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

This case was brought before the United States Court of Appeals For the Seventh Circuit by plaintiffs John Brooks and Gregory Simmons against the City of Pekin and four of its employees. Brooks, a former police lieutenant who developed sleep apnea, claimed that the City violated the Americans with Disabilities Act by failing to reasonably accommodate his condition, discriminating against him, and retaliating against him for raising complaints. Simmons, a former police officer, alleged retaliation under Title VII of the Civil Rights Act of 1964 for reporting sexually harassing comments made by his former boss. The district court had granted summary judgment in favor of the defendants.The Court of Appeals affirmed the lower court's decision. The Court found that Brooks failed to show that the City had not offered him reasonable accommodations for his sleep apnea. The Court also ruled that Brooks could not establish disparate treatment because he failed to identify similarly situated employees who received more favorable treatment. Furthermore, Brooks was unable to prove retaliation because he lacked evidence that the City's reason for disciplining him was pretextual.Regarding Simmons, the Court found that he could not establish a claim for retaliation under Title VII because the inappropriate comments made about him were not because of his sex and were not severe or pervasive enough to create an abusive working environment. Moreover, Simmons could not show that his termination was due to his complaints against his former boss. The Court also noted that the district court did not err in denying the plaintiffs' request to amend their summary judgment response. The Court declined the City's request to impose sanctions on Brooks and Simmons, reasoning that their appeal was not frivolous. View "Brooks v. City of Pekin" on Justia Law

In this case, the United States Court of Appeals for the Seventh Circuit ruled on an appeal brought by Randall Artis, a former city councilman for East Chicago, Indiana. Artis was previously convicted of misappropriating public money for personal political gain. After returning to public service as a junior clerk, he was fired by his boss, Adrian Santos. Artis alleged that Santos fired him in retaliation for exercising his First Amendment free speech rights. The case went to trial, and a jury found in favor of Santos.Artis appealed, arguing that the district court erred in admitting the testimony of an expert witness, in denying him an impartial jury, and in issuing inaccurate and confusing jury instructions and verdict forms. He also questioned the jury's verdict. The appeals court affirmed the district court's judgment, finding no error or reason for a new trial.The court held that the district court did not abuse its discretion in allowing the expert witness to testify, and it did not err in denying Artis's for-cause challenge to a prospective juror. Moreover, the court ruled that the district court did not abuse its discretion in its choice of jury instructions and verdict form. Finally, the court found no inconsistency in the jury's verdict. View "Artis v. Santos" on Justia Law

In the United States Court of Appeals for the Seventh Circuit, Parents Protecting Our Children, an association of parents, sought an injunction against the Eau Claire Area School District in Wisconsin to stop the enforcement of the District’s Administrative Guidance for Gender Identity Support. The parents argued that the policy violated the Due Process and Free Exercise Clauses of the U.S. Constitution by interfering with their right to make decisions on behalf of their children. The District Court dismissed the case due to lack of subject matter jurisdiction, stating that the parents failed to identify any instance where the policy was applied in a way that infringed on parental rights.The Court of Appeals affirmed the lower court's ruling. The court held that the parents' concerns about potential applications of the policy did not establish standing to sue unless the policy resulted in an injury or created an imminent risk of injury. The court stated that the parents had brought a pre-enforcement facial challenge against the policy without any evidence of the School District applying the policy in a manner detrimental to parental rights.The court also noted that the Administrative Guidance did not mandate exclusion of parents from discussions or decisions regarding a student’s gender expression at school. The court found that the alleged harm was dependent on a speculative "chain of possibilities," which was insufficient to establish Article III standing. Therefore, the court upheld the dismissal of the lawsuit for lack of subject matter jurisdiction. View "Parents Protecting Our Children, UA v. Eau Claire Area School District" on Justia Law

The case concerns the plaintiff, Tina Gerlach, who claimed that Indiana officials violated her right to just compensation under the Fifth Amendment's Takings Clause. Gerlach's unclaimed property had been taken into custody by the state under the Revised Indiana Unclaimed Property Act. She asserted that Indiana did not compensate her for interest accrued while the state held her property.Gerlach filed a lawsuit against several state officials, seeking declaratory and injunctive relief, as well as compensation. The defendant officials moved for judgment on the pleadings, arguing that Gerlach's claim for prospective relief was moot and her claims for retrospective relief were barred by the Eleventh Amendment. The district court granted the defendants' motion, and Gerlach appealed.The United States Court of Appeals for the Seventh Circuit affirmed the district court's dismissal. The court found Gerlach's claim for prospective relief was moot due to Indiana's new legislation requiring the payment of interest on all recovered property. The court also held that Gerlach could not obtain compensation in federal court from the Indiana officials because no exception to Eleventh Amendment sovereign immunity applied, and Indiana state courts were open to hear Gerlach's claims. Lastly, the court concluded that Gerlach's claim for compensatory relief was actually against the State of Indiana, and therefore barred by sovereign immunity and Section 1983 of the Civil Rights Act, which does not create a cause of action against a state. View "Gerlach v. Rokita" on Justia Law

The United States Court of Appeals for the Seventh Circuit reviewed a case involving David A. Schlemm, an inmate who had filed a First Amendment retaliation claim against Brendan Pizzala, Jay Van Lanen, and Michael Donovan. Schlemm's claim was based on accusations made against him for theft of sage from the chapel of the Green Bay Correctional Institution, which led to a conduct report being issued against him. The report was later dismissed after another correctional officer testified that he had given the sage to Schlemm. Schlemm then filed complaints against the defendants through the Inmate Complaint Review System (ICRS), claiming retaliation.The lower court had dismissed Schlemm's case, ruling it was time-barred due to the six-year statute of limitations. The court noted that Schlemm's lawsuit, filed in 2019, was more than six years after the 2012 search of his cell. On appeal, the defendants conceded that Schlemm had properly exhausted his administrative remedies, but argued his action was time-barred due to the six-day gap between the accrual of his claim and the filing of his administrative complaints.The Appeals Court reviewed the district court's dismissal de novo and concluded that the defendants had waived their specific statute of limitations argument regarding the six-day gap. They had raised this argument for the first time on appeal, having previously argued that Schlemm had not properly exhausted his administrative remedies. The court reversed the dismissal and remanded for further proceedings, noting that it did not need to address the question of whether the gap between claim accrual and grievance filing is included in the tolling period due to the defendants' waiver of their argument. View "Schlemm v. Pizzala" on Justia Law

The case involves Suzy Martin, the owner and president of Smart Elevators Co., a certified minority- and woman-owned elevator service and repair company. The company, which historically did most of its business with the State of Illinois and the City of Chicago, saw its customer base change after a whistleblower complaint alleged that Martin and her company engaged in a bribery and kickback scheme with a University of Illinois Chicago employee. This led to an investigation by the Office of the Executive Inspector General for the Agencies of the Illinois Governor (OEIG), which concluded that Martin, Smart Elevators, and the University employee had engaged in a kickback scheme that violated Illinois ethics law and University policy and recommended that the University sever ties with Martin and her company.As a result of the report, the State and City ceased doing business with Martin and Smart Elevators, causing the company to lose millions in preexisting and potential contracts. Martin sued several State and City entities and officials under 42 U.S.C. § 1983, bringing “stigma-plus” procedural due process claims under the Fourteenth Amendment. The district court dismissed her amended complaint with prejudice.Upon appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court concluded that Martin's occupation was operating an elevator service and repair business, not just providing those services specifically to the State or City. The court also found that despite the loss of State and City contracts, Martin had not been denied her liberty to pursue her occupation as she remained the owner and operator of Smart Elevators, which continued to operate and even managed to secure a contract with the Department of Justice in 2021. As such, the court found no violation of Martin's occupational liberty rights. View "Martin v. Haling" on Justia Law

In this case heard by the United States Court of Appeals for the Seventh Circuit, the plaintiff, Alexis Wells, sought to hold her employer, The Freeman Company, liable for sexual assault committed by a fellow employee, Timothy Vaughn. Wells asserted that the company should be held responsible under Title VII, the Indiana Wage Payment Statute, and various tort theories. The court, however, affirmed the district court's ruling that Wells was an independent contractor, not an employee, which meant that Freeman's conduct was not tortious and Vaughn's actions could not be attributed to Freeman. The court applied the Knight factors, which analyze the "economic realities" of a work relationship, to determine whether a worker is an employee for purposes of Title VII. The court concluded that most of these factors pointed towards Wells being an independent contractor. Thus, her claims under Title VII and the Indiana Wage Payment Statute failed. The court also dismissed Wells' state law claims for Intentional Infliction of Emotional Distress (IIED) and Negligent Infliction of Emotional Distress (NIED), concluding that Freeman's pre-litigation conduct was not so outrageous as to be regarded as "atrocious," and that Vaughn's conduct was outside the scope of his employment, respectively. Therefore, the court could not hold Freeman vicariously liable for Vaughn's actions. View "Wells v. Freeman Company" on Justia Law

In this case, the plaintiff, Chicago Joe's Tea Room LLC, had plans to open an adult entertainment business in a suburb of Chicago. However, the Village of Broadview denied the plaintiff's application for a special-use permit, which led to the plaintiff claiming that their constitutional rights were violated. The plaintiff sought millions of dollars in lost profits for the business that never opened. The U.S. District Court for the Northern District of Illinois excluded most of the plaintiff's evidence and theories for lost-profit damages due to substantive and procedural issues. The court then awarded the plaintiff just $15,111 in damages. The plaintiff appealed, but the United States Court of Appeals for the Seventh Circuit affirmed the decision of the lower court, finding no abuses of discretion. The appellate court stated that the plaintiff's calculations of lost profits were beyond the scope of the plaintiff's personal knowledge of a similar business and required expert-like analysis and adjustments. The court also ruled that the plaintiff failed to disclose necessary damages evidence in a timely manner, a violation of the Federal Rules of Civil Procedure. The plaintiff was also denied the opportunity to amend their complaint to challenge a state statute, as the request was made a decade after the issue became relevant. The court found that granting the amendment would have caused undue delay and prejudice to the Village. View "Chicago Joe's Tea Room, LLC v. Village of Broadview" on Justia Law

The case concerns an appeal by Brandon Cade against a ruling by the United States District Court for the Northern District of Illinois, Eastern Division, before the United States Court of Appeals For the Seventh Circuit. Cade was arrested by Chicago police officers who noticed an open bottle of alcohol in a sedan next to which Cade and another individual were standing. During a search of the car, officers found an unlicensed firearm and Cade admitted it was his. He was charged with possession of a firearm by a felon. Cade argued to suppress evidence of the gun and his incriminating statements, but the district court denied his motion. Cade pleaded guilty but reserved his right to appeal the suppression ruling. He argued that his initial encounter with the officers was an unlawful seizure and that his incriminating statements should be suppressed because the officers did not have reasonable suspicion to seize him.The Court of Appeals affirmed the lower court's ruling. The court found that the initial encounter with the officers was consensual and did not constitute a seizure. The court also ruled that even if there was an unlawful seizure, Cade's incriminating statements were sufficiently attenuated from any allegedly unlawful conduct. The presence of the open alcohol bottle provided probable cause for the search, which led to the discovery of the firearm, and Cade's admission to owning the firearm occurred after he was read his Miranda rights. The court concluded that there was no evidence of bad faith by the officers, and that an evidentiary hearing was not needed as there were no material factual disputes. View "United States v. Cade" on Justia Law

Jeffrey Bruno, a veteran firefighter with the Kankakee Fire Department, sued Mayor Chasity Wells-Armstrong, James Ellexson, the Human Resources Director for the City of Kankakee, and the City of Kankakee, alleging discrimination and retaliation under the Americans with Disabilities Act (ADA) and the Illinois Human Rights Act (IHRA). Bruno suffered a severe cardiac event in 2017 and upon his return to work was promoted to Deputy Chief. However, in 2019, he was denied a raise and presented with an employment contract that tied additional compensation to his enrollment in college courses. When Bruno requested the removal of this education condition, citing his heart condition as a barrier to attending classes, his request was denied. After signing the contract, Bruno retired and initiated legal proceedings.The United States Court of Appeals For the Seventh Circuit affirmed the district court's decision, which had granted summary judgment for the defendants. The court concluded that Bruno's request to remove the education condition was not a request for a reasonable accommodation under the ADA, as it would not impact his ability to perform his job. The court also rejected Bruno's claim of disparate treatment, as his argument of pretext was contradicted by the evidence. Bruno's ADA retaliation claim also failed because his identified protected activity was not protected under the ADA. As Bruno's IHRA and indemnification claims were dependent on his ADA claims, these too were rejected. View "Bruno v. Wells-Armstrong" on Justia Law