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

Clinton Mahoney, the sole member and manager of Mahoney & Associates, LLC, signed an agreement obligating the company to contribute to the Railroad Maintenance and Industrial Health and Welfare Fund, an employee benefit fund. When the Fund could not collect delinquent contributions from Mahoney & Associates, it sued Mahoney personally, citing a personal liability clause in the agreement. The district court granted summary judgment to the Fund, concluding that Mahoney was personally liable based on the clause.The United States District Court for the Central District of Illinois initially entered judgment on July 31, but it did not comply with Federal Rule of Civil Procedure 58. Mahoney filed a notice of appeal on September 26, and the district court later entered a corrected judgment on October 11. Mahoney filed a second notice of appeal the same day. The district court had awarded the Fund attorneys’ fees based on the trust agreement.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court found that there was a genuine dispute of material fact regarding Mahoney’s intent to be personally bound by the trust agreement, as he signed the memorandum in a representative capacity, which conflicted with the personal liability clause. The court concluded that this issue could not be resolved at summary judgment. The court also addressed Mahoney’s laches defense but found it waived due to his failure to address relevant complications. Consequently, the Seventh Circuit reversed the district court’s grant of summary judgment and vacated the award of attorneys’ fees, remanding the case for further proceedings. View "Railroad Maintenance and Industrial Health & Welfare Fund v. Mahoney" on Justia Law

Kara Mitchell, a laboratory technician at Exxon Mobil Corporation, was terminated in 2020 after a little over a year of employment. ExxonMobil claimed her termination was due to poor performance compared to her peers in the company's annual employee assessment process. Mitchell alleged that her termination was due to sex discrimination and sued the company under Title VII of the Civil Rights Act of 1964.The United States District Court for the Northern District of Illinois granted summary judgment in favor of ExxonMobil, concluding that Mitchell failed to provide sufficient evidence to support her claim of sex discrimination. Mitchell appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case and upheld the district court's decision. The appellate court found that Mitchell did not present enough evidence to show that she was treated less favorably than similarly situated male employees. The court noted that Mitchell's comparators, two male lab technicians, were not similarly situated because they were not part of the same assessment group. Additionally, the court found that Mitchell failed to prove that ExxonMobil's reason for her termination was pretextual.The Seventh Circuit also considered Mitchell's argument under the holistic approach articulated in Ortiz v. Werner Enterprises, Inc., but concluded that there was no evidence of a pattern or practice of sex discrimination at the Cicero plant. The court affirmed the district court's grant of summary judgment to ExxonMobil, finding that no reasonable jury could conclude that Mitchell was terminated because of her sex. View "Mitchell v Exxon Mobil Corp." on Justia Law

Lisa Johnson and Gale Miller Anderson, former Amazon warehouse employees, alleged that Amazon violated federal and Illinois wage laws by not compensating them for time spent in mandatory pre-shift COVID-19 screenings. These screenings, which included temperature checks and symptom questions, took 10-15 minutes on average and were required before employees could clock in for their shifts. Johnson and Miller Anderson argued that this time should be compensable as it was necessary for their work and primarily benefited Amazon by ensuring a safe workplace during the pandemic.The United States District Court for the Northern District of Illinois dismissed their claims under the Fair Labor Standards Act (FLSA) and the Illinois Minimum Wage Law (IMWL). The court found that the FLSA claims were barred by the Portal-to-Portal Act of 1947 (PPA), which excludes certain pre-shift activities from compensable time. The district court also concluded that the IMWL claims failed because it assumed the IMWL incorporated the PPA’s exclusions.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether the IMWL incorporates the PPA’s exclusions for compensable time. The court noted the lack of Illinois state court decisions directly addressing this issue and found the arguments from both parties plausible. To resolve this important and unsettled question of state law, the Seventh Circuit decided to certify the question to the Illinois Supreme Court, seeking a definitive answer on whether the IMWL includes the PPA’s limitations on pre-shift compensation. The court stayed further proceedings pending the Illinois Supreme Court's decision. View "Johnson v. Amazon.com Services LLC" on Justia Law

James Reilly, a deputy in the Will County Sheriff's Office, alleged that his employer and Sheriff Michael Kelley retaliated against him for criticizing Kelley during a 2018 election campaign by not promoting him to sergeant. Reilly filed his complaint over two years after his eligibility for promotion expired. The defendants moved to dismiss the complaint, arguing it was untimely. The district court agreed, granted the motion to dismiss, and entered judgment in favor of the defendants. Reilly then requested the district court to set aside its judgment and allow him to amend his complaint, but the court denied this request, applying a heightened standard and requiring extraordinary circumstances for relief.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that the district court had mistakenly applied a heightened standard to Reilly's Rule 59(e) motion instead of the liberal standard for amending pleadings. The appellate court concluded that Reilly's proposed amended complaint stated a plausible claim for relief and that he had not pled himself out of court based on the statute of limitations. The court noted that Reilly's claim could not be conclusively determined as time-barred at this stage and that the defendants could raise the statute of limitations defense later in the case on a more complete factual record.The Seventh Circuit vacated the district court's judgment and remanded the case for further proceedings, allowing Reilly to proceed with his amended complaint. View "Reilly v Will County Sheriff's Office" on Justia Law

David Bourke, a disabled employee of the U.S. Department of Veterans Affairs (VA), was granted a reserved parking space near his workplace to accommodate his disability. However, during the COVID-19 pandemic, the VA implemented new measures that required employees to enter through designated entrances for screening, which made Bourke's reserved parking spot unusable. The VA offered Bourke an alternate parking space near Building 1, which included a secluded storage area for his mobility scooter. Bourke declined this accommodation, fearing his scooter could be stolen, and sued the VA under the Rehabilitation Act of 1973.The United States District Court for the Northern District of Illinois granted summary judgment in favor of the VA. The court found that the alternate accommodation offered by the VA was reasonable and that there was no significant risk of Bourke's scooter being stolen. The court also rejected Bourke's argument that the VA could not alter his accommodation in response to changing circumstances, such as the pandemic.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court held that the VA's alternate accommodation was reasonable, as it allowed Bourke to perform his job functions while complying with COVID-19 prevention measures. The court noted that an employer is not required to provide the specific accommodation requested by an employee, but rather a reasonable one. The court also found that the VA's actions did not violate the Rehabilitation Act, as the alternate accommodation was sufficient to meet Bourke's needs during the pandemic. Consequently, the Seventh Circuit affirmed the district court's grant of summary judgment in favor of the VA. View "Bourke v. Collins" on Justia Law

Marissa Darlingh, a guidance counselor at an elementary school in the Milwaukee Public School District, attended a rally in April 2022 where she delivered a profanity-laden speech denouncing gender ideology and transgenderism. She identified herself as a school counselor and vowed that no student at her school would transition under her watch. After a video of her speech was posted on YouTube, school officials investigated and eventually fired her for violating employment policies, including using abusive language and undermining the district's mission to provide an equitable learning environment.The United States District Court for the Eastern District of Wisconsin, with a magistrate judge presiding, applied the Pickering balancing test and concluded that the school district's interests as a public employer outweighed Darlingh's speech rights. The judge denied her request for a preliminary injunction and dismissed her First Amendment claim.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the lower court's decision. The court held that while Darlingh spoke on a matter of public concern, her speech was incompatible with her role as a school counselor. The court emphasized that her extreme vulgarity and belligerent tone diminished her First Amendment interests. Additionally, her role required a high degree of public trust, and her speech conflicted with the school district's obligation to provide a supportive educational environment. The court concluded that the school district's interests outweighed Darlingh's free-speech rights, and her speech fell outside the scope of First Amendment protection in the public-employment context. View "Darlingh v Maddaleni" on Justia Law

Jeffery Johnson, a Black employee at Accenture LLP, reported racial discrimination while working on a client project. Accenture's internal investigation found his complaint was made in good faith but lacked merit. Subsequently, Johnson had difficulty securing new projects and was eventually terminated. He sued Accenture, claiming illegal retaliation for reporting discrimination.The United States District Court for the Northern District of Illinois granted summary judgment in favor of Accenture, dismissing Johnson's case. The court found that Johnson's difficulty in finding projects and his termination occurred after his complaint but concluded that the record did not support Johnson's argument that his complaint caused these issues. The court also determined that Johnson's filings violated local rules by presenting unsupported assertions and irrelevant facts, leading to the admission of many of Accenture's facts as uncontroverted.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's decision, agreeing that Johnson failed to show a causal link between his complaint and the adverse employment actions he experienced. The court noted that Johnson's evidence was insufficient to demonstrate that his complaint was the "but for" cause of his difficulties and termination. The court also found that Johnson's arguments relied on speculation rather than concrete evidence. Consequently, the court upheld the summary judgment in favor of Accenture, concluding that Johnson's retaliation claims under 42 U.S.C. § 1981 and Title VII of the Civil Rights Act of 1964 could not proceed. View "Johnson v Accenture LLP" on Justia Law

Melissa Myers, an instructional aide at an elementary school in the Sunman-Dearborn Community Schools, took FMLA leave at the end of the 2017-2018 school year due to grief from her husband's death. Upon returning for the 2018-2019 school year, she exceeded her paid leave days within the first two months. The school principal, Kelly Roth, warned her about her attendance, leading Myers to resign and subsequently sue the school district and Roth for violations of the FMLA, ADA, and the Fourteenth Amendment’s Equal Protection Clause.The United States District Court for the Southern District of Indiana granted summary judgment for the defendants. The court found that Myers was neither eligible for FMLA leave nor had a qualifying condition in the weeks before her resignation. Additionally, she did not notify the school district of her intent to take statutory leave. The court also rejected her "anticipatory retaliation" theory due to insufficient evidence. The ADA claim failed because Myers did not experience an adverse employment action, and her working conditions were not objectively intolerable to constitute constructive discharge. The equal-protection claim was dismissed for lack of proof of differential treatment.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court held that Myers did not meet the eligibility requirements for FMLA leave, lacked evidence of a serious health condition, and failed to provide sufficient notice of intent to take FMLA leave. The court also found no evidence of constructive discharge under the ADA, as her working conditions were not intolerable, and there was no imminent threat of termination. Lastly, the equal-protection claim was dismissed due to the absence of evidence showing that similarly situated employees were treated more favorably. View "Myers v. Sunman-Dearborn Community Schools" on Justia Law

Salvatore Ziccarelli, a former employee of the Cook County Sheriff's Office, used intermittent FMLA leave to manage his PTSD. In 2016, after his condition worsened, he discussed taking block leave with the FMLA coordinator, Wylola Shinnawi, who allegedly warned him against using more FMLA leave. Ziccarelli took one more day of leave and then resigned. He filed a lawsuit alleging FMLA interference and retaliation. The district court granted summary judgment for the Sheriff's Office on both claims, but the Seventh Circuit reversed and remanded the interference claim for trial.At trial, the jury awarded Ziccarelli $240,000. The Sheriff's Office moved for judgment as a matter of law under Rule 50(b), arguing that Ziccarelli could not show prejudice from the alleged interference since he took an additional day of FMLA leave after the phone call. The district court granted the motion and conditionally granted a new trial, reasoning that Ziccarelli's post-call leave negated any reasonable inference of prejudice.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court reversed the district court's entry of judgment as a matter of law, finding that the grounds for the Rule 50(b) motion were not properly presented before the verdict. However, the court affirmed the district court's alternative decision to grant a new trial, agreeing that the evidence did not support a finding of prejudice. The case was remanded for further proceedings consistent with the opinion. View "Ziccarelli v Dart" on Justia Law

Mary Ann Arnold worked for United Airlines from 1994 to 2020. She alleged age discrimination, retaliation, hostile work environment, and constructive discharge after experiencing changes in her job responsibilities and being placed on a Performance Improvement Plan (PIP). Arnold claimed these actions were due to her age and previous complaints about discrimination and harassment.The United States District Court for the Northern District of Illinois granted summary judgment in favor of United Airlines on Arnold's claims of discrimination, retaliation, and hostile work environment. The court dismissed her constructive discharge claim without prejudice, citing failure to exhaust administrative remedies.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's decision, holding that Arnold did not provide sufficient evidence to show that she suffered adverse employment actions due to age discrimination. The court also found that her retaliation claim failed because the actions taken by United were not materially adverse and were not shown to be causally connected to her complaints. Additionally, the court held that Arnold did not demonstrate a hostile work environment based on age, as the incidents she described were not severe or pervasive enough to meet the legal standard. The court also upheld the dismissal of her constructive discharge claim due to failure to exhaust administrative remedies. View "Arnold v. United Airlines, Inc." on Justia Law