the influence on January 1, 2018, and taken to Cass County Jail. While intoxicated, he directed profanities at police and resisted during intake, leading Officer Titus to slam his head against a wall twice, causing a cut. Titus then performed a leg sweep, causing Stewardson to fall and hit his head. Later, Titus opened a cell door into Stewardson and performed a hip toss. Stewardson sued Titus and Biggs, alleging excessive force and failure to intervene.The United States District Court for the Northern District of Indiana granted summary judgment to the defendants on many claims but allowed two to proceed to trial: one against Titus for excessive force and one against Biggs for failing to intervene. The jury found Titus liable and awarded $400,000 in compensatory damages and $850,000 in punitive damages. Biggs was found not liable for failing to intervene. Titus appealed the punitive damages award, and Stewardson cross-appealed the summary judgment decisions.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court upheld the jury's punitive damages award against Titus, finding it not unconstitutionally excessive given the reprehensibility of his conduct, the ratio of punitive to compensatory damages, and comparable cases. The court also affirmed the district court's summary judgment in favor of Biggs, concluding that he did not violate clearly established law regarding excessive force or failure to intervene. Additionally, the court upheld the summary judgment on Stewardson's Monell claim against Cass County, finding insufficient evidence of an unconstitutional custom. View "Stewardson v. Titus" on Justia Law

An inmate at Green Bay Correctional Institution, who is a practicing Muslim, filed a lawsuit under the Religious Land Use and Institutionalized Persons Act (RLUIPA) against the Wisconsin Department of Corrections (WDOC). He challenged WDOC's policy prohibiting inmates from leading religious programs when no outside religious leader or volunteer is available, claiming it resulted in unnecessary cancellations of religious programs. He also alleged that the cancellation of these programs breached a prior settlement agreement with WDOC.The United States District Court for the Western District of Wisconsin granted summary judgment in favor of WDOC on the RLUIPA claim, finding that the policy was the least restrictive means of furthering the compelling interest of maintaining prison safety and security. The court also granted summary judgment in favor of the inmate on the state law breach-of-contract claim as to liability but relinquished supplemental jurisdiction over the request for injunctive relief.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's summary judgment in favor of WDOC on the RLUIPA claim, agreeing that the policy was the least restrictive means to ensure prison safety and security. However, the appellate court vacated the district court's partial judgment on the state law breach-of-contract claim. The court held that the district court abused its discretion by relinquishing jurisdiction over the remedy portion of the claim while retaining jurisdiction over liability. The case was remanded to the district court to determine whether to retain or relinquish jurisdiction over the entire state law claim. View "West v Hoy" on Justia Law

Kevin Johnson, an inmate in Indiana, filed a pro se lawsuit under 42 U.S.C. § 1983, alleging that he received inadequate dental and mental health care while incarcerated. The case was complicated by the COVID-19 pandemic and Johnson's frequent transfers between prisons in Indiana, Ohio, and Virginia, which disrupted his mail service. Johnson claimed he never received the defendants' summary judgment motions due to these mail issues.The United States District Court for the Southern District of Indiana initially denied the defendants' summary judgment motions without prejudice, recognizing potential mail delivery problems. The court allowed the defendants to refile their motions and instructed them to notify the court if Johnson did not receive the filings. Despite these measures, Johnson did not respond to the refiled motions within the given 28-day period. Consequently, the district court granted summary judgment in favor of the defendants and dismissed the case. Johnson later filed a motion to vacate the judgment, asserting he never received the refiled motions, but the district court denied this motion.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court acknowledged the procedural complexities but focused on whether Johnson had constructive notice of the summary judgment motions. The court concluded that Johnson had constructive notice because he received the district court's order resetting the briefing schedule and instructing him on how to proceed. The court found no substantive or procedural error in the district court's decision and affirmed the summary judgment in favor of the defendants. View "Johnson v Purdue" on Justia Law

Clarence Lewis, an inmate at Hill Correctional Center, sued various medical staff members, alleging they were deliberately indifferent to his health issues, violating the Eighth Amendment. Lewis claimed misdiagnosis and mistreatment of diabetes, COPD, irritable bowel syndrome, and Hepatitis C. He also contended that his grievance about a delay in diabetes medication was not properly addressed.The United States District Court for the Central District of Illinois denied Lewis's motions for recruited counsel, stating he could represent himself and obtain relevant documents. The court granted summary judgment in favor of Dr. Sood, Dr. Bautista, Nurse Vollmer, and Administrator Lindor, concluding no reasonable juror could find deliberate indifference. The court also granted summary judgment for Dr. Paul, citing claim splitting due to a similar prior lawsuit.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the judgment in favor of Dr. Sood, Dr. Bautista, Nurse Vollmer, and Administrator Lindor, finding no reasonable likelihood that recruited counsel would have changed the outcome. The court noted that Lewis's disagreement with his diagnoses and treatments did not constitute deliberate indifference. As for Administrator Lindor, her limited role and the lack of harm from the medication delay further supported the judgment.However, the court vacated the judgment in favor of Dr. Paul, agreeing with Lewis that the district court's application of claim splitting was erroneous. Dr. Paul had raised this defense too late, effectively acquiescing to the claim. The case was remanded for further proceedings regarding Dr. Paul, with the district court advised to reconsider Lewis's request for recruited counsel if the claim proceeds to trial. View "Lewis v Sood" on Justia Law