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

In the early hours of July 19, 2018, Peoria Police Officer Ryan Isonhart fatally shot Luis Cruz, who was fleeing from officers and allegedly pointing a gun at Officer Nicholas Mason. Lyrah Hernandez, Cruz’s sister, filed a lawsuit on behalf of Cruz’s estate, alleging federal claims under 42 U.S.C. § 1983 and state law claims against Officers Isonhart and Mason, and the City of Peoria. The district court granted summary judgment for Officer Mason, and the case proceeded to trial against the remaining defendants. The jury found in favor of the defendants. Hernandez appealed, arguing that the district court erred in admitting certain evidence and excluding testimony from two individuals.The United States District Court for the Central District of Illinois admitted evidence including the crimes underlying the 49 messages, the Department of Child and Family Services investigation, Cruz’s incarceration at the time of his daughters’ birth, and his pending drug charge. The court found these pieces of evidence relevant to the officers’ state of mind and Cruz’s damages. The court also barred testimony from forensic scientist Jennifer MacRitchie, ruling it was expert in nature and not properly disclosed, and excluded a recorded statement from Shaquille Alexander, finding it lacked trustworthiness.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s evidentiary rulings for abuse of discretion. The appellate court affirmed the district court’s decisions, finding that the admitted evidence was relevant and not unduly prejudicial, and that the exclusion of MacRitchie’s testimony and Alexander’s statement was appropriate. The court concluded that any potential error in admitting Cruz’s pending drug charge was harmless given the overwhelming evidence supporting the jury’s verdict. The judgment of the district court was affirmed. View "Hernandez v City of Peoria, Illinois" on Justia Law

Jacques Rivera, after being released from over 20 years in prison for a wrongful murder conviction, sued the City of Chicago and several police officers under 42 U.S.C. §1983 for civil rights violations. A jury awarded him over $17 million, and his attorneys sought more than $6 million in fees and costs. The case was settled for $18.75 million, including at least $3.75 million for attorneys' fees and costs. Chicago, which had an insurance policy with Starstone Insurance SE covering liabilities between $15 and $20 million, sought indemnity for the $3.75 million. Starstone refused, claiming their policy only covered damages, not attorneys' fees and costs, and filed for a declaratory judgment.The United States District Court for the Northern District of Illinois ruled in favor of Chicago, determining that the insurance policy covered the entire $18.75 million settlement as an "ultimate net loss" that Chicago was legally obligated to pay. Starstone appealed this decision.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court first addressed whether Starstone, a Societas Europaea (SE) based in Liechtenstein, qualified as a "corporation" under 28 U.S.C. §1332 for diversity jurisdiction purposes and concluded that it did. On the merits, the court found that the insurance policy's language covered the entire settlement amount, including attorneys' fees and costs, as part of the "ultimate net loss" Chicago was legally obligated to pay. The court affirmed the district court's decision, holding that the policy's terms included indemnity for attorneys' fees and costs awarded under statutory provisions. View "Starstone Insurance SE v City of Chicago" on Justia Law

Raymond Tackett, an inmate with the Indiana Department of Corrections (IDOC), suffered from Hepatitis C (HCV) and did not receive direct-acting antivirals (DAAs), a treatment that cures HCV. He died on November 29, 2019, from complications related to HCV. His daughter, Skyler Tackett, as the personal representative of his estate, filed an Eighth Amendment deliberate indifference claim and a state law medical malpractice claim against the medical professionals who treated him, Wexford Health Services, and Dr. Kristen Dauss, the Chief Medical Officer of the IDOC. She later dismissed all claims except the deliberate indifference claim against Dr. Dauss.The United States District Court for the Southern District of Indiana granted summary judgment in favor of Dr. Dauss, finding that she took reasonable steps to expand access to DAAs and was not responsible for the treatment decisions that led to Mr. Tackett’s death. Ms. Tackett appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court’s judgment. The court found that Ms. Tackett presented insufficient evidence for a reasonable jury to find Dr. Dauss liable in her individual capacity. The court noted that Mr. Tackett was in a treatment priority group and that Nurse Myers had requested DAAs for him, but there was no evidence that Dr. Dauss’s actions or the IDOC policy prevented him from receiving the treatment. The court concluded that while Mr. Tackett’s death was tragic, there was no evidence that Dr. Dauss’s actions amounted to deliberate indifference under the Eighth Amendment. View "Tackett v Dauss" on Justia Law

Susan Kinder, a white woman, was employed by the Marion County Prosecutor’s Office (MCPO) and alleged racial discrimination when she was reassigned to a new role. She claimed violations of Title VII and the Equal Protection Clause. Kinder had conflicts with a black colleague, Lydia Richardson, who accused her of making racially insensitive remarks. An investigation found the animosity was mutual. The prosecutor decided to reassign both employees, but Kinder viewed her new role as a demotion.The Equal Employment Opportunity Commission (EEOC) issued a right-to-sue letter on April 28, 2022, but Kinder’s counsel could not access it until July 6, 2022. Kinder filed her complaint on October 4, 2022, alleging Title VII and Equal Protection Clause violations. The MCPO moved for summary judgment, arguing the Title VII claim was untimely and that the office was not a suable entity under 42 U.S.C. § 1983. The United States District Court for the Southern District of Indiana granted summary judgment to the MCPO, finding the Title VII claim was filed outside the 90-day window and that the MCPO was an arm of the state, immune from § 1983 claims.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The court held that the 90-day period for filing the Title VII claim began when Kinder’s counsel was notified on June 15, 2022, that the right-to-sue letter was available, making the October 4 filing untimely. The court also held that the MCPO is an arm of the state and not a suable “person” under § 1983, as the office is financially interdependent with the state and enjoys state indemnification for employment-related actions. View "Kinder v Marion County Prosecutor's Office" on Justia Law

Eric Blackmon was arrested in 2002 and charged with murder, leading to his conviction in 2004 after a bench trial. Despite multiple attempts, state judges in Illinois upheld his conviction. However, the United States Court of Appeals for the Seventh Circuit directed a district court to hold an evidentiary hearing regarding the failure of Blackmon’s lawyer to interview potential alibi witnesses, which resulted in the district court ordering his release unless retried. The state chose to release him rather than retry him. Subsequently, Blackmon filed a suit under 42 U.S.C. §1983 against three police officers, alleging that the photo array and lineup used for his identification were unconstitutionally suggestive.The United States District Court for the Northern District of Illinois denied the officers' motion for judgment on the ground of qualified immunity, concluding that it is clearly established that the results of unduly suggestive photo arrays and lineups must not be used at trial. The officers appealed this decision.The United States Court of Appeals for the Seventh Circuit reviewed the case and held that the police do not violate a suspect’s constitutional rights by conducting a suggestive photo array or lineup. The court emphasized that the introduction of evidence at trial is the responsibility of prosecutors and judges, who have absolute immunity. The court concluded that the appropriate remedy for suggestive identification procedures is the exclusion of evidence at trial, not damages. The court also noted that it was not clearly established in 2002 that officers could be personally liable under §1983 for conducting a suggestive lineup. Therefore, the officers were entitled to qualified immunity. The decision of the district court was reversed. View "Blackmon v. Jones" on Justia Law

In December 2015, sixteen-year-old Isaiah Taylor was stopped by Milwaukee police officers Justin Schwarzhuber and Jasen Rydzewski while running through his neighborhood to deliver a turkey. The officers frisked him, searched his bag, and detained him in their police car to check for outstanding warrants and recent robberies. Taylor later sued the officers under 42 U.S.C. § 1983, claiming an unreasonable search and seizure in violation of the Fourth Amendment and racial profiling in violation of the Equal Protection Clause of the Fourteenth Amendment.The United States District Court for the Eastern District of Wisconsin granted qualified immunity and summary judgment to the officers on Taylor’s Fourteenth Amendment claim and on the Fourth Amendment claim regarding the initial stop and frisk. However, the court denied qualified immunity on the issue of Taylor’s continued detention, sending it to trial. The jury found the officers not liable, and the court denied Taylor’s motion for post-trial relief under Federal Rule of Civil Procedure 59.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the grant of summary judgment on Taylor’s Fourteenth Amendment claim, finding insufficient evidence of racial profiling. However, it vacated the summary judgment on the Fourth Amendment claims related to the initial stop and frisk, concluding that the officers lacked reasonable suspicion for the stop and frisk based on clearly established law. The court also vacated the jury verdict on the continued detention issue, as it was intertwined with the initial stop's constitutionality, and remanded the case for a new trial on all Fourth Amendment claims. View "Taylor v. Schwarzhuber" on Justia Law

Kevin Brooks, an inmate at a federal prison camp, suffered from appendicitis, which was misdiagnosed by medical personnel as constipation and COVID-19. Despite his worsening condition, he was not sent to a hospital for over ten days, resulting in a ruptured appendix and peritonitis. Brooks eventually recovered but experienced severe pain during the ordeal. He filed a lawsuit seeking damages from five federal employees, three of whom treated him and two who were supervisors.The United States District Court for the Northern District of Illinois dismissed Brooks's suit, ruling that it presented a new context to which the doctrine of Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics does not extend. The court reasoned that Brooks's case differed from previous Bivens cases, particularly Carlson v. Green, due to the duration of his medical issue and the involvement of supervisory personnel.The United States Court of Appeals for the Seventh Circuit reviewed the case and disagreed with the district court's reasoning. The Seventh Circuit held that Brooks's claim did not present a new context, as it was similar to Carlson v. Green, where a prisoner alleged constitutionally inadequate medical care. The court found that the distinctions made by the district court regarding the duration of the medical issue and the involvement of supervisors were not sufficient to create a new context. The Seventh Circuit affirmed the dismissal of claims against the two supervisors but vacated the dismissal of claims against the three treating personnel, remanding the case for further proceedings. View "Brooks v. Richardson" on Justia Law

A tenured professor at the University of Illinois Chicago School of Law, Jason Kilborn, included an expurgated racial slur in a law school exam question. This led to an investigation by university officials, who found that Kilborn had created a racially hostile environment and violated the university's nondiscrimination policy. Consequently, Kilborn was suspended from teaching until he completed a diversity training program and was denied a two percent raise. Kilborn sued several university officials, alleging violations of his constitutional rights to free speech and due process.The United States District Court for the Northern District of Illinois dismissed Kilborn's federal claims with prejudice, finding that his speech was not constitutionally protected. The court also declined to exercise supplemental jurisdiction over his state law claims, dismissing them without prejudice. Kilborn appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case and reversed the dismissal of Kilborn's First Amendment retaliation claim, concluding that his speech was constitutionally protected under the Supreme Court's decisions in Connick v. Myers and Pickering v. Board of Education. The court found that Kilborn's speech addressed matters of public concern and that the university's actions could be seen as pretextual. However, the court affirmed the dismissal of Kilborn's remaining federal claims, including his compelled speech and procedural due process claims. The court also vacated the dismissal of Kilborn's state law claims for further consideration by the district court. View "Kilborn v. Amiridis" on Justia Law

The plaintiffs, Thomas Ghelf, Tricia Hansen, Constance and Thomas Klein, Maureen Sommerfeld, and Mississippi Sports and Recreation, Inc. (MSR), own abutting properties in the Town of Wheatland, Vernon County, Wisconsin. They alleged that the Town, its officials, Vernon County, the County Treasurer, and unknown agents and employees engaged in a harassment campaign against them. This included coordinated complaints about their businesses, unlawful arrests, failures to respond to emergency services, excessive property tax assessments, a foreclosure action, and the designation of a private driveway as a public road.The United States District Court for the Western District of Wisconsin dismissed the plaintiffs' tax assessment and road claims for lack of subject matter jurisdiction, abstained from exercising jurisdiction over the foreclosure claims, and dismissed the remaining claims for failure to state a claim. The court held that the Tax Injunction Act and principles of comity barred the tax assessment and foreclosure claims. It also found that the plaintiffs' claims related to events before September 15, 2016, were time-barred by the statute of limitations.The United States Court of Appeals for the Seventh Circuit affirmed the district court's dismissal of the tax assessment and foreclosure claims, agreeing that the Tax Injunction Act and comity principles deprived the district court of jurisdiction. The appellate court also upheld the dismissal of claims related to events before September 15, 2016, as time-barred. However, the Seventh Circuit reversed the dismissal of the plaintiffs' road claims, finding that these claims were not barred by claim or issue preclusion. The case was remanded for further proceedings on the road claims, and the court held that Town Chairman Jayne Ballwahn should not be dismissed from the suit at this stage. View "Ghelf v Town of Wheatland" on Justia Law

Jack William Morgan, a Messianic Jew, purchased a turkey log from the commissary at the Federal Correctional Institution (FCI) Thomson in May 2021, which led to the suspension of his kosher diet approval for thirty days by the institutional chaplain. Morgan claimed this forced him to choose between starvation and violating his religious beliefs, and he chose starvation. After exhausting administrative remedies, he sued the Federal Bureau of Prisons (BOP) and the prison warden, Andrew Ciolli, seeking changes to dietary policies and monetary damages under the Religious Freedom Restoration Act (RFRA). Morgan has since been transferred to a different BOP facility.The United States District Court for the Northern District of Illinois dismissed Morgan’s complaint with prejudice for failure to state a claim. The court found that Morgan did not provide sufficient factual allegations to show that the BOP’s dietary policies substantially burdened his religious exercise. Additionally, the court noted that the BOP is immune from suits for damages under RFRA and that Morgan’s complaint did not include allegations about Ciolli’s conduct.The United States Court of Appeals for the Seventh Circuit reviewed the case and focused on two threshold issues: subject-matter jurisdiction and sovereign immunity. The court determined that Morgan did not adequately allege standing to pursue his claim for injunctive relief, as his threat of future injury was too speculative. Furthermore, the court held that federal sovereign immunity barred Morgan’s claim for monetary damages, as RFRA does not waive the federal government’s sovereign immunity against damages suits. The court affirmed the district court’s dismissal but modified the judgment to reflect a jurisdictional dismissal. View "Morgan v BOP" on Justia Law