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

Miko Thomas, an employee of JBS Green Bay, filed a lawsuit under Title VII of the Civil Rights Act of 1964, alleging racial discrimination. He claimed that his employer delayed his training for three years, denied his vacation requests while approving similar requests for others, and transferred him to a different shift despite knowing it caused childcare issues. Thomas argued these actions were discriminatory based on his color.The United States District Court for the Eastern District of Wisconsin dismissed Thomas's complaint under Rule 12(b)(6) for failure to state a claim. The court found that the alleged events were not serious enough to be actionable under Title VII and that Thomas's complaint did not include all necessary elements to prove his case. After Thomas amended his complaint, the district court dismissed the suit outright, maintaining that the complaint lacked sufficient detail and did not meet the required legal standards.The United States Court of Appeals for the Seventh Circuit reviewed the case and found the district court's dismissal to be mistaken. The appellate court held that the district court incorrectly required the complaint to allege significant or material injury, which is not necessary under Title VII as clarified by the Supreme Court in Muldrow v. St. Louis. The appellate court also noted that the district court improperly demanded that the complaint include every element of proof needed for summary judgment, contrary to the notice pleading standard established by the Federal Rules of Civil Procedure and reaffirmed in Swierkiewicz v. Sorema N.A.The Seventh Circuit reversed the district court's dismissal and remanded the case for further proceedings, allowing it to move to the summary-judgment stage and potentially to trial. View "Thomas v. JBS Green Bay, Inc." on Justia Law

A group of current and former employees of Professional Transportation, Inc. filed a collective action under the Fair Labor Standards Act (FLSA) in 2014, alleging overtime and minimum-wage violations. The district court conditionally certified the collective action, and approximately 3,500 workers opted in. However, the court later decertified the collective action, deeming it overbroad, and the suit was abandoned without an appeal. Subsequently, a second collective action was filed in a different district court on behalf of over 1,400 workers, including a new claim regarding the company's commute-time adjustment formula. This case was transferred to the Southern District of Indiana, which conditionally certified a collective action on the commute-time claim but later decertified it due to the formula's inconsistent application across locations.The Southern District of Indiana severed the claims, leaving Joseph Miller as the sole plaintiff, and determined that the statute of limitations barred Miller's claim. The plaintiffs' lawyers filed a notice of appeal. However, the main issue on appeal was the lack of an appellant, as the named plaintiffs did not file written consents to join the suit as required by 29 U.S.C. §216(b). The court found that the consents from the earlier suit could not be recycled for the new case, and the forms authorizing counsel to represent the plaintiffs were not sufficient consents to join the lawsuit.The United States Court of Appeals for the Seventh Circuit dismissed the appeal due to lack of jurisdiction, as the plaintiffs' lawyers prosecuted the appeal on behalf of individuals who were not parties to the case. The court emphasized that without proper written consents, the named plaintiffs were not parties and could not appeal. The court also noted that the district court's ruling on the statute of limitations for Miller's claim was not adequately contested on appeal. View "Ghafoor v. Professional Transportation, Inc." on Justia Law

Professional Labor Group, LLC (PLG) is an Indiana-based staffing firm that employs skilled tradesmen and assigns them to remote job sites for temporary work. PLG provides per diems and mileage reimbursements but does not compensate employees for travel time to and from these assignments during normal working hours. James Walters, a former PLG employee, filed a lawsuit claiming that this travel time should be compensable under the Fair Labor Standards Act (FLSA).The United States District Court for the Southern District of Indiana denied PLG's motion for summary judgment and granted Walters' motion for summary judgment on the issue of liability. The district court concluded that federal law requires PLG to treat employee travel to overnight work assignments as compensable worktime when it occurs during normal work hours. The parties then stipulated to damages, and PLG reserved the right to appeal the summary judgment order.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court held that PLG violated the FLSA by not compensating employees for travel time to overnight assignments during normal working hours. The court clarified that 29 C.F.R. § 785.39 requires compensation for overnight travel that cuts across an employee's workday, including travel during normal working hours on nonworking days. The court rejected PLG's arguments that the travel was normal commuting and that the Portal-to-Portal Act applied, emphasizing that the regulation's substitution language is a rationale, not a prerequisite for compensation. View "Walters v. Professional Labor Group, LLC" on Justia Law

In January 2015, Sarah Schoper, a tenure-track assistant professor at Western Illinois University, suffered a traumatic brain injury resulting in high-functioning mild aphasia and other physical disabilities. Despite her condition, she returned to teaching in May 2015, with accommodations from the University. Schoper applied for tenure in 2017 but was denied based on her teaching evaluations, which had declined post-injury. She then filed a lawsuit alleging disability discrimination and failure to accommodate under the Americans with Disabilities Act.The United States District Court for the Central District of Illinois granted summary judgment in favor of the University. The court found that Schoper could not prove that her disability was the but-for cause of her negative tenure recommendation. Additionally, the court ruled that Schoper failed to show how her requested accommodation—additional time to meet tenure criteria—would enable her to perform the essential functions of her job.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that Schoper was not a qualified individual under the ADA because her teaching evaluations did not meet the University's tenure requirements. The court also found that her request for more time to achieve tenure was not a reasonable accommodation, as it essentially sought a second chance rather than a modification to enable her to perform her job. Furthermore, the court concluded that no reasonable jury could find that Schoper's disability was the but-for cause of the University's decision to deny her tenure, given the multiple layers of review and the lack of evidence showing discriminatory intent by the reviewers. View "Schoper v. Board of Trustees of Western Illinois University" on Justia Law

Santanu Das, a sales associate at Tata Consultancy Services, participated in a compensation incentive plan that promised a bonus exceeding $400,000 for achieving certain sales targets. Das met the target but was paid less than $100,000. He sued Tata under Illinois law, which requires employers to pay all agreed-upon compensation. Tata argued that disclaimers in the incentive plan negated any agreement to pay the bonus. The district court dismissed Das’s complaint, leading to this appeal.The United States District Court for the Northern District of Illinois initially dismissed Das’s claims without prejudice. Das amended his complaint, adding breach of contract and fraudulent misrepresentation claims. The district court dismissed the repleaded claims with prejudice but allowed Das to replead the new claims. Das chose to appeal only the Wage Act and fraudulent misrepresentation claims. The district court found that the disclaimers in the incentive plan prevented the formation of an agreement to pay wages and that Das’s fraudulent misrepresentation claim lacked the necessary particularity.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court found that Illinois law does not treat disclaimers as necessarily preventing the formation of mutual assent to terms. The court noted that past practices between Das and Tata could establish mutual assent. The court concluded that Das had plausibly alleged that Tata agreed to pay him the full bonus, reversing the district court’s dismissal of the Wage Act claim. However, the court affirmed the dismissal of the fraudulent misrepresentation claim, as Das failed to allege a scheme to defraud.The Seventh Circuit reversed the district court’s decision on the Wage Act claim and remanded the case for further proceedings. The dismissal of the fraudulent misrepresentation claim was affirmed. View "Das v. Tata Consultancy Services Limited" on Justia Law

Heide Montoya, a former Superintendent of On-Board Services at Amtrak, was discharged in 2020 and later rehired to a different position. Montoya filed a lawsuit alleging sex discrimination and other state-law claims. The litigation became complicated due to a dispute over arbitration. Amtrak argued that Montoya had agreed to arbitration by continuing to work after receiving an email notice. Montoya denied receiving the arbitration agreement, and the district judge could not resolve the issue due to a lack of definitive evidence.The United States District Court for the Northern District of Illinois, Eastern Division, held a status hearing where the judge indicated that the evidence was insufficient to determine if an arbitration agreement existed. The judge suggested that the parties confer and possibly provide a joint statement on how to proceed. Instead of following these steps, Amtrak filed a notice of appeal, relying on §16(a)(1) of the Federal Arbitration Act (FAA), which allows interlocutory appeals from orders bypassing arbitration.The United States Court of Appeals for the Seventh Circuit reviewed the case and found that §16 of the FAA only applies when the Act as a whole is applicable. Section 1 of the FAA excludes contracts of employment for railroad employees, among others, from its scope. Since Montoya was an Amtrak employee, the case falls outside the FAA. The court referenced similar cases and legal precedents, including Southwest Airlines Co. v. Saxon and Bissonnette v. LePage Bakeries Park St., LLC, to support its conclusion. Consequently, the Seventh Circuit dismissed Amtrak's appeal for lack of jurisdiction, noting that the district court still needs to resolve whether Montoya agreed to arbitrate disputes under state law. View "Montoya v. National Railroad Passenger Corp." on Justia Law

Three former satellite service technicians filed a class action lawsuit against their employer, DirectSat USA, LLC, alleging violations of the Illinois Minimum Wage Law (IMWL) and the Fair Labor Standards Act (FLSA). They claimed that DirectSat failed to compensate them for work-related tasks performed beyond forty hours per week. The district court initially certified a class of full-time Illinois DirectSat technicians but later vacated this certification and certified a Rule 23(c)(4) issue class to resolve fifteen questions related to DirectSat’s liability.The case was reassigned to another district judge in 2019. Before the trial, the district court decertified the Rule 23(c)(4) class. The plaintiffs settled their individual claims but reserved the right to appeal the decertification decision. The district court found that the class action was not a superior method for adjudicating the plaintiffs' controversy due to the variance in the amount of time technicians spent on work-related tasks and the individualized nature of their piece-rate compensation system.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that a party seeking certification of an issue class under Rule 23(c)(4) must show that common questions predominate in the resolution of the specific issues to be certified, not the entire cause of action. However, the court affirmed the district court’s decision to decertify the class, concluding that a class action was not a superior method for resolving the controversy due to the individualized nature of the claims and the necessity for numerous separate trials to determine liability and damages. View "Jacks v. DirectSat USA, LLC" on Justia Law

The City of Chicago’s Department of Water Management hired Tinka Vassileva as a Filtration Engineer (FE) in 2001. Vassileva, who started as an FE II, was promoted to FE III in July 2019. She applied unsuccessfully for promotions to FE V in April 2018 and FE IV in July 2019. Vassileva claimed that the City’s decisions not to interview her for these positions were based on age, gender, national origin, and retaliation for previous discrimination charges she filed with the Illinois Department of Human Rights (IDHR) and the Equal Employment Opportunity Commission (EEOC).The United States District Court for the Northern District of Illinois granted summary judgment in favor of the City on all claims. The court found that Vassileva did not provide sufficient evidence that her age, gender, national origin, or EEOC charges motivated the City’s decision not to interview her for the 2018 FE V position. Additionally, the court concluded that Vassileva had not administratively exhausted her claims related to the 2019 FE IV openings, as she failed to file an EEOC charge based on the City’s 2019 actions before filing the lawsuit.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The appellate court held that Vassileva did not present evidence suggesting that the City’s explanation for not interviewing her in 2018 was pretext for discrimination or retaliation. The court also noted that Vassileva failed to show that the decision-maker was aware of her EEOC charges. Regarding the 2019 claims, the court found that Vassileva waived her argument about administrative exhaustion by not addressing it until oral argument. Thus, the appellate court affirmed the summary judgment in favor of the City. View "Vassileva v. City of Chicago" on Justia Law

Rene Galvan, a former employee of the Indiana Department of Child Services (DCS), filed a lawsuit against the State of Indiana and his former supervisor, Joanie Crum, alleging race and sex discrimination, retaliation, and a violation of his Fourteenth Amendment right to due process. Galvan, a large Mexican male, claimed he was terminated based on his race and sex and retaliated against for his complaints of discrimination. He also alleged that Crum deprived him of his property rights without due process. The district court granted summary judgment in favor of the defendants, and Galvan appealed.The United States District Court for the Southern District of Indiana granted summary judgment to the defendants, finding no evidence that Galvan’s termination was based on race or sex discrimination. The court noted that Galvan’s performance issues, including his judgment regarding child safety and professional demeanor, were well-documented. The court also found no causal connection between Galvan’s complaints of discrimination and his termination, dismissing his retaliation claim. Additionally, the court held that Galvan received adequate due process before his termination, as he was given notice of the charges and an opportunity to respond.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court’s decision. The appellate court agreed that Galvan failed to provide sufficient evidence to support his claims of discrimination and retaliation. The court also found that the pre-termination procedures provided to Galvan met the requirements of due process, as he was given notice of the charges and an opportunity to respond. The court concluded that the district court properly granted summary judgment in favor of the defendants. View "Galvan v. State of Indiana" on Justia Law

Marlo Spaeth, an individual with Down syndrome, was employed by Wal-Mart for over 15 years. Her work schedule was changed from 12:00 p.m. to 4:00 p.m. to 1:00 p.m. to 5:30 p.m., causing her significant difficulty in adapting due to her disability. Despite requests from Spaeth and her sister to revert to her original schedule, Wal-Mart did not accommodate her, leading to her termination for attendance issues. The Equal Employment Opportunity Commission (EEOC) filed a lawsuit on Spaeth’s behalf under the Americans with Disabilities Act (ADA), alleging failure to accommodate her disability.The United States District Court for the Eastern District of Wisconsin held a jury trial, which resulted in a verdict in favor of the EEOC. The jury awarded Spaeth $150,000 in compensatory damages and $125 million in punitive damages, which the court reduced to $150,000 to comply with the ADA’s damages cap. The court also awarded backpay, prejudgment interest, and compensation for tax consequences, totaling $419,662.59. However, the district court denied the EEOC’s requests for broader injunctive relief, ordering only Spaeth’s reinstatement and communication with her guardian regarding future issues.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the jury’s findings on liability and the awards of compensatory and punitive damages. It held that Wal-Mart was aware of Spaeth’s need for a schedule accommodation due to her Down syndrome and failed to engage in the interactive process required by the ADA. The court found sufficient evidence to support the jury’s award of punitive damages, noting Wal-Mart’s reckless indifference to Spaeth’s rights. The court also upheld the compensatory damages, finding them rationally related to the evidence of Spaeth’s emotional distress and depression.However, the Seventh Circuit vacated the district court’s denial of broader injunctive relief and remanded for reconsideration. The court noted that the district court had incorrectly characterized all requested injunctive relief as “obey the law” injunctions and failed to consider the possibility of recurring discriminatory conduct. The district court was directed to reassess the need for injunctive measures to prevent future violations. View "EEOC v. Wal-Mart Stores East, L.P." on Justia Law