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

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

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