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

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

Anthony Sullers, Sr., an African American elevator mechanic, filed a lawsuit against his union, the International Union of Elevator Constructors, Local 2 (IUEC), alleging that the union breached its duty of fair representation in handling his claim of racial discrimination by his employer, ThyssenKrupp Elevator Corporation (TKE). Sullers and another employee were laid off, and while Sullers was without work, TKE hired a white mechanic. Sullers informed the union of his layoff and his belief that it was racially motivated. The union filed a grievance on his behalf but did not include allegations of racial discrimination. Sullers followed the union's advice to file a complaint with the Illinois Department of Human Rights (IDHR).The United States District Court for the Northern District of Illinois granted summary judgment in favor of IUEC. The court found that the union had fulfilled its duty of fair representation by obtaining the maximum remedy available for Sullers, including his reinstatement and backpay. The court also noted that Sullers had not requested the union to file a racial discrimination grievance and that the union's actions were not arbitrary, discriminatory, or in bad faith.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's judgment. The appellate court held that the union's decision to pursue the grievance as it did, rather than filing a racial discrimination grievance, was within its discretion and not arbitrary, discriminatory, or in bad faith. The court also found that Sullers did not suffer harm attributable to the union's actions, as he was reinstated and received backpay. The court concluded that the union had properly represented Sullers and that he had not shown how he would have achieved a better outcome through arbitration. View "Sullers v. International Union Elevator Constructors, Local 2" on Justia Law

Santoasha Harris endured five years of sexual harassment at her job with the City of Milwaukee. When she reported the harassment in 2017, the City separated her from the harasser, conducted an investigation, compelled the harasser’s resignation, and restored Harris to her position within a month. Harris sued the City, alleging it knew about the harassment for years, failed to act, and retaliated against her for reporting it. Due to Harris’s bankruptcy filing, her estate was substituted as the plaintiff.The United States District Court for the Eastern District of Wisconsin granted summary judgment to the City. The court concluded that Harris’s Estate had not shown the City unreasonably failed to prevent the harassment or that she suffered a tangible employment action as a consequence of reporting it. The court found no evidence supporting the Title VII and Section 1983 claims against the City.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s judgment. The appellate court agreed that the evidence did not support the claims of quid pro quo harassment, hostile work environment, or retaliation under Title VII. The court found that Harris did not suffer a tangible employment action and that the City acted promptly and reasonably once the harassment was reported. Additionally, the court found no basis for employer liability under Section 1983, as there was no evidence of intentional discrimination by the City. The court concluded that no reasonable jury could find for the Estate on its claims against the City. View "Bankruptcy Estate of Harris v City of Milwaukee" on Justia Law

Brian J. Murphy, a former employee of Caterpillar Inc., alleged that he was constructively discharged due to age discrimination and retaliation for previous legal actions against the company. Murphy, who began working for Caterpillar in 1979, had a long history of positive performance reviews and promotions. In 2000, he was placed on a performance action plan and subsequently fired after complaining about age discrimination. He sued Caterpillar, won a retaliation claim, and was reinstated in 2005. In 2018, after successfully leading a significant project, Murphy was placed on another performance action plan that he argued was designed for him to fail.The United States District Court for the Central District of Illinois granted summary judgment in favor of Caterpillar on all claims. The court found that Murphy did not provide sufficient evidence to support his claims of age discrimination and retaliation. Murphy appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that Murphy presented enough evidence to support a reasonable inference of pretext and unlawful intent regarding his age discrimination claim. The court noted that the performance action plan was flawed, as it included a deadline that had already passed and was signed off as failed before Murphy had a chance to comply. This, along with Murphy's consistent positive performance reviews, suggested that the plan was a pretext for discrimination. However, the court affirmed the summary judgment on Murphy's retaliation claim, citing the long gap between his previous lawsuit and the adverse action, and the lack of evidence of retaliatory animus.The Seventh Circuit reversed the district court's decision on the age discrimination claim, allowing it to proceed to trial, but affirmed the decision on the retaliation claim. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Murphy v Caterpillar Inc." on Justia Law

Olayinka Oye, a director at PricewaterhouseCoopers, applied for long-term disability benefits through her employer's plan, administered by Hartford Life and Accident Insurance Company, due to fibromyalgia. Initially, Hartford denied her claim but later reversed its decision and awarded her benefits. In 2020, Hartford reevaluated her condition and terminated her benefits, concluding she was no longer disabled. Oye filed a lawsuit seeking to reinstate her benefits under the Employee Retirement Income Security Act (ERISA).The United States District Court for the Northern District of Illinois conducted a "paper trial" and found that Oye's fibromyalgia, while limiting, did not render her disabled under the plan. The court noted that consultative reports from Hartford's doctors, which were detailed and tied to Oye's medical records, outweighed the brief and conclusory letters from Oye's treating physicians. Additionally, the court found that Oye's mental health issues contributed significantly to her limitations, disqualifying her from additional benefits under the plan.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's decision, emphasizing that the district court owed no deference to Hartford's prior determination of disability. The appellate court found no clear error in the district court's findings, noting that the district court carefully considered the evidence and provided adequate reasoning for its decision. The court also addressed Oye's contention that the district court should have discussed a 2017 consultative report, concluding that the district court was not obligated to address every piece of evidence and had reasonably focused on more recent reports. The Seventh Circuit affirmed the district court's judgment in favor of Hartford. View "Oye v Hartford Life and Accident Insurance Company" on Justia Law

Employees of United Airlines, including pilots, flight attendants, and other staff, challenged the company's COVID-19 vaccination mandate and masking requirement issued in 2021. United required employees to either get vaccinated or apply for religious or medical exemptions by specific deadlines. Plaintiffs alleged that despite submitting or attempting to submit exemption requests, they were either fired, placed on unpaid leave, or subjected to a hostile work environment.The United States District Court for the Northern District of Illinois dismissed the plaintiffs' claims with prejudice, finding that they had not stated any viable claim for relief despite having sufficient opportunities to do so. The court addressed each of the plaintiffs' twelve claims, noting that many were forfeited due to the plaintiffs' failure to respond to substantive arguments. The court also found deficiencies in the proposed amended complaints and ultimately dismissed the action with prejudice after determining that further amendments would be futile.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that the plaintiffs' claims were either improperly preserved or inadequately pled. The court found that the plaintiffs had forfeited their FDCA, invasion of privacy, and negligence claims by failing to address the district court's findings of forfeiture. The court also upheld the dismissal of the Illinois Whistleblower Act claim, as the plaintiffs did not show how receiving a COVID-19 vaccine would violate federal regulations. Additionally, the court affirmed the dismissal of the Title VII claims due to the plaintiffs' failure to obtain right-to-sue letters from the EEOC, which is a prerequisite for such lawsuits. The appellate court concluded that the district court did not err in denying further opportunities to amend the complaint. View "Anderson v. United Airlines" on Justia Law

In August 2021, the Cook County Health and Hospitals System implemented a policy requiring all personnel to be fully vaccinated against infectious diseases, including COVID-19. Exemptions were allowed for disability, medical conditions, or sincerely held religious beliefs. Plaintiffs, who are healthcare employees or contractors, requested religious exemptions, which were granted. However, the accommodation provided was a transfer to unpaid status pending termination, with a limited time to find a non-existent remote position. Plaintiffs argued this was religious discrimination violating the Free Exercise Clause of the First Amendment.The United States District Court for the Northern District of Illinois previously denied plaintiffs' motions for preliminary injunctions against the vaccine mandates, including Cook County’s. The Seventh Circuit affirmed this denial, rejecting the plaintiffs' facial challenge to the mandate. On remand, plaintiffs amended their complaint but were denied permission to add a claim under the Illinois Religious Freedom Restoration Act until after the court ruled on the County’s motion to dismiss. The district court dismissed the second amended complaint, considering it a facial challenge, which had already been ruled upon.The United States Court of Appeals for the Seventh Circuit reviewed the case and held that the plaintiffs waived their as-applied challenge by not raising it in the district court or their opening brief on appeal. The court also noted that plaintiffs conceded they no longer sought injunctive relief and did not pursue a facial challenge. Consequently, the court affirmed the district court’s dismissal of the constitutional claim. Additionally, the court found no abuse of discretion in the district court’s denial of leave to amend the complaint to include the Illinois RFRA claim. The court criticized the plaintiffs' counsel for poor advocacy and procedural errors. View "Lukaszczyk v Cook County" on Justia Law