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

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

A high-school administrator, Justin Schimandle, forcibly restrained a student, C.G., at school. Following an investigation, Detective Josh Duehning of the Dekalb County Sheriff’s Office submitted affidavits to support an arrest warrant for Schimandle on battery charges. An Illinois state magistrate judge issued the warrant, and Schimandle turned himself in. The criminal case proceeded to a bench trial, where Schimandle was found not guilty after the prosecution rested.Schimandle then sued the Dekalb County Sheriff’s Office and Duehning, alleging false arrest. The defendants moved for judgment on the pleadings, and the United States District Court for the Northern District of Illinois granted the motion, dismissing Schimandle’s claims. The court found that there was probable cause to arrest Schimandle and that Duehning was entitled to qualified immunity.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that arguable probable cause supported Schimandle’s arrest, meaning a reasonable officer could have believed probable cause existed based on the circumstances. The court also found that Duehning was entitled to qualified immunity, protecting him from liability for the false arrest claim. Additionally, the court noted that the magistrate judge’s issuance of the arrest warrant further supported the reasonableness of Duehning’s actions. Consequently, the court affirmed the dismissal of Schimandle’s complaint. View "Schimandle v. DeKalb County Sheriff's Office" on Justia Law

Marlo Spaeth, an individual with Down syndrome, was employed by Wal-Mart for over 15 years. Her work schedule was changed from 12:00 p.m. to 4:00 p.m. to 1:00 p.m. to 5:30 p.m., causing her significant difficulty in adapting due to her disability. Despite requests from Spaeth and her sister to revert to her original schedule, Wal-Mart did not accommodate her, leading to her termination for attendance issues. The Equal Employment Opportunity Commission (EEOC) filed a lawsuit on Spaeth’s behalf under the Americans with Disabilities Act (ADA), alleging failure to accommodate her disability.The United States District Court for the Eastern District of Wisconsin held a jury trial, which resulted in a verdict in favor of the EEOC. The jury awarded Spaeth $150,000 in compensatory damages and $125 million in punitive damages, which the court reduced to $150,000 to comply with the ADA’s damages cap. The court also awarded backpay, prejudgment interest, and compensation for tax consequences, totaling $419,662.59. However, the district court denied the EEOC’s requests for broader injunctive relief, ordering only Spaeth’s reinstatement and communication with her guardian regarding future issues.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the jury’s findings on liability and the awards of compensatory and punitive damages. It held that Wal-Mart was aware of Spaeth’s need for a schedule accommodation due to her Down syndrome and failed to engage in the interactive process required by the ADA. The court found sufficient evidence to support the jury’s award of punitive damages, noting Wal-Mart’s reckless indifference to Spaeth’s rights. The court also upheld the compensatory damages, finding them rationally related to the evidence of Spaeth’s emotional distress and depression.However, the Seventh Circuit vacated the district court’s denial of broader injunctive relief and remanded for reconsideration. The court noted that the district court had incorrectly characterized all requested injunctive relief as “obey the law” injunctions and failed to consider the possibility of recurring discriminatory conduct. The district court was directed to reassess the need for injunctive measures to prevent future violations. View "EEOC v. Wal-Mart Stores East, L.P." on Justia Law

In 2018, Officer Patrick Kaine of the City of Wauwatosa Police Department stopped a vehicle based on a citizen's tip about a potential robbery. The vehicle contained Akil Carter, Paulette Barr, and Sandra Adams. Officer Kaine handcuffed Carter and placed him in the back of his squad car while he investigated. He soon realized the tip was mistaken, uncuffed Carter, and allowed the group to leave. Carter, Barr, and Adams subsequently sued Officer Kaine, other officers, and the City of Wauwatosa, alleging violations of their Fourth Amendment rights.The case was initially heard in the United States District Court for the Eastern District of Wisconsin, where the jury found in favor of the defendants. The plaintiffs appealed, challenging several pretrial and trial decisions, including the bifurcation of the trial, jury instructions, exclusion of their police-practices expert, and the judge's failure to recuse himself. They also contested the district judge's denial of their Batson challenge to a peremptory strike.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found no error in the district judge's decisions regarding bifurcation, jury instructions, exclusion of the expert, or recusal. However, the court determined that the district judge did not properly conduct the third step of the Batson inquiry, which requires assessing whether the race-neutral reasons for the peremptory strike were pretextual. The court remanded the case for further findings on the Batson challenge to Juror 10, instructing the district judge to complete the three-step Batson process and make the necessary credibility determinations on the record. The court affirmed the district court's decisions in all other respects. View "Carter v. City of Wauwatosa" on Justia Law

Trevor Davis filed a lawsuit against Deputy Christopher Allen under 42 U.S.C. § 1983, claiming that Allen violated his Fourth Amendment rights by using excessive force during his arrest. Davis had several outstanding warrants for violent felonies, and when officers arrived to arrest him, he fled into a trailer. Deputy Allen used his police dog, Koda, to locate Davis inside the trailer. Despite Davis lying face-down with his hands over his head, Koda bit him, causing severe injury. Davis alleged that Allen failed to recall Koda after Davis had surrendered.The United States District Court for the Western District of Wisconsin denied Deputy Allen’s motion for summary judgment. The court found that there were material disputes of fact regarding the circumstances and timing of the use of the police dog, which precluded a finding of qualified immunity at this stage. Specifically, the court noted that a jury could find that a reasonable officer would have known that Davis had surrendered and that continuing to allow Koda to bite him constituted excessive force.The United States Court of Appeals for the Seventh Circuit reviewed the case and dismissed the appeal for lack of appellate jurisdiction. The court noted that the district court’s denial of qualified immunity was based on disputed facts, which are not subject to interlocutory appeal. The Seventh Circuit emphasized that the reasonableness of Deputy Allen’s actions depended on resolving these factual disputes, such as whether Davis was visibly unarmed and compliant. The court concluded that it could not address the merits of the qualified immunity claim without first resolving these factual issues, which must be done by a jury. View "Davis v. Allen" on Justia Law