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

Henry Beverly, a financial analyst at Abbott Laboratories, took a personal leave of absence during which he began working for Cook County without informing Abbott. His leave was extended twice, but when he requested a third extension, Abbott had already filled his position and terminated his employment. Beverly sued Abbott, alleging racial discrimination and defamation, among other claims.The United States District Court for the Northern District of Illinois granted summary judgment in favor of Abbott on some of Beverly’s claims, including those related to his termination, while allowing others to proceed to trial. The jury found in favor of Abbott on the remaining claims. Beverly appealed, challenging several pretrial, trial, and post-trial rulings.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s decisions. The appellate court held that the reduction in Beverly’s job duties did not amount to a constructive discharge and that Abbott’s reason for terminating Beverly’s employment was not pretextual. The court also upheld the district court’s mid-trial judgment as a matter of law on Beverly’s defamation claim, finding that the statement in question was a non-actionable opinion. Additionally, the appellate court found no abuse of discretion in the district court’s trial rulings, including those related to impeachment attempts and the exclusion of certain evidence. The court concluded that Beverly’s arguments did not warrant a new trial and affirmed the district court’s judgment in full. View "Beverly v. Abbott Laboratories" on Justia Law

Charles Vavra, an employee of Honeywell International, Inc., was required to complete an online unconscious bias training. Vavra refused to participate in the training and was subsequently terminated. He then filed a lawsuit claiming that his termination was in retaliation for his opposition to the training and for his complaints about an email from the head of his business unit, which he found offensive.The United States District Court for the Northern District of Illinois granted summary judgment in favor of Honeywell. The court found that Vavra's retaliation claims were without merit, leading to his appeal to the United States Court of Appeals for the Seventh Circuit.The Seventh Circuit reviewed the district court’s decision de novo. The court held that Vavra’s opposition to the training did not constitute protected activity under Title VII or the Illinois Human Rights Act because he did not have an objectively reasonable belief that the training violated the law. Vavra had not accessed the training or known its contents, making his belief speculative. Additionally, even if his complaints about the email were considered protected activity, Vavra failed to establish a causal connection between his complaints and his termination. The court noted that Honeywell had consistently sought Vavra’s compliance with the training requirement and only terminated him after his final refusal. The Seventh Circuit affirmed the district court’s grant of summary judgment in favor of Honeywell. View "Vavra v. Honeywell International, Inc." on Justia Law

The case revolves around Tondalaya Gamble, a Black physician who worked at Cook County Health’s John Stroger Hospital for approximately eleven years. Gamble sued Cook County and her former department and division chairs, Edward Linn and Fidel Abrego, alleging race discrimination. She claimed that Cook County violated Title VII of the Civil Rights Act of 1964 and the Illinois Human Rights Act, and that Linn and Abrego violated 42 U.S.C. §§ 1981 and 1983. Gamble argued that she was paid less than similarly situated non-Black physicians.The United States District Court for the Northern District of Illinois granted summary judgment in favor of the defendants, concluding that no reasonable jury could find in Gamble’s favor on any of her claims. The court found that Gamble failed to establish that she was similarly situated to her chosen comparators, two white physicians, Bruce Rosenzweig and Karen Fish. The court noted that Rosenzweig was a part-time employee while Gamble was full-time, and that Fish had more experience and was hired to perform different duties.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court agreed that no reasonable jury could find that Gamble was similarly situated to Rosenzweig or Fish. The court noted that the part-time versus full-time distinction was not dispositive in and of itself, but that other differences, such as their different duties and experience, made them inapt comparators for Gamble’s discrimination claim. The court concluded that Gamble presented no other evidence suggesting that her pay or demanding work responsibilities were because of her race. View "Gamble v. County of Cook" on Justia Law

The plaintiff, Mary Rodgers-Rouzier, worked as a bartender on steamboats operated by American Queen. She alleged that she and her coworkers were wrongly denied overtime wages. Rodgers-Rouzier filed a suit as a collective action, and over one hundred of her coworkers joined her proposed collective action. Meanwhile, American Queen moved to dismiss the case, arguing that Rodgers-Rouzier had agreed to arbitration. The district court denied the motion, but American Queen moved again to dismiss based on the arbitration agreement, this time invoking Indiana state law. The district court granted this motion, over Rodgers-Rouzier’s objections.The district court had previously denied American Queen's motion to dismiss the case for improper venue because Rodgers-Rouzier had agreed to arbitration. However, American Queen then moved again to dismiss based on the arbitration agreement, this time invoking Indiana state law. The district court granted this motion, over Rodgers-Rouzier’s objections that American Queen had waived its argument and the court lacked authority to apply Indiana law in this context. The court further determined that all the workers who had filed consent forms were not parties to the action.The United States Court of Appeals for the Seventh Circuit reversed the district court's decision. The court concluded that although American Queen’s arguments were not waived and the court had authority to enforce the arbitration agreement under Indiana law, Indiana law would hold American Queen to its bargain that its arbitration agreement was governed by the Federal Arbitration Act (FAA). Therefore, Rodgers-Rouzier’s case may continue in federal court. The court did not decide whether it may do so as a collective action and left that question for further litigation. View "Rodgers-Rouzier v. American Queen Steamboat Operating Company, LLC" on Justia Law

The case involves Nikkolai Anderson, a former restaurant host, who sued her employer, Mott Street, for sexual harassment, discrimination, and retaliation after her termination. Anderson's tenure at Mott Street was marked by sub-par performance and inappropriate behavior, including negative interactions with guests and non-compliance with restaurant rules. Mott Street received several negative customer reviews about a rude host, which were traced back to Anderson. After her termination, Anderson filed a lawsuit alleging violations of Title VII of the Civil Rights Act of 1964 and intentional infliction of emotional distress under Illinois state law.The United States District Court for the Northern District of Illinois granted summary judgment in favor of Mott Street. The court found Anderson's claim for intentional infliction of emotional distress barred by the statute of limitations and concluded she had not raised triable issues of fact as to her Title VII allegations. Anderson appealed the district court’s decision as to her Title VII claims.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court found no triable issue of fact on the third element of a hostile work environment claim—that the conduct was so severe or pervasive as to alter the conditions of employment. The court also found that Anderson could not identify an appropriate comparator nor raise a triable issue of fact as to Mott Street’s stated reasons for firing her, thus her sex discrimination claim could not proceed to trial. Lastly, the court found no causal connection between Anderson's alleged protected activity and her firing, nor could she produce evidence showing that Mott Street’s stated reason for firing her was pretextual. Therefore, the court affirmed the district court's grant of summary judgment on her retaliation claim. View "Anderson v. Mott Street" on Justia Law

The case revolves around a former coal miner, Richard McLain, who developed a serious lung condition after working underground for nearly two decades. McLain filed a claim under the Black Lung Benefits Act, alleging that his years of mine work had left him totally disabled from a pulmonary perspective. His former employer, Old Ben Coal Company, had been liquidated through bankruptcy, so Liberty Mutual Insurance Company, the surety guaranteeing Old Ben’s debts under the Act, contested liability on the coal company’s behalf.The case was initially heard by an administrative law judge (ALJ), who determined that McLain was disabled within the meaning of the Black Lung Benefits Act. The ALJ's decision was based on a thorough review of the medical record and a set of medical findings regarding how to distinguish between lung disorders arising from coal dust and those arising from tobacco smoke. Old Ben appealed the ALJ’s decision to the Benefits Review Board, arguing that the ALJ erroneously treated the 2001 preamble as if it were binding law and made factual findings unsupported by the medical record. The Review Board affirmed the benefits decision in full.The case was then brought before the United States Court of Appeals for the Seventh Circuit. The court affirmed the decision of the Benefits Review Board, emphasizing the broad discretion ALJs enjoy when evaluating competing medical theories, the weight ALJs may properly attribute to the perspective of the Department of Labor on such issues, and the significant deference owed to ALJs’ medical findings and scientific judgments on appeal. The court found no error in the ALJ's application of a regulatory preamble or in the factual findings that were challenged by Old Ben. View "Safeco Insurance/Liberty Mutual Surety v. OWCP" on Justia Law

The Equal Employment Opportunity Commission (EEOC) brought a Title VII employment discrimination action on behalf of black employees of Village at Hamilton Pointe, LLC, a long-term care facility in Indiana. The EEOC alleged that Hamilton Pointe and Tender Loving Care Management, LLC (TLC), which provides services to Hamilton Pointe, subjected the employees to racial harassment. The district court granted TLC’s motion for summary judgment with respect to some of the employees, ruling that TLC could not be considered an employer under Title VII. The court also granted Hamilton Pointe’s motion for partial summary judgment with respect to the claims of forty employees. Seven remaining employees proceeded to a jury trial, with damages awarded to one employee. The EEOC appealed the grant of summary judgment for TLC and Hamilton Pointe, and the jury’s verdict.The United States Court of Appeals for the Seventh Circuit affirmed the district court's judgment. The court found that the EEOC failed to establish that the employees were subjected to a racially hostile work environment that was so severe or pervasive as to alter the conditions of their employment. The court also found that the EEOC failed to establish that TLC was a joint employer of the claimants. The court emphasized that the federal law governing racial harassment proscribes conduct that is so severe or pervasive as to change the conditions of the victim’s employment, but does not ensure that the worker will have wise and skilled superiors with a sharply honed sense of social justice and a mastery of personnel management skills. View "EEOC v. Village at Hamilton Pointe LLC" on Justia Law

Donald Artz, an electric distribution controller at WEC Energy Group, retired due to multiple sclerosis (MS) and sought long-term disability benefits from a plan administered by Hartford Life and Accident Insurance Company. Hartford denied his claim, asserting that Artz was not "disabled" within the plan's definition. Artz filed a lawsuit under the Employee Retirement Income Security Act, alleging that Hartford's disability determination was arbitrary and capricious because it misconstrued the plan's terms and failed to provide a reasonable explanation for its decision.The case was initially heard in the United States District Court for the Eastern District of Wisconsin. The district court upheld the denial of benefits at summary judgment, concluding that Artz had placed too much emphasis on the duties of his specific position at WEC rather than the "essential duties" of his job in the general workplace as required by the company’s plan. The court also underscored the independent medical reviews commissioned by Hartford and found the medical evidence supported the conclusion that Artz’s MS did not prevent him from working a standard 40-hour week as a power-distribution engineer.The case was then appealed to the United States Court of Appeals for the Seventh Circuit. The appellate court affirmed the district court's decision, finding that Hartford had communicated rational reasons for its decision based on a fair reading of the plan and Artz’s medical records. The court concluded that the plan administrator provided sufficient process and that the Employee Retirement Income Security Act requires no more. The court noted that while Artz's condition was serious, the evidence did not show that the severity and persistency of his symptoms resulted in functional impairment as defined by the policy. View "Artz v. Hartford Life & Accident Insurance Company" on Justia Law

Monica Rongere, a former Diversity Procurement Officer for the City of Rockford, Illinois, sued the city after her employment was terminated. Rongere claimed that she was overworked and underpaid compared to her male colleagues, and that her termination was due to her complaints about this disparity. She brought claims under the Equal Pay Act, Title VII of the Civil Rights Act of 1964, the Illinois Human Rights Act, the Illinois Whistleblower Act, and Illinois common law, alleging equal pay, sex discrimination, hostile work environment, and retaliation.The district court ruled in favor of the City on the Equal Pay Act, Title VII, and Illinois Human Rights Act claims, and relinquished jurisdiction over the remaining state-law claims. Rongere appealed this decision.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court found that Rongere failed to identify adequate comparators for her equal pay and sex discrimination claims, did not show that she engaged in protected activity based on an objectively reasonable belief for her retaliation claim, did not present sufficient evidence of a hostile work environment, and did not explain how the district court abused its discretion in relinquishing jurisdiction over the remaining claims. The court also found that Rongere did not hold an objectively reasonable belief that the City paid male employees more than female employees for the same work, which was necessary for her retaliation claims. View "Rongere v. City of Rockford" on Justia Law

The case involves Appvion, Inc., a Wisconsin-based paper company, which was sold to its employees through an Employee Stock Ownership Plan (ESOP) in 2001. The company declared bankruptcy in 2017. Grant Lyon, acting on behalf of the ESOP, filed a lawsuit against various individuals and corporations, alleging that they fraudulently inflated the price of Appvion in 2001 and that the price remained inflated until Appvion’s bankruptcy. The district court dismissed almost all the claims.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the dismissal of some claims and reversed and remanded others. The court affirmed the dismissal of claims related to actions before November 26, 2012, as they were time-barred under the Employee Retirement Income Security Act (ERISA). However, the court reversed the dismissal of claims related to actions after November 26, 2012, finding that the plaintiff had adequately alleged that the defendants breached their fiduciary duties under ERISA by failing to ensure that the company's valuations were sound. The court also reversed the dismissal of claims alleging that the defendants engaged in prohibited transactions and co-fiduciary liability. The court affirmed the dismissal of state-law claims against the defendants, finding them preempted by ERISA. View "Appvion, Inc. Retirement Savings and Employee Stock Ownership Plan v. Buth" on Justia Law