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

In April 2019, a man was arrested by Chicago police officers after he refused to leave the area of an active crime scene despite repeated orders. During his transport to the police station, he declined to wear a seatbelt. While handcuffed in the backseat, he was injured when the transporting officer braked suddenly, causing him to hit his head on the divider. He was later treated for a cut lip. The disorderly conduct charges brought against him were subsequently dropped.The individual brought suit in the United States District Court for the Northern District of Illinois, Eastern Division, alleging constitutional violations under 42 U.S.C. § 1983—specifically, false arrest, state-created danger, excessive force, and failure to provide adequate medical care. He also asserted a state-law claim for malicious prosecution. The District Court granted summary judgment in favor of the officers on all claims, finding either no constitutional violation or that qualified immunity applied. The plaintiff appealed this decision.The United States Court of Appeals for the Seventh Circuit reviewed the District Court’s grant of summary judgment de novo. The appellate court affirmed the lower court’s judgment, holding that the officers were entitled to qualified immunity on all federal claims, as there was at least arguable probable cause for the arrest and no clearly established constitutional right was violated in the circumstances presented. The court also affirmed the dismissal of the malicious prosecution claim, concluding the plaintiff failed to demonstrate malice by the officers, a required element under Illinois law. Thus, judgment for the officers was affirmed in its entirety. View "O'Neal Johnson v Edwards" on Justia Law

While serving a portion of his sentence at the Federal Correctional Complex in Terre Haute, Indiana, Derek Thomas was repeatedly assaulted by his cellmate, suffering serious physical and psychological harm. Thomas initially sought protective custody after other inmates threatened him due to his conviction as a sex offender. Despite being placed in the Special Housing Unit, he experienced continued threats, food tampering, and was eventually housed with an inmate who violently assaulted and allegedly raped him. Thomas reported these incidents through notes to prison staff and verbally to counselors and psychologists, yet he was not removed from his cell until after the alleged rape. Following his removal, Thomas sought medical and psychological care, but claims his injuries and trauma were not adequately addressed.After filing a pro se complaint in the United States District Court for the Southern District of Indiana, Thomas was allowed to proceed with claims that certain prison officials failed to protect him and were deliberately indifferent to his serious medical needs, both in violation of the Eighth Amendment. The defendants moved for summary judgment, raising qualified immunity as a defense. Thomas’s counsel did not address qualified immunity in the response to the motion, and Thomas later confirmed reliance on counsel’s submission. The district court granted summary judgment to the defendants, concluding Thomas’s claims either presented a new Bivens context not recognized by precedent or failed because Thomas did not overcome the qualified immunity defense.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The appellate court held that Thomas’s failure-to-protect claim could not proceed because it sought to expand Bivens v. Six Unknown Named Agents of the Federal Bureau of Narcotics beyond existing precedent. Regarding the deliberate indifference claim, the court held that Thomas forfeited his opposition to qualified immunity by not raising it in the district court and did not meet the criteria for appellate review of a forfeited argument. View "Thomas v. Carmichael" on Justia Law

A probation officer with the Cook County Juvenile Probation Department alleged that her supervisors created a racially hostile work environment, culminating in her termination for performance issues and insubordination. She cited several workplace incidents, including the enforcement of a no-children-in-the-workplace policy, reprimands related to her work product and interactions with colleagues, and a 2016 meeting where the department director, while reading from a document, said the N-word in front of African American employees (an incident the plaintiff learned about secondhand). The plaintiff’s children occasionally waited in her office after school, and she was reminded of the policy prohibiting this practice. She also disagreed with supervisors over the content of reports submitted to the court, and she was ultimately terminated after an internal investigation found repeated insubordination and issues regarding her communications with clients and the court.The plaintiff first challenged her termination through union arbitration but lost. She then brought a lawsuit under Title VII in the United States District Court for the Northern District of Illinois, alleging that her employer subjected her to a race-based hostile work environment. The district court granted summary judgment in favor of her employer, concluding that the incidents cited, even when considered together, were not sufficiently severe or pervasive as required by Title VII, nor did the plaintiff demonstrate that the alleged harassment was based on race.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision de novo. The Seventh Circuit affirmed, holding that the plaintiff did not present evidence of harassment that was severe or pervasive enough to alter the conditions of employment, nor did she establish that the alleged conduct was based on race. The court also found no error in the exclusion of late-disclosed witness testimony. The judgment for the employer was affirmed. View "Jones v. Das" on Justia Law

While detained at the Hancock County Jail in Indiana, Nicholas Zemlick underwent an elective abdominal surgery. Following his return to the jail, he developed an abdominal infection, experiencing worsening symptoms over several days. Jail medical staff monitored and treated him, ultimately prescribing antibiotics and arranging for a hospital transport after a nurse expressed concern about his condition. Zemlick underwent emergency surgery, recovered, and returned to the jail, where his wound continued to heal without further complications.Zemlick filed suit in the United States District Court for the Southern District of Indiana against the Hancock County Sheriff and two jail officers, alleging violations of his Fourteenth Amendment rights under 42 U.S.C. § 1983 for deliberate indifference to his medical needs. He also brought a Monell claim, asserting that the Sheriff failed to ensure adequate medical resources and training at the jail. The district court granted summary judgment to all defendants on the federal claims, finding no genuine dispute of material fact and relinquished jurisdiction over state-law claims. Zemlick subsequently settled with the medical staff defendants, leaving only the claims against the Sheriff and two officers for appeal.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s summary judgment order de novo. The appellate court held that the individual defendants did not violate Zemlick’s Fourteenth Amendment rights, either because the claims failed on the merits or because the officers were entitled to qualified immunity, as their conduct was not clearly established as unlawful. Regarding the Monell claim, the court found Zemlick’s theories were waived under district court procedures and unsupported by the record. Accordingly, the Seventh Circuit affirmed the district court’s judgment. View "Zemlick v. Burkhart" on Justia Law

Solomon Jones, acting without an attorney, brought a civil rights lawsuit in federal court against several local government entities in Illinois. He alleged that his constitutional rights had been violated during a series of events in 2023, including his being ticketed and arrested for trespassing and disorderly conduct. Subsequent to filing his lawsuit, Jones filed multiple motions, including one requesting the district judge’s recusal.The United States District Court for the Central District of Illinois denied Jones’s motion for recusal. Acting on its own initiative, the court also determined it should abstain from hearing Jones’s claims under the doctrine established in Younger v. Harris, because a related state criminal case was still pending. The district court stayed the federal case, instructing Jones to provide a status update after the conclusion of the state proceedings. While this appeal was pending, Jones notified the court that he had been acquitted in the state criminal case.The United States Court of Appeals for the Seventh Circuit determined it lacked jurisdiction to review the denial of the recusal motion, as no final judgment had been entered. However, it found the stay order based on Younger abstention was immediately appealable. Since the state court proceedings had ended, the appellate court held that the basis for abstention no longer existed. Consequently, the Seventh Circuit vacated the district court’s stay order and remanded the case for further proceedings, directing the district court to address any new developments, such as additional state charges Jones reported, and determine their relevance to the federal case. View "Jones v. Kankakee County Sheriff's Department" on Justia Law

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