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

Indiana enacted a law prohibiting physicians from altering a child's sex characteristics through medication or surgery as treatment for gender dysphoria. Plaintiffs, including transgender children, their parents, and a physician, argued that the law violated their rights under the Equal Protection Clause, substantive due process, and the First Amendment. The district court found these arguments likely to succeed and issued a preliminary injunction against the law. Indiana appealed the decision.The United States District Court for the Southern District of Indiana granted a preliminary injunction, finding that the plaintiffs were likely to succeed on their claims that the law violated the Equal Protection Clause and the First Amendment. The court concluded that the law discriminated based on sex and transgender status and that the aiding and abetting provision regulated speech based on its content. The court also found that the balance of harms favored the plaintiffs and that they would suffer irreparable harm without the injunction.The United States Court of Appeals for the Seventh Circuit reviewed the case and reversed the district court's decision. The Seventh Circuit held that the law did not classify based on sex or transgender status in a way that warranted heightened scrutiny. The court applied rational basis review and found that the law was rationally related to the state's legitimate interest in protecting children from uncertain and potentially harmful medical treatments. The court also held that the law's aiding and abetting provision did not violate the First Amendment, as it regulated speech integral to unlawful conduct. The court vacated the preliminary injunction and remanded the case for further proceedings. View "K.C. v. Individual Members of the Medical Licensing Board" on Justia Law

Six former commanders of the Cook County Jail filed a lawsuit under 42 U.S.C. §1983, claiming their layoffs in late 2017 violated their First Amendment rights. The layoffs occurred during a budget crisis, which led to the elimination of their positions. The plaintiffs argued that the layoffs were retaliatory, linked to their support for unionization efforts by the Teamsters Union, which the Sheriff opposed.The United States District Court for the Northern District of Illinois granted summary judgment in favor of the Sheriff. The court found that the evidence did not support an inference that the commanders' pro-union speech caused the layoffs. The court concluded that the layoffs were a result of a significant budget shortfall, not retaliation for union activities.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that the budget crisis was the primary reason for the layoffs. It noted that the Illinois Labor Relations Board had determined the commanders were supervisors and not entitled to collective bargaining. The court found no evidence that the Sheriff's Office targeted the commanders for their union activities, as the layoffs affected all commanders regardless of their stance on unionization. The court also observed that the overall unionized workforce increased after the layoffs, further undermining the plaintiffs' claims of anti-union retaliation. The court concluded that reasonable jurors could not find the Sheriff's explanation for the layoffs to be pretextual. View "Consolino v. Dart" on Justia Law

In January 2015, Sarah Schoper, a tenure-track assistant professor at Western Illinois University, suffered a traumatic brain injury resulting in high-functioning mild aphasia and other physical disabilities. Despite her condition, she returned to teaching in May 2015, with accommodations from the University. Schoper applied for tenure in 2017 but was denied based on her teaching evaluations, which had declined post-injury. She then filed a lawsuit alleging disability discrimination and failure to accommodate under the Americans with Disabilities Act.The United States District Court for the Central District of Illinois granted summary judgment in favor of the University. The court found that Schoper could not prove that her disability was the but-for cause of her negative tenure recommendation. Additionally, the court ruled that Schoper failed to show how her requested accommodation—additional time to meet tenure criteria—would enable her to perform the essential functions of her job.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that Schoper was not a qualified individual under the ADA because her teaching evaluations did not meet the University's tenure requirements. The court also found that her request for more time to achieve tenure was not a reasonable accommodation, as it essentially sought a second chance rather than a modification to enable her to perform her job. Furthermore, the court concluded that no reasonable jury could find that Schoper's disability was the but-for cause of the University's decision to deny her tenure, given the multiple layers of review and the lack of evidence showing discriminatory intent by the reviewers. View "Schoper v. Board of Trustees of Western Illinois University" on Justia Law

In February 2020, a police officer in Wauwatosa, Wisconsin, shot and killed a Black teenager, Alvin Cole. Following the incident, community members organized protests against police violence and racism. Anticipating unrest after the district attorney decided not to charge the officer, the mayor imposed a curfew. Plaintiffs, affected by the curfew and police conduct, filed constitutional and state law claims against the City of Wauwatosa and individual defendants.The United States District Court for the Eastern District of Wisconsin dismissed most claims, allowing only First Amendment and Driver’s Privacy Protection Act (DPPA) claims to proceed. The court later granted summary judgment for the defendants on the First Amendment claims, leaving only the DPPA claims for trial. The jury ultimately ruled in favor of the defendants on the DPPA claims.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s rulings, holding that the curfew was a permissible time, place, and manner restriction under the First Amendment. The court found that the curfew was content-neutral, served a significant government interest in public safety, was narrowly tailored, and left open ample alternative channels for communication. The court also upheld the dismissal of the plaintiffs' § 1983 claims against individual defendants, agreeing that the claims were inadequately pleaded and that the district court did not abuse its discretion in denying further amendments. Lastly, the court found no abuse of discretion in the district court’s response to a jury question regarding the definition of “personal information” under the DPPA. The judgment of the district court was affirmed. View "Knowlton v. City of Wauwatosa" on Justia Law

On the night of July 18, 2019, in Charlestown, Indiana, bystanders called 911 to report a fight between RJ Slaymaker and his wife, Amylyn Slaymaker. Two police officers responded, separated the couple, and learned from Amylyn that RJ was drunk, had hit her, had guns, and was threatening to kill her and himself. RJ denied the allegations. The officers called an ambulance for RJ to seek mental health help at a hospital but did not place him under a 24-hour mental health hold. RJ left the hospital shortly after arriving, returned home, and killed Amylyn before committing suicide.The administrator of Amylyn’s estate sued Officer Roederer and the estate of Officer Johnson, claiming they created a danger by misleading Amylyn into believing RJ would be held for 24 hours, thus making her believe it was safe to return home. The United States District Court for the Southern District of Indiana granted summary judgment to the defendants, concluding they were entitled to qualified immunity.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s judgment regarding Officer Roederer, finding no evidence of his personal involvement in making assurances to Amylyn. However, the court reversed the judgment regarding Officer Johnson, finding that a jury could reasonably infer that he misled Amylyn about RJ’s detention, creating a danger she would not have otherwise faced. The court held that Officer Johnson’s actions could be seen as a violation of clearly established law under the state-created danger doctrine, as established in Monfils v. Taylor. The case against Officer Johnson’s estate was remanded for further proceedings. View "Rakes v. Roederer" on Justia Law

A student at Rosalind Franklin University was accused of sexual assault by another student after a night of heavy drinking and marijuana use. The accused student, Nicholas Gash, had no memory of the events due to his intoxication. The university conducted an investigation, during which Gash received notices of allegations and participated in interviews. Despite attempting to withdraw from the university, Gash was informed that his withdrawal was not approved, and the Title IX hearing proceeded. The hearing panel found Gash responsible for the alleged assault and sanctioned him with expulsion.The United States District Court for the Northern District of Illinois dismissed Gash’s claims of sex-based discrimination under Title IX and breach of contract under Illinois law. The court found that the procedural errors cited by Gash did not suggest sex-based discrimination. Gash’s state law contract claims were also dismissed, as the court determined that he did not meet the high burden of showing that the university acted arbitrarily or in bad faith.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court affirmed the district court’s dismissal, holding that the procedural errors and alleged biases did not plausibly suggest sex-based discrimination. The court noted that the errors could indicate a pro-victim or pro-complainant bias but not an anti-male bias. Additionally, the court found that Gash did not provide sufficient evidence to support his breach of contract claim, as he failed to show that the university acted without a rational basis or in bad faith. The court concluded that the university’s actions, while flawed, did not constitute sex-based discrimination or breach of contract. View "Gash v. Rosalind Franklin University" on Justia Law

Carl McDaniel, a Wisconsin prisoner with multiple serious medical conditions, sued the Wisconsin Department of Corrections under the ADA and the Rehabilitation Act, claiming the Department violated his rights by denying him a cell in a no-stairs unit, a single-occupancy cell, and a bed without a top bunk. He also brought an Eighth Amendment claim against Dr. Salam Syed, alleging deliberate indifference to his medical needs. The district court granted summary judgment for the Department on all claims and for Dr. Syed on the Eighth Amendment claim. McDaniel appealed.The United States District Court for the Eastern District of Wisconsin initially handled the case. McDaniel, representing himself, submitted evidence that he missed approximately 600 meals in one year due to the pain and difficulty of navigating stairs to access meals and medications. The district court, however, largely discounted McDaniel’s factual statements and granted summary judgment for the defendants, concluding that McDaniel’s cell assignment was reasonable and that his medical treatment did not violate the Eighth Amendment.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the summary judgment for the Department on the claims for a single-occupancy cell and no top bunk, as well as the Eighth Amendment claim against Dr. Syed. However, it reversed the summary judgment on the refusal to assign McDaniel to a no-stairs unit. The court found that McDaniel presented sufficient evidence that the denial of a no-stairs unit effectively denied him access to meals and medications, which could be seen as an intentional violation of the ADA and the Rehabilitation Act. The court also held that McDaniel’s ADA and Rehabilitation Act claims for compensatory damages survived his release from prison and his death.The Seventh Circuit concluded that a reasonable jury could find that the denial of a no-stairs unit amounted to an intentional violation of McDaniel’s rights under the ADA and the Rehabilitation Act, and that the Department was not entitled to sovereign immunity. The case was remanded for further proceedings consistent with this opinion. View "McDaniel v. Syed" on Justia Law

Rene Galvan, a former employee of the Indiana Department of Child Services (DCS), filed a lawsuit against the State of Indiana and his former supervisor, Joanie Crum, alleging race and sex discrimination, retaliation, and a violation of his Fourteenth Amendment right to due process. Galvan, a large Mexican male, claimed he was terminated based on his race and sex and retaliated against for his complaints of discrimination. He also alleged that Crum deprived him of his property rights without due process. The district court granted summary judgment in favor of the defendants, and Galvan appealed.The United States District Court for the Southern District of Indiana granted summary judgment to the defendants, finding no evidence that Galvan’s termination was based on race or sex discrimination. The court noted that Galvan’s performance issues, including his judgment regarding child safety and professional demeanor, were well-documented. The court also found no causal connection between Galvan’s complaints of discrimination and his termination, dismissing his retaliation claim. Additionally, the court held that Galvan received adequate due process before his termination, as he was given notice of the charges and an opportunity to respond.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court’s decision. The appellate court agreed that Galvan failed to provide sufficient evidence to support his claims of discrimination and retaliation. The court also found that the pre-termination procedures provided to Galvan met the requirements of due process, as he was given notice of the charges and an opportunity to respond. The court concluded that the district court properly granted summary judgment in favor of the defendants. View "Galvan v. State of Indiana" on Justia Law

Thad Brockett, a former employee of the Effingham County Sheriff’s Department, alleged he was terminated for supporting the former sheriff in disputes with the county chair and for reporting misconduct by two correctional officers. Brockett claimed that after he reported the officers for violating inmate safety and sexually harassing female inmates, the county chair and board shielded the officers from discipline. Subsequently, the newly elected sheriff terminated Brockett, allegedly due to budget cuts, which Brockett argued was a pretext for retaliation.The United States District Court for the Southern District of Illinois dismissed Brockett’s claim under 42 U.S.C. § 1983 for First Amendment retaliation. The court found that Brockett’s speech was not protected by the First Amendment because it pertained to personal matters and was made pursuant to his official duties, not as a private citizen. Brockett appealed the dismissal, arguing that his speech addressed matters of public concern and was protected political activity.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The appellate court noted that Brockett failed to provide sufficient arguments or legal analysis to support his claim that his speech was a matter of public concern and that he spoke as a private citizen. The court emphasized that public employees must demonstrate that their speech addresses matters of public concern and is made as private citizens to claim First Amendment protection. Brockett’s failure to adequately argue these points resulted in the waiver of his claims, leading to the affirmation of the district court’s decision. View "Brockett v. Effingham County, Illinois" on Justia Law

Brian Jones, a Wisconsin prisoner, sued several correctional officers under 42 U.S.C. § 1983, alleging violations of his Eighth Amendment rights. The claims arose from an incident where Jones caused a disturbance in the prison dayroom, refused to return to his cell, and was subsequently placed in a restraint chair and transported to a restrictive-housing cell. Jones alleged that the officers used excessive force, conducted an unlawful strip search, and confined him in a dirty cell.The United States District Court for the Eastern District of Wisconsin granted summary judgment in favor of the officers on all claims. Jones, who represented himself during the lower court proceedings, argued on appeal that the magistrate judge should have granted his request for pro bono counsel under 28 U.S.C. § 1915(e)(1). The magistrate judge had denied this request, concluding that Jones was competent to litigate the straightforward case on his own.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that the magistrate judge applied the correct legal standard and reasonably concluded that Jones was capable of handling the case himself. The court also determined that the video evidence conclusively showed that Jones's claims lacked merit. The video demonstrated that the officers used only minimal force, conducted the strip search in a professional manner, and that Jones's cell conditions did not amount to a constitutional violation. Consequently, the Seventh Circuit affirmed the district court's judgment, holding that the denial of pro bono counsel was appropriate and that the officers did not violate Jones's Eighth Amendment rights. View "Jones v. Anderson" on Justia Law