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

After completing an orientation program for newly licensed nurses, Bragg was denied a full-time position at Community Hospital, which is operated by Munster. Community transferred her to Hartsfield, another Munster facility, where her pay was lower. Bragg, who is Black, alleged that, during her orientation, after being race-matched to patients, she complained and was subsequently treated differently. Bragg asserts that another supervisor played sexually explicit rap music at the nurses' station when Bragg was present, making graphic hand gestures. Bragg felt this was targeted at her. When white nurses were present, the supervisor played pop and country music. The supervisor allegedly laughingly called a Black patient’s amputated limb a “skinny, brown stick.” Bragg thought that another supervisor made an inappropriate reference to lynching when an oxygen line got wrapped around a Black patient’s neck, stating“let’s not have a hanging.” Bragg claims that all three supervisors gave her poor evaluations and blamed her for problems that were not her fault. Bragg sued under Title VII of the Civil Rights Act, 42 U.S.C. 2000e. The district court granted the defendants summary judgment. The Seventh Circuit affirmed, acknowledging that Bragg’s reports of racial insensitivity are typical of the challenges Black women face in the workplace. Bragg’s evidence would not allow a trier of fact to conclude that Community denied her a full-time position and transferred her for impermissible reasons, rather than for its stated concern about deficiencies in her performance. View "Bragg v. Munster Medical Research Foundation, Inc." on Justia Law

Behning, an Illinois prisoner, claims that prison guards violated his constitutional rights while responding to his altercation with a prison guard. After the incident Behning was taken to the emergency room, was charged with assaulting an officer, and was put in solitary confinement at another institution. While he was in solitary confinement, Behning allegedly timely mailed a grievance over the altercation, inadequate medical care, and procedural defects in his disciplinary hearing to the Illinois Department of Corrections Administrative Review Board. He sent a copy to his attorney, who also forwarded it to the Board. The Board returned it, asserting that only offenders themselves could submit grievances. Behning mailed another grievance, which the prison rejected as untimely.Behning filed suit under 42 U.S.C. 1983.The district court granted summary judgment based on Behning’s failure to exhaust available administrative remedies under the Prison Litigation Reform Act. 42 U.S.C. 1997e. The Seventh Circuit vacated in part. Behning, through his attorney, submitted most of his grievances to the appropriate administrative office, on time. Nothing in the regulation prohibits an offender from submitting a grievance through an attorney. Regardless of how Behning’s grievance arrived, it apprised the Board of the nature of his complaints. View "Behning v.Johnson" on Justia Law

Baro was an ESL teacher for Waukegan Community School District in 2019 when she signed a union membership form—a contract to join the union that represents teachers in the District. The form authorized the District to deduct union dues from her paychecks for one year. Baro alleged she learned later that she was not required to join the union. She tried to back out of the agreement. The union insisted that her contract was valid. The District continued deducting dues from her paychecks.Baro filed suit, arguing that the dues deduction violated her First Amendment rights under the Supreme Court’s 2019 “Janus: decision. The Seventh Circuit affirmed the dismissal of the suit. Baro voluntarily consented to the withdrawal of union dues. The enforcement of a valid private contract does not implicate her First Amendment rights. The “First Amendment protects our right to speak. It does not create an independent right to void obligations when we are unhappy with what we have said.” View "Baro v. Lake County Federation of Teachers Local 504, IFT-AFT" on Justia Law

Braun suffered a seizure and crashed into a telephone pole while driving. Palatine Officer Licari and other officers responded. Braun could not remember what happened. Licari suspected that Braun was intoxicated. The crash occurred late at night. Braun had slurred speech, bloodshot and glassy eyes, and difficulty balancing; he stated that he lived in “Chicago-Miami” and that he had consumed a beer earlier. After observing Braun struggle with field sobriety tests, Licari arrested him. Though an ambulance had been dispatched to the scene, Braun said he was fine and declined medical assistance. At the police station, Licari administered a Breathalyzer test. Braun passed but, based on other indicators of intoxication, Licari took him to a hospital to collect blood and urine samples for more sensitive testing. When the booking process was completed, Braun was released. He suffered another seizure while at the station.Braun sued Licari and the village under 42 U.S.C. 1983, alleging false arrest and failure to provide medical care. The district judge dismissed a “Monell” claim about widespread police misconduct and later entered granted the defendants summary judgment on the other claims. The court found that Licari had probable cause to arrest Braun for DUI; Licari's failure to provide medical care was not objectively unreasonable. The medical-care claim against the village failed for lack of evidence. The Seventh Circuit affirmed. Licari neither knew nor had reason to know of Braun’s initial seizure or other medical needs. View "Braun v. Village of Palatine" on Justia Law

Stapleton lured women into prostitution and exploited them using threats, force, and other forms of coercion. An anonymous tip led to his arrest. Indicted for sex-trafficking crimes, Stapleton claimed that the police had fabricated the anonymous tip and tampered with his cellphone. The court appointed a succession of defense attorneys, but Stapleton constantly disagreed with them regarding his police-misconduct claims. The judge denied his motion to suppress the evidence derived from the anonymous tip. Stapleton then insisted on representing himself. After making the inquiries required by Supreme Court precedent, the judge granted Stapleton’s motion and appointed a standby attorney. Before trial, Stapleton unsuccessfully moved for a court-funded expert to investigate his phone-tampering claim. Before opening statements, Stapleton announced that he would conditionally plead guilty, reserving the right to challenge the suppression ruling. The judge conducted a colloquy and accepted Stapleton’s pleas. Before sentencing, Stapleton unsuccessfully moved to withdraw his pleas. The judge sentenced him to life in prison.Stapleton did not appeal the suppression ruling but argued that his guilty pleas were invalid because he did not have counsel and was confused about his appellate rights and challenged the denial of his motion for a court-funded expert. The Seventh Circuit affirmed. Stapleton validly waived his right to counsel after two thorough colloquies; his guilty pleas were also knowing and voluntary. The judge did not abuse his discretion in denying Stapleton’s request for a court-funded cellphone expert. View "United States v. Stapleton" on Justia Law

The plaintiffs, firefighters and their union, alleged retaliation for protected First Amendment activity. Mayor Copeland, a former firefighter of 26 years, had implemented cost-cutting measures, including freezing the firefighters' salaries and benefits. During Copeland’s reelection campaign, the firefighter’s political action committee endorsed Copeland’s opponent and other candidates who opposed Copeland’s policies. Copeland was reelected. Several firefighters protested at Copeland’s inauguration. Copeland vetoed an ordinance to restore some of the benefits and directed Fire Chief Serna to develop a new schedule. An 8/24 schedule, whereby a firefighter would work eight hours and then be off 24 hours was proposed. No other fire department in the country has adopted that schedule, which assigns firefighters to different shifts every day. In a secretly-recorded conversation, Serna said: “You can call it retaliation.” The defendants proposed to give up the schedule in exchange for the Union giving up its right to lobby the Common Council. The Union rejected the proposal; the city implemented the 8/24 schedule. The Council later returned the firefighters’ to a 24/48 schedule. Copeland sued the Council, alleging that the ordinance violated his executive power. The state court agreed with Copeland and struck the ordinance—leaving the 8/24 schedule in effect.The Seventh Circuit affirmed a preliminary injunction, ordering the city to immediately begin reinstating the old work schedule. There was no evidence that the 8/24 schedule would result in cost savings; the firefighters would suffer irreparable harm without an injunction. View "International Association of Fire Fighters, Local 365 v. City of East Chicago, Indiana" on Justia Law

In 2017, Ramos settled his lawsuits against Cook County Jail correctional officers under 42 U.S.C. 1983 that alleged a failure to protect Ramos from another inmate and the use of excessive force. The settlement agreements contained an identical 262-word sentence—labeled a general release—that released Cook County and its employees from all claims. Months later, Ramos filed another section 1983 lawsuit against two Cook County police officers based on a 2016 arrest that occurred after the events that lead to the first two lawsuits but prior to the execution of the settlement agreements.The Seventh Circuit affirmed the district court’s grant of summary judgment to the defendants. “While the rambling, 262- word sentence is no model of clarity,” it unambiguously released Ramos’s claims arising out of the 2016 arrest. Three phrases signal that Ramos released all foreseeable claims against Cook County “and its agents, employees and former employees,” including those stemming from his 2016 arrest when he signed the settlement agreements in 2017. View "Ramos v. Piech" on Justia Law

Five days after Carter was booked into the Macon County Jail, he died of diabetic ketoacidosis. In the hours preceding his death, Carter exhibited symptoms commonly associated with diabetic ketoacidosis: confusion, lethargy, and labored breathing. He was denied timely medical care because the jail nurse thought he was faking his condition. She assured the corrections officers tasked with transferring Carter out of the medical unit that his vitals were within a normal range. Relying on the nurse’s medical judgment, the officers declined to intervene and proceeded to relocate Carter, believing that his failure to follow orders stemmed from deliberate refusal, not medically induced incapacity.In a suit under 42 U.S.C. 1983, including claims against five corrections officers, the district court denied the officers’ summary judgment based on qualified immunity, finding there to be a material factual dispute over whether they had reason to know that Carter was receiving inadequate medical care, creating a duty to intervene. The Seventh Circuit reversed. Established circuit precedent entitles a corrections officer to defer to the judgment of medical professionals. That is what the officers did here; they are entitled to qualified immunity. View "McGee v. Parsano" on Justia Law

Dorsey, an Illinois state prisoner, was emptying a bucket in the prison laundry when he felt a pop in his lower back and felt pain shoot down his leg. He asked to see a nurse and was told to “go lay down.” Dorsey took ibuprofen and lay down for two hours, but his pain worsened. He again, unsuccessfully, requested permission to seek medical care. The next morning, Dorsey could barely move. Six days later, a nurse concluded that he was exaggerating his symptoms. Dorsey alleges that instead of being treated for back pain, he was prescribed psychiatric medications without his knowledge or consent and was disciplined for refusing to take those medications.Dorsey sued. The district court screened his complaint under 28 U.S.C. 1915A and determined that Dorsey had improperly joined unrelated claims. His complaint asserted three claims under 42 U.S.C. 1983 against 12 defendants. Two claims alleged Eighth Amendment violations based on the poorly maintained washing machines and deliberate indifference to a serious medical condition, his back injury. The third alleged a due process violation, that Dorsey was prescribed medications without his consent. After deeming three amended complaints unsatisfactory, the district court dismissed the case. The Seventh Circuit reversed in part. Dorsey’s claims met both requirements of Rule 20(a)(2), so joinder was legally permissible and the dismissal was an abuse of discretion. The court rejected his other claims. View "Dorsey v. Varga" on Justia Law

Wallace and Santos, inmates at Menard Correctional Center in Illinois filed suit under 42 U.S.C. 1983, alleging that Menard’s “double-ceiling” policy of housing two inmates in single-person cells violated their Eighth Amendment rights. The district court dismissed for failure to exhaust administrative remedies under the Prison Litigation Reform Act (PLRA), 42 U.S.C. 1997e.The Seventh Circuit reversed in part. Where a plaintiff is able to point to some evidence that administrative remedies were not “available” to him under the PLRA, as described by the Supreme Court in its 2016 Ross v. Blake decision, the district court must decide whether remedies were “available” before granting summary judgment on exhaustion. The plaintiffs claimed to have submitted grievances, offered some evidence that other inmates complained of the same issue with no response, and cited a mechanism by which prison officials can allegedly use state law to reject their grievances without any consideration of their merits. The court remanded for consideration of the exhaustion question as it applies to double-celling at Menard. If the district court finds that double-celling remedies were “available,” then the PLRA’s exhaustion requirement applies. The court affirmed a factual determination that Santos did not file a grievance regarding Menard’s double-celling policy. View "Wallace v. Baldwin" on Justia Law