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

Rodney Clemons, an inmate at Stateville Correctional Center, filed a lawsuit against Wexford Health Sources, Inc., and two of its physicians, alleging that they were deliberately indifferent to his serious foot condition. Clemons had injured his right ankle before his incarceration and suffered from pain in his right ankle and foot for several years while incarcerated. He claimed that the defendants prioritized cost concerns over reasoned medical judgment.The case was initially heard in the United States District Court for the Northern District of Illinois, Eastern Division. The district court granted summary judgment to the defendants, concluding that the treatment plan adopted by the physicians was reasonable and that there was no evidence of a widespread pattern of indifference that could infer a constitutional violation by Wexford.Clemons appealed to the United States Court of Appeals for the Seventh Circuit. The appellate court affirmed the district court's decision. The court found that the prison doctor's treatment decisions were not so unacceptable that no minimally competent professional would have responded in the same way. The court also found that the alleged policy of limiting referrals to trim costs was not facially unconstitutional. Furthermore, Clemons failed to show a pattern of violations that would infer that Wexford was aware of and condoned the misconduct of their employees. Therefore, the court concluded that Clemons failed to show that the defendants were deliberately indifferent to his serious medical needs. View "Clemons v. Wexford Health Sources, Inc." on Justia Law

The case revolves around Tondalaya Gamble, a Black physician who worked at Cook County Health’s John Stroger Hospital for approximately eleven years. Gamble sued Cook County and her former department and division chairs, Edward Linn and Fidel Abrego, alleging race discrimination. She claimed that Cook County violated Title VII of the Civil Rights Act of 1964 and the Illinois Human Rights Act, and that Linn and Abrego violated 42 U.S.C. §§ 1981 and 1983. Gamble argued that she was paid less than similarly situated non-Black physicians.The United States District Court for the Northern District of Illinois granted summary judgment in favor of the defendants, concluding that no reasonable jury could find in Gamble’s favor on any of her claims. The court found that Gamble failed to establish that she was similarly situated to her chosen comparators, two white physicians, Bruce Rosenzweig and Karen Fish. The court noted that Rosenzweig was a part-time employee while Gamble was full-time, and that Fish had more experience and was hired to perform different duties.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court agreed that no reasonable jury could find that Gamble was similarly situated to Rosenzweig or Fish. The court noted that the part-time versus full-time distinction was not dispositive in and of itself, but that other differences, such as their different duties and experience, made them inapt comparators for Gamble’s discrimination claim. The court concluded that Gamble presented no other evidence suggesting that her pay or demanding work responsibilities were because of her race. View "Gamble v. County of Cook" on Justia Law

Minosa Echols, a civil detainee in an Illinois facility, was seriously injured when another resident attacked him. Echols filed a lawsuit under 42 U.S.C. § 1983, alleging that three security officers present during the assault violated his rights under the Fourteenth Amendment’s Due Process Clause by failing to protect him. The case went to trial, and the jury returned a verdict in favor of the defense. Echols appealed, arguing that the district court committed a legal error in its jury instruction.The district court had instructed the jury that to succeed on a failure-to-protect claim, Echols needed to show that the officer in question was subjectively aware that the other resident presented a risk of harm to Echols. On appeal, the United States Court of Appeals for the Seventh Circuit agreed that the jury instruction was erroneous. The court stated that Echols did not need to prove subjective awareness of the risk of harm to establish liability. Instead, the jury should have been instructed to determine whether a reasonable officer in the defendant’s position would have appreciated that the conditions within the dayroom put Echols at risk of harm, and whether the defendant acted in an objectively unreasonable way in addressing that risk.However, to prevail on appeal, Echols also needed to show that the error prejudiced him. The court found that Echols failed to do so. The court concluded that the attack was so unexpected that no reasonable officer, in the circumstances before them, would have anticipated the surprise attack or taken different measures to protect Echols. Therefore, the court affirmed the lower court's decision. View "Echols v. Johnson" on Justia Law

Raynard Jackson, a prisoner at the Wisconsin Secure Program Facility (WSPF), was placed in a cell without running water for five days. He alleged that Lieutenant Dane Esser, among other WSPF staff, knew that he did not have water and yet failed to turn the water on. After Jackson showed another staff member that he did not have water, the water was promptly turned on; however, he claimed Lt. Esser and other WSPF staff failed to provide him with medical care for his dehydration. Jackson filed grievances pertaining to these issues. After he exhausted his administrative remedies within the WSPF, he sued Lt. Esser and other WSPF staff under 42 U.S.C. § 1983 for violating his Eighth and Fourteenth Amendment rights.The district court, only considering the processed grievances, and without holding an evidentiary hearing, found that Jackson had not exhausted his administrative remedies as to certain claims and defendants. Additional defendants, Nurse Beth Edge and Captain Dale Flannery, were dismissed at summary judgment, leaving only the claims against Lt. Esser for trial. The jury found for Lt. Esser on both claims.The United States Court of Appeals for the Seventh Circuit agreed with Jackson that the district court should not have disregarded his allegedly unprocessed grievances without holding an evidentiary hearing. However, the court found no error in the district court’s conclusion that Jackson’s processed grievances did not exhaust remedies as to all his claims. The court also found no error in the district court’s grant of summary judgment to Nurse Edge or its evidentiary rulings before trial. The court affirmed in part, reversed in part, and remanded for a hearing on the allegedly unprocessed grievances. View "Jackson v. Esser" on Justia Law

Rodney Lass was initially charged with misdemeanor domestic abuse. However, the case ended in a mistrial due to the alleged victim's disregard of a court order. Subsequently, the prosecutors recharged the case, adding multiple felony counts. Lass was found guilty on all but one charge and was sentenced to 40 years' imprisonment. Lass contended that the second set of charges were the product of an unconstitutional vindictive prosecution. He argued that the prosecutors leveled the expanded charges against him in retaliation for his seeking and receiving a mistrial in the misdemeanor case.Lass sought post-conviction relief in Wisconsin state court and later in federal court under 28 U.S.C. § 2254. The Wisconsin Court of Appeals affirmed the lower court's decision, determining that Lass failed to allege facts that would establish a presumption of vindictiveness or actual vindictiveness. The Wisconsin Supreme Court declined review.Lass's application for relief in federal district court under 28 U.S.C. § 2254 also fell short. The district court found that the Wisconsin Court of Appeals did not apply a presumption of vindictiveness and that its declining to do so was neither contrary to nor reflected an unreasonable application of clearly established U.S. Supreme Court precedent. The district court also declined to consider Lass's two remaining claims, finding both procedurally defaulted.In the United States Court of Appeals For the Seventh Circuit, Lass's contentions were seen as procedurally defaulted. The court affirmed the district court's disposition of these two claims. The court also found no basis for federal habeas relief under § 2254(d) on Lass's vindictive prosecution claim. The court concluded that no aspect of the Wisconsin Court of Appeals' rationale was contrary to or reflected an unreasonable application of clearly established U.S. Supreme Court precedent. View "Lass v. Wells" on Justia Law

AsymaDesign, LLC, a company that operated a virtual-reality ride in a shopping mall, entered into a lease with CBL & Associates Management, Inc. Following complaints about noise from the ride, CBL relocated it within the mall, as permitted by the lease. The new location proved unprofitable, leading AsymaDesign to stop paying rent, resulting in eviction and subsequent dissolution under the Illinois Limited Liability Company Act. Nearly four years later, George Asimah, the former owner of the LLC, filed a lawsuit against CBL under 42 U.S.C. §1981 and state contract law, alleging racial discrimination when CBL did not allow the LLC extra time to pay its rent.The district court dismissed the suit on the grounds that Asimah was not the real party in interest, as the lease was held by AsymaDesign, not Asimah personally. An amended complaint added AsymaDesign as an additional plaintiff, but this was also dismissed as untimely. The court ruled that although Illinois law allows a dissolved LLC a "reasonable time" to wind up its business, AsymaDesign had not begun to litigate until almost five years after its dissolution, exceeding the benchmark allowed by Illinois law.In the United States Court of Appeals for the Seventh Circuit, AsymaDesign filed a notice of appeal. However, the notice was signed only by George Asimah, who is not a lawyer and therefore cannot represent AsymaDesign or anyone other than himself. The court ruled that only a member of the court's bar (or a lawyer admitted pro hac vice) can represent another person or entity in litigation. AsymaDesign's sole argument was that anyone may represent an Illinois corporation in federal court, which the court dismissed as misguided. Consequently, the appeal was dismissed. View "Asimah v. CBL & Associates Management, Inc." on Justia Law

The case revolves around an incident where Charles Brumitt, who was intoxicated and lying on a utility box, struck Evansville Police Department Sergeant Sam Smith. In response, Smith punched Brumitt four times in the face, knocking him unconscious. Brumitt sued Smith under 42 U.S.C. § 1983, alleging that Smith used excessive force in violation of his Fourth Amendment rights. Smith sought summary judgment, arguing that his use of force was objectively reasonable and that he was entitled to qualified immunity.The district court denied Smith's motion for summary judgment. It concluded that there were factual disputes that prevented it from determining whether the force used by Smith was reasonable and whether Smith was entitled to qualified immunity. The court stated that the right Brumitt asserted—“to be free from force once subdued”—was clearly established. Smith appealed this decision.The United States Court of Appeals for the Seventh Circuit reversed the district court's decision. The appellate court concluded that Brumitt had not met his burden of showing that Smith violated a clearly established right. The court found that no case clearly established that a reasonable officer must reassess his use of force within less than four seconds. Therefore, Smith was entitled to qualified immunity. The court remanded the case with instructions to enter judgment in Smith's favor on the Fourth Amendment claim. View "Brumitt v. Smith" on Justia Law

The case revolves around John Sabo, who was sentenced to a probation term that exceeded the maximum limit set by Wisconsin law. After his probation should have ended, he was imprisoned for violating its conditions. Sabo sued two groups of defendants under 42 U.S.C. § 1983: Sheri Hicks and Debra Haley, officials from the Wisconsin Department of Corrections who failed to correct his unlawful probation term, and Megan Erickson and Barb Hanson, the probation officers who enforced it. Sabo alleged that all four defendants violated his right of due process and showed deliberate indifference to his unjustified imprisonment.The district court dismissed all claims against Hicks and Haley, and most against Erickson and Hanson, before entering summary judgment for Erickson and Hanson on the deliberate indifference and unreasonable seizure claims. Sabo appealed the dismissal of his claims against Hicks and Haley.The United States Court of Appeals for the Seventh Circuit found that Sabo's complaint stated claims of deliberate indifference against Hicks and Haley. The court held that assuming all facts and inferences in Sabo’s favor, the record did not compel a finding of qualified immunity for Hicks and Haley. Therefore, the court vacated the district court’s dismissal of those claims. However, the court affirmed the district court's decision in all other respects, including the summary judgment for Erickson and Hanson on the deliberate indifference and unreasonable seizure claims. View "Sabo v. Erickson" on Justia Law

Monica Rongere, a former Diversity Procurement Officer for the City of Rockford, Illinois, sued the city after her employment was terminated. Rongere claimed that she was overworked and underpaid compared to her male colleagues, and that her termination was due to her complaints about this disparity. She brought claims under the Equal Pay Act, Title VII of the Civil Rights Act of 1964, the Illinois Human Rights Act, the Illinois Whistleblower Act, and Illinois common law, alleging equal pay, sex discrimination, hostile work environment, and retaliation.The district court ruled in favor of the City on the Equal Pay Act, Title VII, and Illinois Human Rights Act claims, and relinquished jurisdiction over the remaining state-law claims. Rongere appealed this decision.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court found that Rongere failed to identify adequate comparators for her equal pay and sex discrimination claims, did not show that she engaged in protected activity based on an objectively reasonable belief for her retaliation claim, did not present sufficient evidence of a hostile work environment, and did not explain how the district court abused its discretion in relinquishing jurisdiction over the remaining claims. The court also found that Rongere did not hold an objectively reasonable belief that the City paid male employees more than female employees for the same work, which was necessary for her retaliation claims. View "Rongere v. City of Rockford" on Justia Law

The Greenwald Family Limited Partnership, a landowner in the Village of Mukwonago, Wisconsin, had a longstanding positive relationship with the Village, collaborating on several development projects. However, this relationship soured after a failed land deal in 2014 and several other conflicts. The Partnership sued the Village, alleging that it had been irrationally singled out for unfavorable treatment, violating its Fourteenth Amendment rights. The Partnership pointed to several adverse municipal decisions, focusing primarily on the failed land deal and a new road that was rerouted from the Partnership’s property.The case was initially filed in state court but was later removed to federal court. The district court concluded that the Village had a rational basis for its actions regarding the failed land deal, the new road, and other decisions affecting the Partnership’s properties. The court entered summary judgment in favor of the Village and relinquished jurisdiction over the state-law claims.The case was then brought before the United States Court of Appeals for the Seventh Circuit. The court affirmed the district court's decision, stating that the Partnership had failed to show that the Village’s actions lacked any conceivable rational basis. The court found that the Village’s decisions were rationally related to its legitimate interests in promoting its land-use objectives and protecting public funds. The court concluded that the Partnership was a disappointed landowner, but not a victim of unconstitutional discrimination. View "Greenwald Family Limited Partnership v. Village of Mukwonago" on Justia Law