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

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

Cameron Johnson, a convicted felon, was found in possession of a firearm on September 15, 2019. He pleaded guilty to this charge. The Government sought an enhanced sentence under the Armed Career Criminal Act (ACCA) based on Johnson's three prior robbery convictions under Indiana law. Johnson argued that two of these robberies, committed on January 22, 2009, occurred on the same occasion and thus should not count as separate offenses under ACCA. He also contended that a jury should determine whether the robberies were committed on different occasions.The United States District Court for the Southern District of Indiana rejected Johnson's argument, relying on Seventh Circuit precedent that did not require a jury to decide the different-occasions question. The court concluded that the robberies were committed on different occasions and sentenced Johnson to fifteen years in prison, the minimum under ACCA.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court noted that the Supreme Court's recent decision in Erlinger v. United States established that the Fifth and Sixth Amendments entitle defendants to have a jury decide whether prior offenses were committed on the same or different occasions. Given this precedent, the Seventh Circuit determined that the district court erred in not submitting the different-occasions question to a jury. The court also found that this error was not harmless, as it was not clear beyond a reasonable doubt that a jury would have found the robberies to be committed on different occasions.The Seventh Circuit vacated Johnson's sentence and remanded the case for further proceedings consistent with its opinion. View "USA v. Johnson" on Justia Law

Harold Grimes, a coal miner for 34 years, developed black lung disease and later died of lung cancer in 2018. His widow, Susan Grimes, is eligible for survivor’s benefits under the Black Lung Benefits Act. The dispute centers on whether Apogee Coal Company, Grimes’s last employer, or the Black Lung Disability Trust Fund should pay these benefits. The Department of Labor’s administrative law judge (ALJ) and the Benefits Review Board assigned financial responsibility to Apogee, with Arch Resources Inc., Apogee’s former parent corporation, bearing the liability. Arch contested this, arguing that the Trust Fund should pay.The district director initially identified Apogee as a potentially liable operator and notified Arch as Apogee’s “Insurance Carrier.” Despite Apogee’s bankruptcy in 2015, the district director and ALJ concluded that Arch, as Apogee’s self-insuring parent, was responsible for the benefits. The ALJ’s decision was based on the premise that Arch’s self-insurance umbrella covered Apogee’s liabilities. The Benefits Review Board affirmed this decision, referencing its prior cases, including Howard v. Apogee Coal Co., which supported the Department’s theory of liability for self-insuring parents.The United States Court of Appeals for the Seventh Circuit reviewed the case and found no statutory or regulatory basis for holding Arch liable for Apogee’s obligations. The court emphasized that neither the ALJ nor the Board identified a specific provision in the Act or its regulations that justified this liability. The court vacated the Board’s decision and remanded the case with instructions to assign Mrs. Grimes’s benefits to the Black Lung Disability Trust Fund. The court noted that future cases might provide additional arguments for such liability, but in this instance, the Trust Fund must pay. View "Apogee Coal Co. v. Office of Workers' Compensation Programs" on Justia Law

The case involves a challenge to Indiana's ballot access laws by the Indiana Green Party, the Libertarian Party of Indiana, and associated individuals. They argue that the requirements for candidates to collect signatures amounting to 2% of the votes cast in the last Secretary of State election, the process for submitting petitions, and the early deadline for submission are unconstitutional under the First and Fourteenth Amendments. They also challenge the law's indexing of party-level access to the results of the most recent Secretary of State election.The United States District Court for the Southern District of Indiana granted summary judgment in favor of the defendant, Indiana’s Secretary of State. The district court concluded that the 2% signature requirement and the June 30 deadline for submitting petitions were constitutionally permissible, relying on precedent from the Supreme Court and the Seventh Circuit. The court did not address the burdens created by the county-level submission requirement or the challenge to the indexing of the full slate access option.The United States Court of Appeals for the Seventh Circuit affirmed the district court's judgment. The court held that Indiana's ballot access requirements do not impose severe burdens on the plaintiffs' rights. The 2% signature requirement, the June 30 deadline, and the county-level submission process were deemed reasonable and justified by the state's interests in preventing voter confusion and ensuring orderly elections. The court also found that the requirement for parties to garner 2% of the vote in the Secretary of State election to maintain full slate access was reasonable, given the alternative petitioning route available to candidates. The court concluded that the state's regulatory interests were sufficient to justify the challenged restrictions. View "Indiana Green Party v. Morales" on Justia Law

Xengxai Yang robbed a credit union in Appleton, Wisconsin, wearing a black mask and armed with a sawed-off rifle. After his arrest, Yang admitted to the robbery, claiming he wanted to "try something new." He was indicted on multiple counts, including armed bank robbery. Yang initially raised an insanity defense but later withdrew it and entered a plea agreement. However, he subsequently sought to withdraw his guilty plea, citing ineffective assistance of counsel. A second psychological evaluation suggested Yang's mental conditions impaired his judgment during the crime. The court allowed Yang to withdraw his plea and reassert the insanity defense, but ultimately found him guilty and sentenced him to 168 months in prison.Yang did not appeal his conviction directly but filed a motion to vacate his sentence under 28 U.S.C. § 2255, claiming ineffective assistance of counsel. After an evidentiary hearing, Yang withdrew this claim and instead argued that the court's failure to hold a competency hearing violated his due process rights. The district court denied his motion, finding that Yang had procedurally defaulted his competency claim by not raising it earlier and that he was competent during the proceedings.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The court held that procedural default bars Yang's competency claim because he failed to raise it on direct appeal and did not demonstrate cause and prejudice or actual innocence to overcome the default. The court concluded that Yang's competency claim was procedurally defaulted and dismissed his petition for collateral relief under § 2255. View "Xengxai Yang v. United States" 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

In late 1996, Jerry Walker was convicted of engaging in a continuing criminal enterprise (CCE) and other drug-related offenses. He was sentenced to life in prison. Following the passage of the First Step Act of 2018, Walker sought a sentence reduction in 2020, arguing that his CCE conviction qualified as a "covered offense" under the Act. The district court denied his motion, leading to this appeal.The United States District Court for the Eastern District of Wisconsin initially handled Walker's case. After his conviction, the Presentence Investigation Report (PSR) calculated his statutory penalties, suggesting a mandatory 20 years to life imprisonment under 21 U.S.C. § 848(a). The government argued for a mandatory life sentence under § 848(b), the "Super CCE" provision. The court agreed with the PSR's guideline range of life imprisonment but did not explicitly state whether the sentence was under § 848(a) or § 848(b). In 1998, the Seventh Circuit vacated Walker's conspiracy charge but upheld the CCE conviction and life sentence. In 2020, Walker moved for resentencing under the First Step Act, but the district court denied the motion, concluding that his CCE conviction under § 848(a) was not a "covered offense."The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's decision, finding no clear error in determining that Walker was sentenced under § 848(a). The court held that a conviction under § 848(a) is not a "covered offense" under the First Step Act, as its statutory penalties were not modified by the Fair Sentencing Act of 2010. Therefore, Walker was ineligible for a sentence reduction under the First Step Act. The court affirmed the district court's denial of Walker's motion for First Step Act relief. View "USA v. Walker" on Justia Law

Jasmine Bradley was assessed as incompetent to assist in her defense against criminal charges and was referred to the Bureau of Prisons for evaluation under 18 U.S.C. §4241. She reported to the U.S. Marshal on January 28, 2022, and was released on August 24, 2022, with a report stating she was competent. Bradley then pleaded guilty to ten counts of fraud and aggravated identity theft, receiving a 198-month sentence. Her conditional guilty plea reserved the issue of whether the seven-month period between reporting and release required dismissal of her indictment with prejudice.The United States District Court for the Central District of Illinois held that dismissal was not mandatory, even though the Bureau exceeded the statutory time limits set by §4241(d). The court found that the statute did not specify a remedy for exceeding the time limits, and thus dismissal was not required.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court held that while §4241(d) sets a four-month limit for evaluating a defendant's competence, it does not specify a consequence for exceeding this limit. The court emphasized that statutory time limits are "time-related directives" and that dismissal with prejudice is not a fitting remedy for delays in restoring a detainee to competence. The court also noted that the Speedy Trial Act excludes delays caused by mental-health examinations and that dismissal of the indictment would not serve the interests of justice. The court concluded that the appropriate remedy for such delays is not dismissal but potentially ordering the release of the detainee while evaluations continue. View "United States v. Bradley" on Justia Law

Meghan Faxel was injured while riding an inflatable tube down the "Black Hole" water slide at the Wilderness Hotel in Wisconsin Dells. Her tube became stuck and flipped over, causing a shoulder injury. Meghan and her husband, Mike Faxel, sued Wilderness for negligence, common-law premises liability, and loss of consortium. Wilderness filed a cross-claim against ProSlide Technology, Inc., the slide's manufacturer, seeking contribution if found liable. The Faxels missed the deadline to disclose their liability expert and sought an extension, which was denied by the magistrate judge. Wilderness then moved for summary judgment, arguing that without expert testimony, the Faxels could not prove their claims. The magistrate judge agreed and entered judgment for Wilderness.The case was initially filed in the Northern District of Illinois, which transferred it to the Western District of Wisconsin due to lack of personal jurisdiction. The parties consented to proceed before a magistrate judge. The Faxels filed an amended complaint adding ProSlide as a defendant, but the claims against ProSlide were dismissed as time-barred. The Faxels also missed the deadline to disclose an expert witness and their motion to extend the deadline was denied. Wilderness moved for summary judgment, which the magistrate judge granted, concluding that expert testimony was necessary to establish the standard of care required of water-park operators.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the magistrate judge's decision. The court held that the hotel’s duty of care regarding the safety protocols, inspection, and maintenance of water slides required specialized knowledge and expertise. Without expert testimony, the Faxels could not prove their claims. The court concluded that the safety measures taken by Wilderness appeared reasonable on their face and that jurors could not determine the standard of care without expert testimony. Therefore, summary judgment for Wilderness was appropriate. View "Faxel v. Wilderness Hotel & Resort, Inc" on Justia Law