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

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

The case involves Quintin Scott, a former pretrial detainee at the Cook County Jail, who filed a class action lawsuit against Cook County and its sheriff. Scott alleged that the county provided him and other pretrial detainees with inadequate dental care, violating the Fourteenth Amendment. The district court refused to certify the class, and Scott settled his individual claim but reserved his right to appeal the class ruling and to seek an incentive award for his role as the named plaintiff.The County argued that Scott lacked standing to pursue the class aspects of the case, contending that he no longer had a live interest in the litigation and that courts were forbidden from granting incentive awards. The United States Court of Appeals for the Seventh Circuit disagreed, finding that Scott had standing and that incentive awards were permissible. The court also concluded that the district court had abused its discretion in denying class certification, as it had misapplied a previous decision and used too strict a standard.The Court of Appeals vacated the district court's order and remanded the case for further proceedings, noting that the district court was free to revise the class definition as needed to address any overbreadth issues. The court also noted that the district court had not addressed whether the proposed class met the requirements of numerosity and adequacy of representation, which must be satisfied before the class can be certified. View "Scott v. Dart" on Justia Law

The case involves three plaintiffs, Xingjian Sun, Xing Zhao, and Ao Wang, who sued their professor, Gary Gang Xu, for various allegations. Sun and Zhao, former students at the University of Illinois at Urbana-Champaign, accused Xu of sexual and emotional abuse. Wang, a professor at Wesleyan University, posted online that Xu had a history of sexually assaulting students. In response, Xu allegedly posted negative comments about Wang and sent a letter to his employer. Xu counterclaimed, asserting a defamation claim against Sun and claims for intentional infliction of emotional distress against all three plaintiffs.The case was tried in the United States District Court for the Central District of Illinois, where a jury found in favor of Xu on all issues and awarded him damages against Sun and Wang. The plaintiffs appealed, arguing that the district court erred in denying their motion for judgment as a matter of law regarding Xu’s intentional infliction of emotional distress counterclaims. They also contended that the district court erred in denying their motion for a new trial, based on the court’s decision to admit evidence that Sun had a relationship with another professor.The United States Court of Appeals for the Seventh Circuit reversed the judgment in favor of Xu on his counterclaim against Wang, finding that no reasonable jury could find Wang's conduct extreme and outrageous under Illinois law. However, the court affirmed the judgment in favor of Xu on his counterclaim against Sun, concluding that a reasonable jury could find that Sun's conduct met the requirements for intentional infliction of emotional distress. The court also affirmed the district court's denial of the plaintiffs' motion for a new trial. View "Sun v. Xu" on Justia Law

The plaintiff, Richard Rodgers, a prisoner with a history of scoliosis and back pain, had steel rods implanted in his back prior to his incarceration. During his time in prison, the rods broke, but this went undetected for over a year due to two radiologists misreading his x-rays. The prison's primary care physician, Dr. William Rankin, discovered the broken rods and arranged for corrective surgery. Rodgers sued the radiologists and Dr. Rankin, alleging violation of his Eighth Amendment rights.The district court dismissed Rodgers' claims against the radiologists, finding that he did not state a viable constitutional claim against them. The court allowed Rodgers to proceed against Dr. Rankin but eventually granted summary judgment in his favor. The court found that Rodgers had not provided evidence that would allow a reasonable jury to find that Dr. Rankin had violated the Eighth Amendment by acting with deliberate indifference toward Rodgers' serious medical condition.The United States Court of Appeals for the Seventh Circuit affirmed the district court's judgment. The court agreed that Rodgers' allegations against the radiologists amounted to no more than negligence, which is insufficient to state a viable Eighth Amendment claim. Regarding Dr. Rankin, the court found that the evidence would not support a reasonable finding that he acted with deliberate indifference to Rodgers' serious medical condition. The court noted that Dr. Rankin was the one who discovered the radiologists' errors and arranged for Rodgers' corrective surgery. View "Rodgers v. Rankin" on Justia Law

The case involves a class action lawsuit brought against the Illinois Department of Corrections (IDOC) by four parents who were convicted of sex offenses and were on mandatory supervised release (MSR). The plaintiffs challenged an IDOC policy that restricts contact between a parent convicted of a sex offense and their minor child while the parent is on MSR. The plaintiffs argued that this policy violates their Fourteenth Amendment rights to procedural and substantive due process.The district court upheld the policy, with two exceptions. It ruled that the policy's ban on written communications was unconstitutional and that IDOC must allow a parent to submit a written communication addressed to their child for review and decision within seven calendar days. The plaintiffs appealed, challenging the policy's restrictions on phone and in-person contact.The United States Court of Appeals for the Seventh Circuit affirmed in part and reversed in part. The court agreed with the district court that the policy does not violate procedural due process. However, it held that the policy's ban on phone contact violates substantive due process. The court found that call monitoring is a ready alternative to the phone-contact ban that accommodates the plaintiffs’ right to enjoy the companionship of their children at a de minimis cost to IDOC’s penological interests. View "Montoya v. Jeffreys" on Justia Law

The case involves Songie Adebiyi, a former Vice President of Student Services at South Suburban College in Illinois, who was terminated in 2019 due to alleged performance issues. Adebiyi claimed that her termination was in retaliation for filing a charge with the United States Equal Employment Opportunity Commission and the Illinois Department of Human Rights. She sued the college and its president, alleging racial discrimination and retaliation under 42 U.S.C. § 1981 and Title VII of the Civil Rights Act of 1964, as well as breach of contract.The United States District Court for the Northern District of Illinois granted summary judgment to the college and its president, ruling that Adebiyi failed to show a causal link between her charge of discrimination and her termination. The court found that the evidence did not support Adebiyi’s retaliation claim. Adebiyi appealed the decision, arguing that the district court erred in dismissing her Title VII retaliation claim and abused its discretion when it denied her motion to amend the complaint and seek more discovery.The United States Court of Appeals for the Seventh Circuit affirmed the judgment of the district court. The appellate court agreed with the lower court's finding that Adebiyi failed to demonstrate a causal link between her protected activity and the adverse employment action. The court found no evidence of pretext in the college's reasons for termination or suspicious timing between Adebiyi's filing of her EEOC and IDHR charge and her termination. The court also found no abuse of discretion in the district court's denial of Adebiyi's motion to file an amended complaint and take additional discovery. View "Adebiyi v. South Suburban College" on Justia Law

On July 4, 2021, Gavin Wallmow was arrested for violating his probation and was taken to Oneida County jail. During his booking, Wallmow denied any suicidal tendencies or mental health issues. Two days later, Wallmow's probation officer visited him and noticed a change in his behavior, including him hitting himself and expressing "demonic" thoughts. The officer reported this to a corrections officer at the jail, who then informed her superior. Despite these reports, Wallmow was observed behaving normally during routine checks. On July 8, Wallmow was found unresponsive in his cell, having committed suicide. His estate brought a series of constitutional claims under 42 U.S.C. § 1983, alleging that the jailers failed to protect Wallmow from himself.The United States District Court for the Western District of Wisconsin granted summary judgment to the defendants, concluding that the record did not support an inference that any defendant knew Wallmow faced a serious risk of harm. The court also found no reason to think the County's policies were inadequate, given the absence of any pattern of suicides to put it on notice.Upon appeal, the United States Court of Appeals for the Seventh Circuit affirmed the lower court's decision. The appellate court found that the jail's employees had taken reasonable precautions, including checking on Wallmow at least 37 times per day. The court also noted that Wallmow had thrice disavowed any risk of suicide, and nothing indicated otherwise after his talk with his probation officer. The court concluded that the jail's actions complied with the Constitution's requirements. View "Estate of Wallmow v. Oneida County, Wisconsin" on Justia Law

The case involves Circle City Broadcasting I, LLC, a local television broadcasting network operating in Indianapolis, which owns two local television stations—WISH-TV and WNDY. The company is majority-owned by DuJuan McCoy, a Black man. The dispute arose when DISH and DirecTV Network declined to pay broadcast fees to Circle City for rights to carry the company’s two Indianapolis-based television stations. Circle City alleged that the decisions reflected discrimination against its majority owner, DuJuan McCoy, and thus discrimination against the company itself.Previously, the United States District Court for the Southern District of Indiana entered summary judgment for DISH and DirecTV, concluding that Circle City failed to identify evidence permitting a jury to find that the decisions not to pay the broadcast fees reflected anything other than lawful business choices responsive to dynamics of the television broadcast market.The United States Court of Appeals For the Seventh Circuit affirmed the lower court's decision. The court found that Circle City failed to produce evidence that would allow a jury to find that DISH or DirecTV's conduct during the contractual negotiations reflected racial discrimination. The court concluded that DISH and DirecTV declined to pay fees for rights to broadcast WISH and WNDY because Circle City—unlike Nexstar—as the new owner of both stations lacked the market power to demand the fees. The court also found that Circle City fell short of demonstrating any pretext in DISH and DirecTV’s explanations for choosing not to pay retransmission fees. View "Circle City Broadcasting I, LLC v. DISH Network L.L.C." on Justia Law