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

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

Paul Carnes, an employee of Consolidated Grain and Barge Co., was diagnosed with degenerative disc disease in 2019 and received medical treatment for it. HMO Louisiana, Inc., the administrator of Consolidated Grain’s employer-sponsored health plan governed by ERISA, paid for some of Carnes’s treatments but not all. Carnes filed a workers’ compensation claim against his employer, which was settled without the employer accepting responsibility for his medical claims. With an outstanding medical balance of around $190,000, Carnes sued HMO Louisiana, alleging it violated Illinois state insurance law by not paying his medical bills and sought penalties for its alleged "vexatious and unreasonable" conduct.The United States District Court for the Central District of Illinois dismissed Carnes’s complaint on the grounds that his state law insurance claim was preempted by ERISA. The court allowed Carnes to amend his complaint to plead an ERISA claim, but instead, Carnes moved to reconsider the dismissal. The district court denied his motion and ordered the case closed. Carnes then appealed the final order.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 Carnes’s state law claim was preempted by ERISA. The court noted that ERISA’s broad preemption clause supersedes any state laws relating to employee benefit plans, and Carnes’s claim fell within this scope. The court also found that ERISA’s saving clause did not apply because the health plan in question was self-funded, making it exempt from state regulation. The court concluded that Carnes’s attempt to frame his suit as a "coordination of benefits dispute" was an impermissible effort to avoid ERISA preemption. Consequently, the court affirmed the dismissal of Carnes’s case. View "Carnes v. HMO Louisiana, Inc." on Justia Law

John Smith, an employee of Sysco Indianapolis, LLC, did not receive a monthly benefit check he expected. His labor union, Teamsters Local 135, filed a grievance on his behalf, alleging that Sysco violated their 2018 collective bargaining agreement (CBA) by not providing a $500 Supplemental Early Retirement Benefit (SERB) to certain retirees and employees. Sysco participated in the initial grievance process but refused to proceed to arbitration, arguing that the grievance was not arbitrable under the CBA. Sysco then sought a declaratory judgment from the district court, while the Union counterclaimed for a declaration that the grievance was arbitrable.The United States District Court for the Southern District of Indiana sided with Sysco, finding that the monthly benefit was governed by terms outside the CBA and that the parties' bargaining history indicated they did not intend for the benefit to be arbitrable. The court granted Sysco's motion for summary judgment and denied the Union's counterclaims.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and reached a different conclusion. The appellate court found that Sysco failed to present the "most forceful evidence" required to exclude the monthly benefit from the arbitration provision in the CBA. The court noted that the grievance fell within the scope of the arbitration clause on its face and that the CBA did not explicitly exclude the SERB from arbitration. The court also found that the parties' bargaining history did not clearly demonstrate an intent to exclude the benefit from arbitration. Consequently, the Seventh Circuit reversed the district court's judgment, holding that the grievance must be sent to arbitration. View "Sysco Indianapolis LLC v. Teamsters Local 135" on Justia Law

The case involves Jose Ageo Luna Vanegas, a guestworker employed by Signet Builders, Inc., who alleges that Signet overworked and underpaid him in violation of the Fair Labor Standards Act (FLSA). Signet, incorporated and headquartered in Texas, hires H-2A visa holders for agricultural work, which it claims exempts them from FLSA overtime pay requirements. Luna Vanegas, who built livestock structures in multiple states including Wisconsin, filed a collective action against Signet in the Western District of Wisconsin, seeking to represent similarly situated workers.The district court initially dismissed the case, citing the FLSA’s agricultural exemption, but the United States Court of Appeals for the Seventh Circuit reversed that decision. Luna Vanegas then moved for conditional certification to notify other Signet workers nationwide about the collective action. Signet argued that the notice should be limited to workers in Wisconsin, asserting that the court only had specific jurisdiction over claims from that state. The district court allowed nationwide notice but certified the question of whether specific jurisdiction is required for each opt-in plaintiff’s claim. The district court held that such jurisdiction was not required, leading to this interlocutory appeal.The United States Court of Appeals for the Seventh Circuit reversed the district court’s decision. The court held that in FLSA collective actions, personal jurisdiction must be established for each plaintiff’s claim individually, whether representative or opt-in. The court rejected the argument that Federal Rule of Civil Procedure 4 could be used to establish nationwide personal jurisdiction in FLSA cases. The court concluded that the district court’s personal jurisdiction is limited to claims that fall within Wisconsin’s specific jurisdiction, and any expansion of jurisdiction would require new Rule 4 service. The case was reversed and remanded for further proceedings consistent with this holding. View "Ageo Luna Vanegas v. Signet Builders, Inc." on Justia Law

Five former participants in the Salvation Army's residential rehabilitation program filed a lawsuit alleging that the organization subjected them to forced labor. The plaintiffs, who participated in the program to address issues such as homelessness and substance abuse, were required to work approximately forty hours per week in exchange for food, clothing, and housing. They claimed that the work was not therapeutic but rather a coercive labor arrangement benefiting the Salvation Army financially. The plaintiffs included both individuals who voluntarily enrolled in the program and those referred by courts or parole/probation departments.The United States District Court for the Northern District of Illinois dismissed the plaintiffs' claims. The court found that the justice-referred plaintiffs' claims were barred by the Rooker-Feldman doctrine, as they were allegedly compelled to participate by state court orders. For the walk-in plaintiffs, the court concluded that the threats of losing food, clothing, and shelter were not sufficiently serious to constitute forced labor under federal law. The court also found that the plaintiffs failed to allege that the Salvation Army acted with the requisite intent to compel labor through threats of serious harm. The district court denied the plaintiffs' request to amend their complaint, leading to an immediate entry of judgment for the Salvation Army.The United States Court of Appeals for the Seventh Circuit affirmed the district court's judgment. The appellate court held that the Rooker-Feldman doctrine did not bar the justice-referred plaintiffs' claims, as their participation was not compelled by state court orders but by parole or probation officers. However, the court found that the plaintiffs' allegations did not plausibly indicate that the Salvation Army violated the forced labor provisions. The walk-in plaintiffs were free to leave the program at any time, and the justice-referred plaintiffs did not adequately demonstrate how the conditions of their participation constituted forced labor. The court also agreed that the proposed second amended complaint would not cure the deficiencies of the original complaint. View "Taylor v. The Salvation Army National Corporation" on Justia Law

Lanlan Li, a 51-year-old woman of Chinese descent, worked as a senior scientist at Fresenius Kabi USA, LLC. In 2019, she developed back pain and eye strain, which led her to take various types of leave. Despite accommodations, her back injury persisted, and she could not return to her position. Consequently, Fresenius terminated her employment. Li sued the company for disability discrimination, retaliation, and failure to accommodate under the Americans with Disabilities Act (ADA) and the Illinois Human Rights Act (IHRA), as well as for national origin and age discrimination under Title VII and the Age Discrimination in Employment Act (ADEA).The United States District Court for the Northern District of Illinois granted summary judgment in favor of Fresenius on all claims. The court found that Li failed to exhaust her administrative remedies for her age and national origin claims, as she did not include a right-to-sue letter from the Equal Employment Opportunity Commission (EEOC) or the Illinois Department of Human Rights (IDHR). The court also held that her disability and retaliation claims failed on the merits, noting that Li was not a qualified individual under the ADA because she could not perform the essential functions of her job, including bench work.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court agreed that Li was not a qualified individual under the ADA and that Fresenius had provided reasonable accommodations. The court also found that Li failed to present evidence of age or national origin discrimination and that her retaliation claim lacked a causal connection between her EEOC charges and her termination. Therefore, the court upheld the summary judgment in favor of Fresenius. View "Li v. Fresenius Kabi USA, LLC" 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

A group of employees sued their employer, Metalcraft of Mayville, for not paying them for time spent working just before or after their shifts. The employees alleged that Metalcraft's timekeeping system, which allowed clocking in up to 15 minutes before and after shifts, did not accurately reflect the time they worked. They claimed that adjustments to their clock-in times were made even when they performed compensable work during these periods.The United States District Court for the Eastern District of Wisconsin decertified the collective action in April 2020, leading to 24 additional cases being filed and consolidated. Nine cases were dismissed for various reasons, and the district court granted summary judgment to Metalcraft in the four selected cases, ruling that the employees' evidence was speculative and insufficient. The remaining 12 plaintiffs voluntarily dismissed their cases, acknowledging that the summary judgment ruling likely determined their claims. Metalcraft then moved for sanctions against the plaintiffs' counsel, arguing that the lawsuits were frivolous.The United States Court of Appeals for the Seventh Circuit reviewed the case and upheld the district court's denial of sanctions. The appellate court found that the plaintiffs had enough factual and legal support for their claims to avoid sanctions. The court noted that FLSA claims can be based on reconstructed memories when an employer's record-keeping is inadequate. The court also determined that the plaintiffs' legal arguments regarding the Portal-to-Portal Act and the de minimis doctrine were not baseless. The appellate court emphasized that the standard for summary judgment is different from the standard for Rule 11 sanctions and that the plaintiffs' failure to win on summary judgment did not make their cases frivolous. Therefore, the denial of sanctions was affirmed. View "Farina v. Metalcraft of Mayville, Inc." on Justia Law