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

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

Joel Cielak and Barron Hodges were sexually abused by David Johnson, a teacher at Nicolet High School (NHS), in the late 1970s and early 1980s. Hodges reported the abuse in 1983, leading the school board to confront Johnson but keep him employed under supervision. Johnson ceased abusing Hodges but continued to abuse Cielak, who had graduated in 1982. Both plaintiffs sued NHS, the school district, and board members under 42 U.S.C. §§ 1983 and 1985, alleging violations of their Fourteenth Amendment rights and a conspiracy to violate their equal protection rights. The district court dismissed the claims with prejudice and denied leave to amend the complaint.The United States District Court for the Eastern District of Wisconsin granted the defendants' motion to dismiss, concluding that the plaintiffs failed to state claims based on Johnson's abuse predating Hodges's 1983 allegation. The court also found that Hodges's claims were time-barred and that Cielak's allegations of post-allegation harms did not amount to violations of his substantive due process or equal protection rights. The court denied the plaintiffs leave to amend their complaint, deeming it futile.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court held that Hodges's claims were time-barred as he knew of his injuries and their cause in the fall of 1983. In contrast, the court found that it was unclear when Cielak knew or had reason to know that his post-allegation injuries were connected to actions by the defendants, making it improper to dismiss his claims on statute of limitations grounds at this stage. However, the court concluded that Cielak failed to plausibly plead a violation of his substantive due process or equal protection rights because Johnson's post-allegation abuse was not under color of state law. The court also upheld the denial of leave to amend, noting that the plaintiffs failed to explain how they would cure the complaint's defects. View "Cielak v. Nicolet Union High School District" on Justia Law

Three plaintiffs, planning to participate in protests during the Democratic National Convention in Chicago, challenged the constitutionality of a city ordinance listing prohibited items within security perimeters. The list includes items such as laptops, large bags, drones, bicycles, and pointed objects, among others. Plaintiffs argued that the ordinance is unconstitutionally vague, particularly concerning the prohibition of "pointed object(s)," which they feared could include everyday items like ballpoint pens and buttons.The United States District Court for the Northern District of Illinois denied the plaintiffs' request for a preliminary injunction, finding that the ordinance was not unconstitutionally vague. The plaintiffs then appealed this decision.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 the ordinance has a core of ascertainable meaning, covering items that pose clear safety risks, such as weapons and explosives. The court noted that while the plaintiffs raised concerns about potential overreach, they had not demonstrated that a substantial number of the ordinance's applications were unconstitutional. The court concluded that the plaintiffs' facial challenge to the ordinance lacked merit, as the potentially problematic applications were not substantial in relation to the valid ones. The court also found that the plaintiffs had standing to challenge the ordinance but ultimately ruled against them on the merits. View "Thayer v. City of Chicago" on Justia Law

The plaintiff, Word Seed Church, now known as Grace Fellowship Covenant Church, sought to establish a permanent location in the Village of Hazel Crest but faced difficulties due to the village's zoning ordinance. The church claimed that the ordinance discriminated against religious assemblies by not listing churches as a permitted use in any zoning district and requiring a special use permit for churches in certain residential districts. The church argued that this process was burdensome and discriminatory, violating the Equal Protection Clause and the Religious Land Use and Institutionalized Persons Act (RLUIPA).The United States District Court for the Northern District of Illinois initially denied the church's motion for a preliminary injunction, finding that the church had standing but was unlikely to succeed on the merits. Later, the district court granted summary judgment in favor of the village, concluding that the church did not have a property interest in Hazel Crest and had not shown that comparable secular organizations were treated more favorably. The court also rejected the church's vagueness challenge to the zoning ordinance. The church did not appeal the summary judgment but instead filed a Rule 60(b) motion for relief from judgment, arguing that the district court had evaluated the wrong version of the zoning ordinance. The district court denied this motion.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's denial of the Rule 60(b) motion. The appellate court found that the district court did not abuse its discretion in its decision. The court noted that the church's argument regarding the zoning ordinance amendments was not raised during the summary judgment proceedings and that the church had waived any challenge to the B-2 district, which was affected by the 2008 amendment. The appellate court concluded that the church's difficulties in finding a property were due to the lack of suitable parcels, not the zoning ordinance. View "Word Seed Church v. Village of Hazel Crest" on Justia Law

Courtney Ealy, an inmate in the Illinois prison system, spent five consecutive months in segregation starting in 2019. During this period, he experienced cold temperatures, dirty cells, and faulty plumbing, which he claimed negatively affected his mental and physical health. Ealy sued several prison officials, alleging violations of his Fourteenth Amendment right to due process. He also filed multiple motions for recruitment of counsel during the litigation.The United States District Court for the Central District of Illinois granted summary judgment in favor of the defendants, Cameron Watson, David D. Frank, and Angela McKittrick, and denied Ealy's motions for recruitment of counsel. The court found that Ealy had received due process before being placed in disciplinary segregation and that the conditions of his confinement did not constitute an atypical and significant hardship. The court also determined that Ealy was competent to represent himself despite his claims to the contrary.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 Ealy received all the due process he was entitled to, including advance written notice of the charges, an opportunity to be heard, and a written statement of the evidence and reasons for the disciplinary action. The court also found that the district court did not abuse its discretion in denying Ealy's motions for recruitment of counsel, noting that Ealy's case was not complex and that he appeared competent to represent himself based on his filings. View "Ealy v. Watson" on Justia Law

Christine Bube and Connie Hedrington, both registered nurses, worked for Aspirus, Inc., a non-profit hospital system. In response to the COVID-19 pandemic, Aspirus mandated that all employees receive the COVID vaccine, allowing exemptions for religious reasons. Bube and Hedrington applied for religious exemptions, citing their Catholic faith and beliefs about bodily integrity and health. Aspirus denied their requests and terminated their employment in December 2021.The United States District Court for the Western District of Wisconsin dismissed Bube and Hedrington’s Title VII claim, reasoning that their accommodation requests did not sufficiently tie their objections to specific religious beliefs or practices. The court concluded that their objections were primarily about personal autonomy and vaccine safety, rather than religious beliefs.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that an employee seeks accommodation because of their religion when their request is plausibly based at least in part on some aspect of their religious belief or practice. Applying this standard, the court found that Bube’s and Hedrington’s requests were indeed based in part on their religious beliefs. The court emphasized that Title VII’s broad definition of religion requires a hands-off approach to defining religious exercise. The court reversed the district court’s dismissal and remanded the case for further proceedings. View "Bube v. Aspirus Hospital, Inc" on Justia Law

Two healthcare workers, Megan Passarella and Sandra Dottenwhy, employed by Aspirus Health in Wisconsin, sought religious exemptions from the company's COVID-19 vaccination mandate. Passarella cited her Christian belief that her body is a temple of the Holy Spirit and expressed concerns about the vaccine's safety. Dottenwhy also referenced her Christian faith, stating that her body is a temple and expressing distrust in the vaccine's development and long-term effects. Both were denied exemptions and subsequently terminated.The United States District Court for the Western District of Wisconsin dismissed their Title VII claims, ruling that their objections were based on medical judgment rather than religious conviction. The court found that the plaintiffs did not articulate any religious belief that would prevent them from taking the vaccine if they believed it was safe.The United States Court of Appeals for the Seventh Circuit reversed the district court's decision. The appellate court held that an employee's request for accommodation is based on religion if it is plausibly connected to their religious beliefs or practices, even if it also includes non-religious reasons. The court emphasized that Title VII's definition of religion is broad and includes all aspects of religious observance and practice. The court found that both Passarella's and Dottenwhy's exemption requests were at least partially based on their religious beliefs, making them sufficient to survive a motion to dismiss. The case was remanded for further proceedings to determine the sincerity of the plaintiffs' beliefs and whether Aspirus could reasonably accommodate them without undue hardship. View "Dottenwhy v. Aspirus, Inc." on Justia Law

Gary Hicks, a corrections sergeant, was suspended for 10 days by the Illinois Department of Corrections after an internal investigation into his Facebook posts, which were described as "Islamophobic" and "offensive" by a news article. The investigation concluded that Hicks violated Department policies prohibiting conduct unbecoming of a State employee or that may reflect unfavorably on the Department. Hicks admitted to making the posts, which included derogatory comments about various groups and a prayer for a civil war or government overthrow. He sued the Department and officials under 42 U.S.C. § 1983, alleging First Amendment retaliation and a Fourteenth Amendment challenge to the Department’s policies.The United States District Court for the Central District of Illinois granted summary judgment in favor of the defendants on both claims. The court held that Hicks’s suspension did not violate the First Amendment because his posts were not on matters of public concern, and the Department’s interest in maintaining discipline outweighed his interest in speaking. The court also found that the Department’s policies were not impermissibly vague as applied to Hicks’s conduct and granted qualified immunity to the defendants.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The court concluded that the Department’s interest in managing its affairs outweighed Hicks’s interest in posting the content, thus he could not sustain a First Amendment retaliation claim. Additionally, the court found that the Department’s code of conduct was not impermissibly vague as applied to Hicks, as a reasonable officer would understand that his posts were unbecoming and could reflect unfavorably on the Department. Therefore, the court affirmed the summary judgment in favor of the defendants on both the First and Fourteenth Amendment claims. View "Hicks v. Illinois Department of Corrections" on Justia Law

Phillip Robbin was removing a tree from a residential lot in the City of Berwyn when he was confronted by Sarah Lopez, a city inspector. Lopez berated Robbin using racial slurs, which led Robbin to demand disciplinary action against her. The Mayor of Berwyn denied Robbin's request for Lopez's termination, leading Robbin to sue the City, the Mayor, and Lopez for violations of his substantive due process rights under the Fourteenth Amendment and state law.The United States District Court for the Northern District of Illinois dismissed Robbin’s complaint under Federal Rule of Civil Procedure 12(b)(6), finding that he failed to state a federal claim. The court also declined to exercise supplemental jurisdiction over the state law claims, leading to Robbin's appeal.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court held that Robbin failed to allege a violation of a fundamental right and that the conduct described did not "shock the conscience," which are necessary elements for a substantive due process claim under the Fourteenth Amendment. The court noted that while Lopez's use of racial slurs was deplorable, it did not rise to the level of a constitutional violation. Consequently, the Seventh Circuit affirmed the district court's dismissal of Robbin's complaint. View "Robbin v. City of Berwyn" on Justia Law

Reginald Pittman, a pretrial detainee at the Madison County jail, attempted suicide and suffered a severe brain injury. He claimed that two guards ignored his requests for crisis counseling before his suicide attempt. Pittman sued Madison County and various jail officials under 42 U.S.C. § 1983, alleging a violation of the Fourteenth Amendment for failing to provide adequate medical care. The case has a lengthy procedural history, including three appeals and three trials.The United States District Court for the Southern District of Illinois initially granted summary judgment for the defendants, but this was reversed in part by the Seventh Circuit in Pittman I. After a first trial, the Seventh Circuit in Pittman II reversed and remanded for a new trial due to the erroneous exclusion of evidence. In Pittman III, the Seventh Circuit found a jury instruction error and remanded for a third trial. In the third trial, the district court instructed the jury in line with Pittman III, requiring proof that the officers were subjectively aware or strongly suspected a high likelihood of self-harm. The jury returned a verdict for the defendants.The United States Court of Appeals for the Seventh Circuit reviewed the case and found that the jury instruction was erroneous. The court clarified that Pittman did not need to prove subjective awareness of the risk of harm. Instead, the jury should have been instructed to determine whether the defendants made an intentional decision regarding Pittman’s conditions of confinement and whether they acted objectively unreasonably by failing to mitigate the risk. Despite this error, the court concluded that the erroneous instruction did not prejudice Pittman, as the case was presented as a credibility contest between the testimony of the guards and an inmate. Therefore, the Seventh Circuit affirmed the verdict for the defendants. View "Pittman v. Madison County, Illinois" on Justia Law