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

William Manery filed a lawsuit under 42 U.S.C. § 1983 in Indiana state court against Lieutenant Jason Lee and other defendants, alleging that Lee used excessive deadly force in violation of the Fourth Amendment. The case was removed to the United States District Court for the Southern District of Indiana. Lee moved for summary judgment, claiming qualified immunity, but the district court denied the motion, citing genuine issues of material fact.The district court acknowledged that Lee knew Manery was wanted for serious crimes and believed he was armed and had threatened "suicide by cop." However, the court found that factual disputes about the threat level at the time Lee fired his weapon precluded summary judgment. The court assumed, without deciding, that Lee might have violated Manery's constitutional rights but concluded that the issue of whether the law was clearly established was intertwined with these factual disputes, necessitating a jury's resolution.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court noted that Lee accepted Manery's version of the facts for the appeal. The court emphasized that qualified immunity protects officers unless they violate clearly established rights that a reasonable officer would know. The court found that the cases cited by Manery did not clearly establish that Lee's use of deadly force was unreasonable under the specific circumstances. Given the rapidly evolving situation and the information Lee had, the court concluded that a reasonable officer in Lee's position would not have known that using deadly force was a violation of Manery's rights.The Seventh Circuit reversed the district court's denial of qualified immunity and remanded the case for further proceedings consistent with its opinion. View "Manery v Lee" on Justia Law

Nathaniel Pryor was stopped by police in Aurora, Illinois, after officers received a tip about drug activity linked to a van. Pryor exited the van quickly, and an officer ordered him to the ground, took him down, struck him twice, and searched him. No drugs were found, and Pryor was charged with obstructing/resisting a police officer, but the charge was later dropped. Pryor then sued several officers and the City of Aurora, alleging multiple federal and state law claims, including under 42 U.S.C. § 1983.The United States District Court for the Northern District of Illinois granted in part the defendants' motion for summary judgment, dismissing some claims and allowing others to proceed to trial. At trial, the jury found in favor of the defendants on the remaining claims. Pryor appealed, arguing that the district court erred in its summary judgment decision and in various evidentiary and procedural rulings during the trial.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the district court did not err in granting summary judgment on Pryor’s false arrest claim, finding that the officers had probable cause to arrest him for obstruction of justice and resisting arrest. The court also upheld the district court’s decision to grant qualified immunity to the officer for the leg sweep and tackle, as Pryor failed to show that the use of force was clearly established as excessive under the circumstances. Additionally, the court found that the searches conducted by the officer were proper incidents to Pryor’s arrest and were not extreme or patently abusive.The Seventh Circuit also affirmed the district court’s evidentiary and procedural rulings, including the admission of drug surveillance evidence, the exclusion of certain testimony by Pryor, and the handling of jury instructions. The court concluded that the district court did not abuse its discretion in these decisions and that any errors were harmless. The judgment of the district court was affirmed in full. View "Pryor v. Corrigan" on Justia Law

Attorney Stephen Eberhardt filed a 102-page, 19-count complaint against 11 defendants, including the Village of Tinley Park, its officials, attorneys, and residents, alleging a scheme to prevent him from making public comments at Village board meetings and on Village-related Facebook pages, violating his constitutional rights. He also brought claims against the Village’s outside counsel, Patrick Walsh, under the Illinois Open Meetings Act. The district court dismissed the complaint without prejudice for being too lengthy and jumbled. Eberhardt then filed an amended complaint, which was also dismissed, and the court entered final judgment.Following the judgment, Walsh’s attorney filed a motion for sanctions under Rule 11 of the Federal Rules of Civil Procedure, arguing that Eberhardt’s claims were frivolous and filed in bad faith to harass Walsh. The district court granted the motion, ordering Eberhardt to pay $26,951.22 in attorneys’ fees, finding that his claims were frivolous and brought with inadequate investigation into the relevant law and facts. The court noted Eberhardt’s history of filing numerous lawsuits and motions, which indicated bad faith.Eberhardt appealed to the United States Court of Appeals for the Seventh Circuit, challenging the district court’s decision to sanction him and its denial of his motion to reconsider. The Seventh Circuit reviewed the case and found no abuse of discretion in the district court’s decisions. The court affirmed the sanctions order, agreeing that Eberhardt’s claims were frivolous and brought in bad faith, and that a hearing was not necessary as the record was adequate to determine the need for sanctions. The court also affirmed the denial of the motion to reconsider, finding no manifest errors of law or fact. View "Eberhardt v. Walsh" on Justia Law

The case involves a class action lawsuit filed by transgender women prisoners in Illinois, who allege that the Illinois Department of Corrections (IDOC) has been deliberately indifferent to their gender dysphoria, a serious medical condition. The plaintiffs seek injunctive relief to ensure timely evaluations and treatments, including hormone therapy, gender-affirming surgery, and appropriate support for social transitioning.The United States District Court for the Southern District of Illinois initially issued a preliminary injunction on February 7, 2022, which was intended to address the plaintiffs' claims. The court later issued further injunctions to supplement and modify the terms. However, more than a year and a half after the preliminary injunction was issued, the district court retroactively labeled it as a permanent injunction and issued a final judgment consistent with the February 7, 2022 decision. The defendants appealed several injunctions and a finding of civil contempt by the district court.The United States Court of Appeals for the Seventh Circuit reviewed the case and found that the district court's attempt to retroactively transform the preliminary injunction into a permanent one was not authorized. The appellate court held that under the Prison Litigation Reform Act (PLRA), the preliminary injunction issued on February 7, 2022, expired 90 days later, on May 8, 2022. Consequently, the appellate court vacated all existing injunctions and remanded the case for further proceedings consistent with its opinion. The court also dismissed the portion of the appeal challenging the finding of contempt, as the district court had not yet imposed any sanctions, which are necessary to establish appellate jurisdiction. View "Monroe v. Bowman" on Justia Law

In late 2020, the FBI began investigating Tyron Offutt for narcotics trafficking in Centralia, Illinois. A confidential informant conducted three controlled purchases of methamphetamine from Offutt, which were recorded. Based on these buys, a search warrant was obtained and executed on February 3, 2021. Offutt attempted to flee during a traffic stop but was eventually apprehended. The search of his residence revealed methamphetamine, firearms, marijuana, cash, and drug paraphernalia.The United States District Court for the Southern District of Illinois appointed Dan Cronin as Offutt’s attorney, but he was later replaced by Rebecca J. Grosser due to a conflict of interest. Offutt was indicted on multiple counts related to drug distribution and firearm possession. Offutt requested new counsel multiple times, citing communication issues, and eventually, Bobby Edward Bailey was appointed as his third attorney. Offutt’s trial commenced on December 6, 2022, and he was found guilty on three counts but the jury could not reach a verdict on one count.On appeal to the United States Court of Appeals for the Seventh Circuit, Offutt challenged his conviction and sentence, arguing that the district court erred in instructing the jury that his flight could be considered evidence of guilt and that his Sixth Amendment right to counsel was violated when his request for counsel at sentencing was denied. The Seventh Circuit held that the flight instruction did not affect the trial's outcome and that Offutt had constructively waived his right to counsel by refusing to work with appointed attorneys and failing to retain private counsel. The court affirmed Offutt’s conviction and sentence. View "USA v. Offutt" on Justia Law

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