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

The case concerns the plaintiff, Tina Gerlach, who claimed that Indiana officials violated her right to just compensation under the Fifth Amendment's Takings Clause. Gerlach's unclaimed property had been taken into custody by the state under the Revised Indiana Unclaimed Property Act. She asserted that Indiana did not compensate her for interest accrued while the state held her property.Gerlach filed a lawsuit against several state officials, seeking declaratory and injunctive relief, as well as compensation. The defendant officials moved for judgment on the pleadings, arguing that Gerlach's claim for prospective relief was moot and her claims for retrospective relief were barred by the Eleventh Amendment. The district court granted the defendants' motion, and Gerlach appealed.The United States Court of Appeals for the Seventh Circuit affirmed the district court's dismissal. The court found Gerlach's claim for prospective relief was moot due to Indiana's new legislation requiring the payment of interest on all recovered property. The court also held that Gerlach could not obtain compensation in federal court from the Indiana officials because no exception to Eleventh Amendment sovereign immunity applied, and Indiana state courts were open to hear Gerlach's claims. Lastly, the court concluded that Gerlach's claim for compensatory relief was actually against the State of Indiana, and therefore barred by sovereign immunity and Section 1983 of the Civil Rights Act, which does not create a cause of action against a state. View "Gerlach v. Rokita" on Justia Law

The United States Court of Appeals for the Seventh Circuit reviewed a case involving David A. Schlemm, an inmate who had filed a First Amendment retaliation claim against Brendan Pizzala, Jay Van Lanen, and Michael Donovan. Schlemm's claim was based on accusations made against him for theft of sage from the chapel of the Green Bay Correctional Institution, which led to a conduct report being issued against him. The report was later dismissed after another correctional officer testified that he had given the sage to Schlemm. Schlemm then filed complaints against the defendants through the Inmate Complaint Review System (ICRS), claiming retaliation.The lower court had dismissed Schlemm's case, ruling it was time-barred due to the six-year statute of limitations. The court noted that Schlemm's lawsuit, filed in 2019, was more than six years after the 2012 search of his cell. On appeal, the defendants conceded that Schlemm had properly exhausted his administrative remedies, but argued his action was time-barred due to the six-day gap between the accrual of his claim and the filing of his administrative complaints.The Appeals Court reviewed the district court's dismissal de novo and concluded that the defendants had waived their specific statute of limitations argument regarding the six-day gap. They had raised this argument for the first time on appeal, having previously argued that Schlemm had not properly exhausted his administrative remedies. The court reversed the dismissal and remanded for further proceedings, noting that it did not need to address the question of whether the gap between claim accrual and grievance filing is included in the tolling period due to the defendants' waiver of their argument. View "Schlemm v. Pizzala" on Justia Law

The case involves Suzy Martin, the owner and president of Smart Elevators Co., a certified minority- and woman-owned elevator service and repair company. The company, which historically did most of its business with the State of Illinois and the City of Chicago, saw its customer base change after a whistleblower complaint alleged that Martin and her company engaged in a bribery and kickback scheme with a University of Illinois Chicago employee. This led to an investigation by the Office of the Executive Inspector General for the Agencies of the Illinois Governor (OEIG), which concluded that Martin, Smart Elevators, and the University employee had engaged in a kickback scheme that violated Illinois ethics law and University policy and recommended that the University sever ties with Martin and her company.As a result of the report, the State and City ceased doing business with Martin and Smart Elevators, causing the company to lose millions in preexisting and potential contracts. Martin sued several State and City entities and officials under 42 U.S.C. § 1983, bringing “stigma-plus” procedural due process claims under the Fourteenth Amendment. The district court dismissed her amended complaint with prejudice.Upon appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court concluded that Martin's occupation was operating an elevator service and repair business, not just providing those services specifically to the State or City. The court also found that despite the loss of State and City contracts, Martin had not been denied her liberty to pursue her occupation as she remained the owner and operator of Smart Elevators, which continued to operate and even managed to secure a contract with the Department of Justice in 2021. As such, the court found no violation of Martin's occupational liberty rights. View "Martin v. Haling" on Justia Law

In this case heard by the United States Court of Appeals for the Seventh Circuit, the plaintiff, Alexis Wells, sought to hold her employer, The Freeman Company, liable for sexual assault committed by a fellow employee, Timothy Vaughn. Wells asserted that the company should be held responsible under Title VII, the Indiana Wage Payment Statute, and various tort theories. The court, however, affirmed the district court's ruling that Wells was an independent contractor, not an employee, which meant that Freeman's conduct was not tortious and Vaughn's actions could not be attributed to Freeman. The court applied the Knight factors, which analyze the "economic realities" of a work relationship, to determine whether a worker is an employee for purposes of Title VII. The court concluded that most of these factors pointed towards Wells being an independent contractor. Thus, her claims under Title VII and the Indiana Wage Payment Statute failed. The court also dismissed Wells' state law claims for Intentional Infliction of Emotional Distress (IIED) and Negligent Infliction of Emotional Distress (NIED), concluding that Freeman's pre-litigation conduct was not so outrageous as to be regarded as "atrocious," and that Vaughn's conduct was outside the scope of his employment, respectively. Therefore, the court could not hold Freeman vicariously liable for Vaughn's actions. View "Wells v. Freeman Company" on Justia Law

In this case, the plaintiff, Chicago Joe's Tea Room LLC, had plans to open an adult entertainment business in a suburb of Chicago. However, the Village of Broadview denied the plaintiff's application for a special-use permit, which led to the plaintiff claiming that their constitutional rights were violated. The plaintiff sought millions of dollars in lost profits for the business that never opened. The U.S. District Court for the Northern District of Illinois excluded most of the plaintiff's evidence and theories for lost-profit damages due to substantive and procedural issues. The court then awarded the plaintiff just $15,111 in damages. The plaintiff appealed, but the United States Court of Appeals for the Seventh Circuit affirmed the decision of the lower court, finding no abuses of discretion. The appellate court stated that the plaintiff's calculations of lost profits were beyond the scope of the plaintiff's personal knowledge of a similar business and required expert-like analysis and adjustments. The court also ruled that the plaintiff failed to disclose necessary damages evidence in a timely manner, a violation of the Federal Rules of Civil Procedure. The plaintiff was also denied the opportunity to amend their complaint to challenge a state statute, as the request was made a decade after the issue became relevant. The court found that granting the amendment would have caused undue delay and prejudice to the Village. View "Chicago Joe's Tea Room, LLC v. Village of Broadview" on Justia Law

The case concerns an appeal by Brandon Cade against a ruling by the United States District Court for the Northern District of Illinois, Eastern Division, before the United States Court of Appeals For the Seventh Circuit. Cade was arrested by Chicago police officers who noticed an open bottle of alcohol in a sedan next to which Cade and another individual were standing. During a search of the car, officers found an unlicensed firearm and Cade admitted it was his. He was charged with possession of a firearm by a felon. Cade argued to suppress evidence of the gun and his incriminating statements, but the district court denied his motion. Cade pleaded guilty but reserved his right to appeal the suppression ruling. He argued that his initial encounter with the officers was an unlawful seizure and that his incriminating statements should be suppressed because the officers did not have reasonable suspicion to seize him.The Court of Appeals affirmed the lower court's ruling. The court found that the initial encounter with the officers was consensual and did not constitute a seizure. The court also ruled that even if there was an unlawful seizure, Cade's incriminating statements were sufficiently attenuated from any allegedly unlawful conduct. The presence of the open alcohol bottle provided probable cause for the search, which led to the discovery of the firearm, and Cade's admission to owning the firearm occurred after he was read his Miranda rights. The court concluded that there was no evidence of bad faith by the officers, and that an evidentiary hearing was not needed as there were no material factual disputes. View "United States v. Cade" on Justia Law

Jeffrey Bruno, a veteran firefighter with the Kankakee Fire Department, sued Mayor Chasity Wells-Armstrong, James Ellexson, the Human Resources Director for the City of Kankakee, and the City of Kankakee, alleging discrimination and retaliation under the Americans with Disabilities Act (ADA) and the Illinois Human Rights Act (IHRA). Bruno suffered a severe cardiac event in 2017 and upon his return to work was promoted to Deputy Chief. However, in 2019, he was denied a raise and presented with an employment contract that tied additional compensation to his enrollment in college courses. When Bruno requested the removal of this education condition, citing his heart condition as a barrier to attending classes, his request was denied. After signing the contract, Bruno retired and initiated legal proceedings.The United States Court of Appeals For the Seventh Circuit affirmed the district court's decision, which had granted summary judgment for the defendants. The court concluded that Bruno's request to remove the education condition was not a request for a reasonable accommodation under the ADA, as it would not impact his ability to perform his job. The court also rejected Bruno's claim of disparate treatment, as his argument of pretext was contradicted by the evidence. Bruno's ADA retaliation claim also failed because his identified protected activity was not protected under the ADA. As Bruno's IHRA and indemnification claims were dependent on his ADA claims, these too were rejected. View "Bruno v. Wells-Armstrong" on Justia Law

This case involves a federal habeas corpus petition by Darnell Dixon, who was convicted of home invasion and murder by an Illinois state court and sentenced to life imprisonment. Dixon's habeas petition primarily focused on claims of actual innocence and prosecutorial misconduct. The United States Court of Appeals for the Seventh Circuit affirmed the denial of his habeas petition by the United States District Court for the Northern District of Illinois.The case involved a series of events including a drug-related robbery and subsequent murders. Dixon and Eugene Langston were implicated in the murders, with Langston identified in a police lineup by a witness, Horace Chandler. However, Chandler later recanted this identification. The state's case against Dixon relied heavily on a confession that Dixon later claimed was false. Dixon's confession and Chandler's identification of Langston were central to the state's theory of accomplice liability, arguing that Dixon was accountable for Langston's acts.In his habeas petition, Dixon argued that he was denied due process when the trial court excluded evidence that charges against his alleged accomplice, Langston, were dismissed. He also asserted that his trial counsel was ineffective for failing to object to the exclusion of that evidence. Furthermore, Dixon claimed that the state committed prosecutorial misconduct by presenting conflicting positions regarding Langston's involvement in the murders at trial and during post-conviction proceedings.However, the Seventh Circuit found that Dixon's claim of actual innocence, based on the state's post-conviction contention that Langston's involvement was irrelevant and evidence of abusive and perjurious conduct by the case's police detective, did not meet the high standard required to conclusively prove his innocence. The Seventh Circuit also rejected Dixon's arguments of prosecutorial misconduct and ineffective assistance of counsel, finding no clear error in the district court's factual findings on these issues. View "Darnell Dixon v. Tarry Williams" on Justia Law

In the case at hand, the plaintiff, Benjamin Adams, an inmate at Indiana’s Plainfield Correctional Facility, sued the current and former commissioners of the Indiana Department of Corrections and various other officials pursuant to 42 U.S.C. § 1983, alleging that they violated his First and Eighth Amendment rights, as well as his Fourteenth Amendment rights to due process and equal protection. Adams was sentenced to a prison term of 30 years for attempted murder and a consecutive term of four years for involuntary manslaughter. He was assigned to work in the prison kitchen, but that assignment was rescinded due to concerns that he might use the assignment to smuggle drugs into the prison. He was later charged with offense A-100 for engaging in criminal gang activity related to an assault in the prison. Disciplinary Hearing Officer J. Peltier found Adams guilty of that offense on March 16. He was ordered to spend one year in disciplinary segregation, 365 days of his earned good time credits were revoked, and he was demoted from credit-earning class 1 to class 3.The United States Court of Appeals for the Seventh Circuit affirmed the district court's grant of summary judgment in favor of the defendants. The appellate court concluded that Adams' claim of First Amendment retaliation lacked sufficient evidence to suggest that the defendants were motivated by a retaliatory intent to pursue the assault charge against him. The court also held that Adams was not deprived of his Fourteenth Amendment due process rights, as prison disciplinary hearings require only informal due process, which leaves substantial flexibility in the hands of prison administrators. Regarding the Equal Protection claim, the court found no evidence that Adams was treated differently based on his race. Lastly, the court concluded that the defendants could not be held liable for violating Adams' Eighth Amendment rights as there was no evidence that they had control over the conditions of restrictive housing where Adams was placed. View "Adams v. Reagle" on Justia Law

In a case before the United States Court of Appeals For the Seventh Circuit, plaintiff Catherine Erdman, a firefighter from Janesville, Wisconsin, applied for a position with the Madison fire department. Erdman claimed that the Madison fire department's Physical Abilities Test (PAT), which she failed to pass, had a disparate impact on women, violating Title VII of the Civil Rights Act of 1964. Erdman proposed an alternative test, the Candidate Physical Abilities Test (CPAT), licensed by the International Association of Fire Fighters (IAFF), which she claimed would have less disparate impact on women while still effectively measuring an applicant's physical abilities.The district court found that Erdman had shown the Madison PAT had a prima facie disparate impact on women. However, it also found that the Madison PAT was job-related and served the city’s legitimate needs, and that Erdman had failed to prove that the IAFF test would adequately serve the city’s legitimate needs. Erdman appealed the decision.The appeals court affirmed the district court's ruling. It agreed that the Madison PAT as a whole, not its individual components, should be considered as the "particular employment practice" for the purpose of determining disparate impact. The court found that Erdman had established her prima facie case of disparate impact as the Madison PAT as a whole showed a statistically significant disparate impact on female applicants.However, the appeals court also agreed with the district court's finding that Erdman failed to prove that the IAFF test would serve the Madison fire department's legitimate needs as well as the Madison PAT. This was based on testimony that certain elements of the Madison PAT were specifically designed for Madison, considering the city’s characteristics, the fire department’s equipment, and safety considerations. Also, the court noted that the Madison fire department had a higher-than-average rate of hiring and retaining female firefighters compared to the national average, suggesting the effectiveness of the Madison PAT. View "Erdman v. City of Madison" on Justia Law