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

Mullins Food Products, Inc. was sued in Illinois state court for violating the Biometric Information Privacy Act (BIPA). Mullins requested its liability insurer, Citizens Insurance Company of America, to defend the suit, but Citizens declined and instead filed a federal suit seeking a declaratory judgment that it had no duty to defend or indemnify Mullins based on exclusions in the commercial liability insurance policies issued to Mullins in 2015, 2016, and 2017. While the federal suit was pending, Mullins settled the state-court action.The United States District Court for the Northern District of Illinois agreed with Citizens that the policy exclusions relieved Citizens of the duty to defend or indemnify Mullins. Specifically, the court found that the Access or Disclosure of Confidential or Personal Information exclusion and the Recording and Distribution of Material or Information in Violation of Law exclusion barred coverage for BIPA claims. The district court also ruled against Mullins on its counterclaim for breach of contract, reasoning that Citizens' timely filing of the declaratory judgment action precluded a finding of breach.The United States Court of Appeals for the Seventh Circuit reviewed the case and vacated the district court's decision. The appellate court concluded that the Access or Disclosure exclusion in the 2016 and 2017 policies barred coverage for BIPA claims, but the Statutory Violations exclusion did not. Therefore, Citizens had a duty to defend and indemnify Mullins under the 2015 policy, assuming Mullins provided timely notice of the state-court action. The appellate court remanded the case for further proceedings to determine the timeliness of Mullins' notice and to address Mullins' claim for reimbursement of defense costs. View "Citizens Insurance Company of America v Mullins Food Products, Inc." on Justia Law

An executive at a litigation funding company, Signal, resigned to start a competing business and sought legal advice from Signal’s outside counsel, Sugar Felsenthal Grais & Helsinger LLP. Signal sued the law firm and several of its attorneys, alleging legal malpractice, breach of contract, breach of fiduciary duty, and fraud. The district court dismissed some claims and granted summary judgment in favor of the defendants on the remaining claims. Signal appealed these rulings.The United States District Court for the Northern District of Illinois dismissed Signal’s breach of fiduciary duty claim and part of its fraud claim, allowing the legal malpractice, breach of contract, and fraudulent misrepresentation claims to proceed. The court also struck Signal’s request for punitive damages. During discovery, the court denied Signal’s motion to compel production of a memorandum prepared by one of the defendants. The district court later granted summary judgment in favor of the defendants on all remaining claims.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s rulings. The appellate court agreed that Signal failed to establish proximate cause and damages for its legal malpractice and breach of contract claims. The court also found that Signal waived its challenge to the summary judgment ruling on the fraudulent misrepresentation claim by not adequately addressing it on appeal. Additionally, the court upheld the district court’s decision to deny Signal’s motion to compel production of the memorandum, as Signal did not demonstrate that the document influenced the witness’s testimony. The appellate court concluded that the district court’s dismissal of the fraudulent concealment theory was harmless error and denied Signal’s motion to certify a question to the Illinois Supreme Court as moot. View "Signal Funding, LLC v Sugar Felsenthal Grais & Helsinger LLP" on Justia Law

Dr. William Partin filed a lawsuit against Baptist Healthcare System, Inc. and Dr. Daniel Eichenberger after he resigned from his position. Partin alleged that Baptist and Eichenberger retaliated against him in violation of the Emergency Medical Treatment and Active Labor Act (EMTALA) and brought claims under Indiana law for breach of contract, tortious interference with contractual relations, and defamation. The dispute arose from Partin's treatment of a suicidal patient, J.C., in Baptist's emergency department, where Partin ordered procedures against J.C.'s will, leading to complaints from hospital staff.The United States District Court for the Southern District of Indiana granted summary judgment in favor of Baptist and Eichenberger. The court found that no reasonable jury could conclude that Partin engaged in EMTALA-protected activity or that he was retaliated against for such activity. The court also determined that Partin's breach of contract claim failed because the bylaws did not create a contractual relationship between Partin and Baptist, and his resignation was not under duress. Additionally, the court found no evidence to support Partin's claims of tortious interference with contract or defamation.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 Partin did not engage in EMTALA-protected activity and that his belief in reporting a potential EMTALA violation was not objectively reasonable. The court also agreed that the bylaws did not create a contract between Partin and Baptist and that Partin's resignation was voluntary. Furthermore, the court found that Baptist's actions were justified and not malicious, and that the statements made by Eichenberger and Marksbury were protected by qualified privilege and not made in bad faith. View "Partin v Baptist Healthcare System, Inc." on Justia Law

Overhead Door Company of Indianapolis contracted with Blue Giant Equipment Corporation, a Canadian company, for the purchase of multiple dock levelers. After installation, Overhead experienced issues with the levelers and sued Blue Giant in federal court under diversity jurisdiction for breach of contract and warranty. Blue Giant moved to dismiss, citing a provision in its standard terms requiring arbitration in Ontario, Canada. The district court denied the motion, concluding that the standard terms were not incorporated into the parties' contract.The United States District Court for the Southern District of Indiana reviewed the case and denied Blue Giant's motion to dismiss. The court found that the mere reference to standard terms on a website was insufficient to incorporate those terms into the contract between Overhead and Blue Giant. Blue Giant appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case and reversed the district court's decision. The appellate court held that Blue Giant's reference to its Terms and Conditions on its website was sufficient to incorporate those terms into the contract. The court noted that the reference was conspicuous and provided Overhead with reasonable opportunity to take notice of the terms. The court concluded that the parties were obligated to resolve their dispute through arbitration in Ontario, Canada, as specified in the incorporated terms. The case was reversed and remanded for further proceedings consistent with this opinion. View "Garage Door Systems, LLC v Blue Giant Equipment Corp." on Justia Law

Charles Bich and the Bruno Bich Trust made a series of loans to WW3 LLC, owned by Curt Waldvogel, for constructing an oil-processing facility in North Dakota. Waldvogel assured the Bichs that their investment would be secured by real and personal property. However, the project failed, and the Bichs did not recover their investment, leading them to sue for breach of contract.The Eastern District of Wisconsin court found that Waldvogel's promise to secure the loans with property was a "special promise" under Wisconsin law, requiring compliance with the statute of frauds. Since there was no written agreement meeting the statute's requirements, the court ruled the loan agreement unenforceable. The court also determined that the promise would have constituted a mortgage, which also needed to satisfy the statute of frauds. The court granted summary judgment to the defendants on the breach of contract claim but allowed the unjust enrichment claim to proceed to trial. The jury awarded the Bichs $200,000 for unjust enrichment, and the court held Waldvogel and WW3 jointly and severally liable.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's decision, agreeing that the promise to secure the loans with property was a mortgage under Wisconsin law and required a written agreement to be enforceable. The court found that the emails exchanged between the parties did not constitute a final agreement and did not meet the statute of frauds' requirements. Consequently, the breach of contract claim failed, and the unjust enrichment award remained the only compensation for the Bichs. View "Bich v WW3 LLC" on Justia Law

An inmate at Green Bay Correctional Institution, who is a practicing Muslim, filed a lawsuit under the Religious Land Use and Institutionalized Persons Act (RLUIPA) against the Wisconsin Department of Corrections (WDOC). He challenged WDOC's policy prohibiting inmates from leading religious programs when no outside religious leader or volunteer is available, claiming it resulted in unnecessary cancellations of religious programs. He also alleged that the cancellation of these programs breached a prior settlement agreement with WDOC.The United States District Court for the Western District of Wisconsin granted summary judgment in favor of WDOC on the RLUIPA claim, finding that the policy was the least restrictive means of furthering the compelling interest of maintaining prison safety and security. The court also granted summary judgment in favor of the inmate on the state law breach-of-contract claim as to liability but relinquished supplemental jurisdiction over the request for injunctive relief.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's summary judgment in favor of WDOC on the RLUIPA claim, agreeing that the policy was the least restrictive means to ensure prison safety and security. However, the appellate court vacated the district court's partial judgment on the state law breach-of-contract claim. The court held that the district court abused its discretion by relinquishing jurisdiction over the remedy portion of the claim while retaining jurisdiction over liability. The case was remanded to the district court to determine whether to retain or relinquish jurisdiction over the entire state law claim. View "West v Hoy" on Justia Law

Technical Security Integration, Inc. ("Technical Security") and EPI Technologies, Inc. ("EPI") entered into a Sales Representative Agreement in which EPI agreed to sell Technical Security's products in exchange for commissions. The agreement included a clause requiring disputes to be submitted to mediation, and if mediation failed within 180 days, the prevailing party in any subsequent litigation would be entitled to attorneys' fees. A dispute arose, and EPI demanded mediation, but Technical Security did not respond promptly. EPI then sued Technical Security in state court, where it mostly lost. Technical Security sought attorneys' fees in federal court, which the district court denied, ordering each party to pay its own fees.The Circuit Court of Cook County, Illinois, granted partial summary judgment for Technical Security on the commissions dispute. EPI's remaining claims were dismissed, and the state court denied Technical Security's motion for attorneys' fees, citing a factual dispute. Technical Security then demanded mediation to resolve the fee dispute, but EPI did not respond. Technical Security subsequently sued EPI in the Northern District of Illinois, seeking fees and costs from the state court litigation. The district court granted summary judgment for EPI, concluding that Technical Security had delayed the mediation process.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that the agreement did not specify a timeline for mediation demands or responses, creating ambiguity. The court held that the district court erred in faulting Technical Security for preventing mediation without considering whether EPI's actions were reasonable. The Seventh Circuit vacated the district court's summary judgment for EPI and remanded the case for further proceedings to determine the reasonableness of each party's conduct regarding the mediation timeline. View "Technical Security Integration, Inc. v EPI Technologies, Inc." on Justia Law

Bellin Memorial Hospital hired Kinsey & Kinsey, Inc. to upgrade its computer software. Kinsey failed to implement the agreed-upon software, leading Bellin to sue Kinsey in Wisconsin state court for breach of contract and other claims. Bellin also sued Kinsey’s president and a senior product consultant. Kinsey’s insurer, Philadelphia Indemnity Insurance Company, provided a defense under a professional liability insurance policy. During the trial, Bellin and Philadelphia Indemnity entered into a partial settlement, resolving some claims and specifying the conditions under which Bellin could collect damages from Kinsey. Bellin prevailed at trial and was awarded damages.The Wisconsin circuit court ruled that the limited liability provision in the Agreement did not apply due to Kinsey’s material breach. The court granted a directed verdict on the breach of contract claim against Kinsey, leaving the question of damages to the jury. The jury awarded Bellin $1.39 million, later reduced to $750,000 plus costs. The jury found Kinsey and its president not liable for intentional misrepresentation and misleading representation.Philadelphia Indemnity filed a declaratory judgment action in the United States District Court for the Northern District of Illinois, seeking a declaration that the state court’s judgment was covered by the insurance policy and that the $1 million settlement offset the $750,000 judgment. The district court ruled for Bellin, concluding that the state court judgment was not covered by the insurance policy.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The court held that the insurance policy covered only negligent acts, errors, or omissions, and the state court’s judgment was based on a breach of contract, not negligence. Therefore, the $1 million set-off provision did not apply, and Bellin could recover the full amount of the judgment. View "Philadelphia Indemnity Insurance Co. v Kinsey & Kinsey, Inc." on Justia Law

Shawn Montgomery was severely injured when his truck was hit by a tractor-trailer driven by Yosniel Varela-Mojena, who was employed by motor carrier Caribe Transport II, LLC. The shipment was coordinated by C.H. Robinson Worldwide, Inc., a freight broker. Montgomery sued Varela-Mojena, Caribe, and Robinson, alleging that Robinson negligently hired Varela-Mojena and Caribe and was vicariously liable for their actions.The United States District Court for the Southern District of Illinois granted partial summary judgment in favor of Robinson on the vicarious liability claim, finding that Varela-Mojena and Caribe were independent contractors, not agents of Robinson. Following the Seventh Circuit's decision in Ye v. GlobalTranz Enterprises, Inc., which held that the Federal Aviation Administration Authorization Act (FAAAA) preempts state law claims against freight brokers for negligent hiring, the district court also granted judgment for Robinson on the negligent hiring claims. Final judgment was entered in favor of Robinson to facilitate Montgomery's appeal, while his claims against Varela-Mojena and Caribe were stayed.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court affirmed the district court's decision, agreeing that Robinson did not exercise the necessary control over Caribe and Varela-Mojena to establish an agency relationship, thus negating vicarious liability. The court also declined to overrule its precedent in Ye, maintaining that the FAAAA preempts state law negligent hiring claims against freight brokers. Consequently, the court affirmed the district court's judgment in favor of Robinson. View "Montgomery v. C.H. Robinson Company" on Justia Law

In 2005, Full Circle Villagebrook GP, LLC formed a partnership with Protech 2004-D, LLC and AMTAX Holdings 436, LLC to develop and operate an affordable housing project in Illinois. Full Circle, as the General Partner, held a minor ownership stake but had an option to buy out the Limited Partners after 15 years, based on the property's fair market value. The partnership agreement specified that the appraiser for this valuation must be selected from the approved lists of LaSalle Bank or Deutsche Bank Berkshire Mortgage (DBBM). When Full Circle attempted to exercise this option in 2020, it selected an appraiser from the approved lists of the successor banks to LaSalle and DBBM, as the original banks no longer existed.The United States District Court for the Northern District of Illinois granted summary judgment in favor of the Limited Partners and Alden Torch Financial, LLC. The court held that Full Circle did not comply with the partnership agreement's terms, as it did not select an appraiser from the lists of the named banks, nor did it seek the Investor Limited Partner's approval for an alternative appraiser. Consequently, the court denied Full Circle's claims for breach of contract and tortious interference.The United States Court of Appeals for the Seventh Circuit affirmed the district court's judgment. The appellate court agreed that the contract's language was unambiguous and required strict compliance with the specified method for selecting an appraiser. Since Full Circle did not adhere to these terms, it failed to validly exercise its option, and no binding contract was formed. Therefore, the Limited Partners were not in breach, and Full Circle's claims were properly dismissed. View "Full Circle Villagebrook GP, LLC v. Protech 2004-D, LLC" on Justia Law