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

Carl McDaniel, a Wisconsin prisoner with multiple serious medical conditions, sued the Wisconsin Department of Corrections under the ADA and the Rehabilitation Act, claiming the Department violated his rights by denying him a cell in a no-stairs unit, a single-occupancy cell, and a bed without a top bunk. He also brought an Eighth Amendment claim against Dr. Salam Syed, alleging deliberate indifference to his medical needs. The district court granted summary judgment for the Department on all claims and for Dr. Syed on the Eighth Amendment claim. McDaniel appealed.The United States District Court for the Eastern District of Wisconsin initially handled the case. McDaniel, representing himself, submitted evidence that he missed approximately 600 meals in one year due to the pain and difficulty of navigating stairs to access meals and medications. The district court, however, largely discounted McDaniel’s factual statements and granted summary judgment for the defendants, concluding that McDaniel’s cell assignment was reasonable and that his medical treatment did not violate the Eighth Amendment.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the summary judgment for the Department on the claims for a single-occupancy cell and no top bunk, as well as the Eighth Amendment claim against Dr. Syed. However, it reversed the summary judgment on the refusal to assign McDaniel to a no-stairs unit. The court found that McDaniel presented sufficient evidence that the denial of a no-stairs unit effectively denied him access to meals and medications, which could be seen as an intentional violation of the ADA and the Rehabilitation Act. The court also held that McDaniel’s ADA and Rehabilitation Act claims for compensatory damages survived his release from prison and his death.The Seventh Circuit concluded that a reasonable jury could find that the denial of a no-stairs unit amounted to an intentional violation of McDaniel’s rights under the ADA and the Rehabilitation Act, and that the Department was not entitled to sovereign immunity. The case was remanded for further proceedings consistent with this opinion. View "McDaniel v. Syed" on Justia Law

Angela Midthun-Hensen and Tony Hensen sought insurance coverage for therapies for their daughter K.H.'s autism from Group Health Cooperative between 2017 and 2019. The insurer denied coverage, citing a lack of evidence supporting the effectiveness of speech therapy for a child K.H.'s age and sensory-integration therapy for autism at any age. The family's employer-sponsored plan only covered "evidence-based" treatments. After several medical reviews and appeals upheld the insurer's decision, the parents sued, alleging violations of the Employee Retirement Income Security Act (ERISA) and state law regarding autism coverage.The United States District Court for the Western District of Wisconsin ruled in favor of the insurer, finding no violations of state law or ERISA. The plaintiffs then focused on their claim that the insurer's actions violated the Mental Health Parity and Addiction Equity Act (MHPAEA), which mandates equal treatment limitations for mental and physical health benefits. They argued that the insurer applied the "evidence-based" requirement more stringently to autism therapies than to chiropractic care, which they claimed lacked scientific support.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court found that the insurer's reliance on medical literature, which varied in its recommendations based on patient age, was permissible under the Parity Act. The court also noted that the plaintiffs failed to demonstrate that the insurer's treatment limitations for mental health benefits were more restrictive than those applied to "substantially all" medical and surgical benefits, as required by the statute. The court concluded that the plaintiffs' focus on a single medical benefit was insufficient to prove a violation of the Parity Act. View "Midthun-Hensen v. Group Health Cooperative of South Central, Inc.," on Justia Law

Pearl Ray and Andrew Ray, Sr. sued medical providers in Illinois state court for medical malpractice, which allegedly injured Pearl and caused Andrew to suffer a loss of consortium. They settled with all but one defendant. Pearl was enrolled in a federal health benefits plan, and Blue Cross and Blue Shield Association (BCBSA) was the plan’s carrier. Under the plan, BCBSA sought reimbursement from the settlement for benefits paid to Pearl. The plaintiffs filed a motion to reduce BCBSA’s reimbursement by their attorney’s fees and costs under Illinois’s common fund doctrine.The case was removed to federal court by BCBSA, arguing federal question jurisdiction and federal officer removal. The United States District Court for the Northern District of Illinois initially denied the remand motion but later reconsidered and remanded the entire case, concluding it lacked federal question jurisdiction. BCBSA appealed, asserting federal question jurisdiction and federal officer removal.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision de novo. The court held that federal question jurisdiction was not present, as federal common law did not govern the reimbursement dispute, following the precedent set by Empire Healthchoice Assurance, Inc. v. McVeigh and Blue Cross Blue Shield of Illinois v. Cruz. However, the court found that BCBSA met the requirements for federal officer removal under 28 U.S.C. § 1442, as it was acting under a federal agency (OPM) and had a colorable federal defense.The Seventh Circuit affirmed the district court’s decision in part, reversed in part, and remanded, instructing the district court to exercise jurisdiction over the motion for adjudication while remanding the rest of the case to state court. View "Ray v. Tabriz" on Justia Law

Christopher Truett operated a methamphetamine distribution network while incarcerated in the Marion County Jail. He coordinated drug purchases and sales through phone calls, directing his girlfriend to handle the transactions and collect proceeds. Truett and his co-conspirators faced various drug and firearm charges, but he was specifically charged with conspiracy to possess with intent to distribute methamphetamine. He pleaded guilty and disclosed his mental, cognitive, and memory impairments during the change-of-plea hearing.The United States District Court for the Southern District of Indiana did not hold a competency hearing despite Truett's impairments and behavior during the plea hearing. His counsel assured the court of his competence, and Truett actively participated in the proceedings. At sentencing, additional evidence of his impairments was presented, but the court again did not order a competency hearing. The court adopted the Presentence Investigation Report's findings, attributing the entire drug quantity to Truett and sentencing him to 240 months of imprisonment, five years of supervised release, and a $250 fine. The written judgment included a condition for fine payment not orally pronounced at sentencing.The United States Court of Appeals for the Seventh Circuit reviewed the case. It held that the district court did not abuse its discretion by not holding a competency hearing, as Truett's behavior and counsel's assurances indicated his understanding of the proceedings. The court also found no error in attributing the entire drug quantity to Truett, as he was personally involved in all transactions. Finally, the appellate court affirmed the inclusion of the fine payment condition in the written judgment, deeming it a mandatory condition of supervised release. The court affirmed the district court's decisions. View "USA v. Truett" on Justia Law

Three sets of parents refused to allow their newborns to receive Vitamin K shots at private hospitals in Illinois due to concerns about risks and religious reasons. Hospital staff reported the refusals to the Illinois Department of Children and Family Services (DCFS), which investigated the parents for medical neglect. In one case, hospital staff took temporary protective custody of the child. The parents sued under 42 U.S.C. § 1983, alleging violations of their Fourth and Fourteenth Amendment rights by the hospitals and medical professionals.The United States District Court for the Northern District of Illinois dismissed the cases, ruling that the private entities were not engaged in state action and thus not liable under § 1983. The parents appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the private hospitals and their staff did not act under color of state law. The court found no evidence of a conspiracy or joint action between the hospitals and DCFS to infringe on the parents' constitutional rights. The court also determined that the hospitals were not performing a public function traditionally reserved to the state, as the mere threat of taking protective custody did not constitute state action. Additionally, the court found no symbiotic relationship or entwinement between the hospitals and the state to the point of largely overlapping identity.The Seventh Circuit affirmed the district court's dismissal of the parents' claims, concluding that without state action, there could be no § 1983 liability. View "Bougher v. Silver Cross Hospital and Medical Centers" on Justia Law

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

A nurse practitioner, Lisa Hofschulz, and her ex-husband, Robert Hofschulz, were convicted of conspiracy and multiple counts of distributing drugs in an unauthorized manner, including one count resulting in a patient's death. The charges stemmed from their operation of a "pain clinic" that functioned as a front for an opioid mill, dispensing opioid prescriptions for cash-only payments. Robert Hofschulz was also convicted for his role in assisting Lisa Hofschulz in running the opioid mill.The Hofschulzes were initially tried in the United States District Court for the Eastern District of Wisconsin. They were found guilty on all counts, with Lisa Hofschulz receiving a minimum 20-year prison term for the count of unlawful distribution resulting in death, and Robert Hofschulz receiving concurrent terms of 36 months in prison on each of his five convictions. The Hofschulzes appealed their convictions on three grounds: they claimed the jury instructions were inconsistent with a Supreme Court decision, that the judge wrongly permitted the government’s medical expert to testify about the standard of care, and that the evidence was insufficient to support their convictions.The case was then reviewed by the United States Court of Appeals for the Seventh Circuit. The court found no instructional error, stating that the district judge had correctly instructed the jury that the government must prove beyond a reasonable doubt that the Hofschulzes intended to distribute controlled substances and intended to do so in an unauthorized manner. The court also found that the judge had correctly permitted the government’s medical expert to testify about the standard of care in the usual course of professional pain management. Lastly, the court dismissed the Hofschulzes' challenge to the sufficiency of the evidence, deeming it frivolous. The court affirmed the convictions of the Hofschulzes. View "United States v. Hofschulz" on Justia Law

The case involves Roland Black, who was convicted of attempting to possess with intent to distribute a controlled substance, specifically furanyl fentanyl. Law enforcement intercepted a package addressed to Black, believing it contained narcotics. After obtaining a warrant, they found the substance, replaced it with sham narcotics, and delivered the package to Black's residence. Black was arrested after the package was opened and he was found with luminescent powder from the sham narcotics on his hands.Prior to his trial, Black had unsuccessfully moved to dismiss the indictment and suppress all evidence derived from the seizure of the package. He argued that the officers lacked reasonable suspicion to seize the package and requested an evidentiary hearing to resolve related factual disputes. The district court denied these motions, ruling that the totality of the circumstances supported the officers' reasonable suspicion determination.In the United States Court of Appeals for the Seventh Circuit, Black appealed his conviction, raising four arguments. He contended that the officers lacked reasonable suspicion to seize the package, the jury instruction about his requisite mens rea was erroneous, the jury’s verdict was not supported by sufficient evidence, and the court erred in denying his motion to dismiss based on the court’s treatment of furanyl fentanyl as an analogue of fentanyl.The Court of Appeals affirmed the lower court's decision. It found that the officers had reasonable suspicion to seize the package, the jury instruction accurately stated the law, the jury’s verdict was supported by more than sufficient evidence, and Black's motion to dismiss argument was foreclosed by precedent. View "USA v. Black" on Justia Law

The case revolves around Morgan Morales, who appealed against an administrative law judge's (ALJ) decision that she was not disabled and hence, not entitled to Social Security disability benefits. Morales claimed to suffer from several conditions, including bipolar disorder, depression, anxiety, ADHD, and narcolepsy. After being treated at a mental health center and starting on prescription medications, Morales reported that her conditions were in remission. The ALJ, however, denied her application for benefits, finding that her mental impairments were mild and did not limit her ability to perform basic work activities, including her past job as a material handler.Morales challenged the ALJ's decision in the United States District Court for the Southern District of Indiana, Indianapolis Division. She criticized the ALJ's decision about her functional capacity to work but failed to provide evidence compelling the conclusion that the adverse disability decision lacked substantial support in the record. The District Court upheld the ALJ's decision, stating that Morales had not carried her burden of proof and that the ALJ's decision was supported by substantial evidence.The case was then brought to the United States Court of Appeals for the Seventh Circuit. The court affirmed the lower court's decision, stating that Morales had misunderstood the burden she bore on appeal. The court noted that it was not enough to criticize the ALJ's decision; Morales needed to point to evidence compelling the conclusion that the adverse disability decision lacked substantial support in the record. The court also dismissed Morales's criticism of the District Court's decision, stating that the District Court had conducted an adequate review of the ALJ's determination and correctly applied the law. The court concluded that the ALJ's determination was reasonable and supported by substantial evidence, and therefore, affirmed the decision. View "Morales v. O'Malley" on Justia Law

The case involves Asif Sayeed and three associated healthcare companies who were found liable for violating the Anti-Kickback Statute and False Claims Act, resulting in a nearly $6 million judgment. Sayeed owned a healthcare management company, Management Principles, Inc. (MPI), which managed two smaller companies that provided home-based medical services to Medicare recipients in Illinois. Sayeed's companies received a significant amount of their business from the Healthcare Consortium of Illinois. In December 2010, Sayeed devised a scheme to bypass the Consortium’s referral process by directly soliciting its clients for additional services. MPI signed a Management Services Agreement with the Consortium, which gave MPI full access to its clients’ healthcare data. MPI used this information to identify and directly solicit Medicare-eligible seniors who might want or need additional healthcare services.The district court held a bench trial in July 2019 and found that Sayeed and his companies had not violated the Anti-Kickback Statute or False Claims Act because they had paid the Consortium with the intent to obtain information, not patient referrals. The plaintiff appealed, and the court of appeals reversed the decision, concluding that the defendants' conduct qualified as a form of indirect referral giving rise to an unlawful kickback scheme.On remand, the district court found the defendants liable under both the Anti-Kickback Statute and False Claims Act. The court imposed $5,940,972.16 in damages, which it calculated by trebling the value of the Medicare claims it deemed false and then adding a per-claim penalty of $5,500. The defendants appealed, challenging both the damages award and the underlying finding of liability. The United States Court of Appeals for the Seventh Circuit affirmed the judgment of liability but reversed in part to permit the district court to clarify which Medicare claims, all or some, resulted from the defendants’ illegal kickback scheme. View "Stop Illinois Health Care Fraud, LLC v. Sayeed" on Justia Law