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

The Seventh Circuit affirmed the judgment of the district court denying the motion filed by the Word Seed Church after the district court dismissed this suit for lack of standing, holding that Word Seed failed to show exceptional circumstances warranting relief from the denial of that motion.Word Seed and an organization to which it belonged (collectively, Word Seed) brought this action against the Village of Homewood, Illinois alleging violations of the Religious Land Use and Institutionalized Persons Act and the Equal Protection Clause of the Fourteenth Amendment. The district court dismissed the suit for lack of standing after concluding that Word Seed did not suffer an injury and denied Word Seed's ensuing motions to reconsider. In the second motion, which the district court considered under Fed. R. Civ. P. 60(b), Word Seed raised for the first an argument that could have been raised before the district court entered judgment dismissing the case. The district court denied the motion. The Seventh Circuit affirmed, holding that the court did not abuse its discretion in denying Word Seed's Rule 60(b) motion. View "Word Seed Church v. Village of Homewood" on Justia Law

The Seventh Circuit affirmed the judgment of the district court dismissing North American Elite Insurance Company's (North American) claims against Menard, holding that there was no error.After a Menard employee hit a customer with a forklift the customer brought a negligence suit against Menard and its employee in state court. Menard carried two levels of personal injury liability insurance at the time. Liability exceeding $3 million fell under an umbrella policy with North American. The jury returned a $13 million verdict, which was reduced to a $6 million settlement. North American indemnified Menard for liability in excess of $3 million then brought this action against Menard in federal court, arguing that Menard violated its duties under Illinois law by rejecting a settlement offer and proceeding to trial. The district court dismissed all claims. The First Circuit affirmed, holding that North American was not entitled to relief on its claims of error. View "North American Elite Insurance v. Menard, Inc." on Justia Law

The Seventh Circuit vacated Defendant's above-Guidelines sentence of eighty-four months in prison imposed in connection with his plea of guilty to possessing a firearm as a felon, holding that the sentencing decision rested on conflicting findings that could not be reconciled.Based largely on his finding that Defendant was an active participant in the shoot-out at issue rather than an innocent bystander, the sentencing judge imposed an above-guidelines sentence of eighty-four months in prison. On appeal, Defendant argued that the judge selected the sentence based on the clearly erroneous finding that he was an active participant in the shooting. The Seventh Circuit agreed and remanded the cause for resentencing, holding that the record reflected an "inscrutable inconsistency" in the factual findings on which the judge based his choice of sentence. View "United States v. Davis" on Justia Law

The Seventh Circuit affirmed the judgment of the district court denying Defendant's motion to suppress without holding an evidentiary hearing, holding that the district court did not abuse its discretion by denying an evidentiary hearing.A law enforcement officer stopped Defendant while he was riding a motorized bicycle and arrested him under the theory that his bicycle was a motor vehicle requiring a license. During the arrest, police searched Defendant and found various drugs and drug paraphernalia. Defendant filed a motion to suppress, arguing that the government needed to establish probable cause that he was driving a motor vehicle on a revoked license. The district court summarily denied the motion. The Seventh Circuit affirmed, holding that the evidence established that the arresting officer had probable cause to believe that Defendant rolled past a stop sign, which independently supported Defendant's arrest. View "United States v. Norville" on Justia Law

In this dispute over Plaintiff's employment status the Seventh Circuit reversed the judgment of the district court granting Defendant's motion to dismiss all claims on the pleadings, holding that the district court erred by giving decisive effect to the terms of Defendant's contracts.Plaintiff hauled freight for Defendant under an agreement that labeled him as an independent contractor. Plaintiff later filed this lawsuit claiming that Defendant violated minimum wage requirements under the Fair Labor Standards Act (FLSA) and Wisconsin law, unjustly enriched itself under Wisconsin law, and violated federal Truth-in-Leasing regulations. The district court dismissed all claims on the pleadings. The Seventh Circuit reversed, holding that Plaintiff alleged legally viable claims for relief under the FLSA, federal Truth-in-Leasing regulations, and Wisconsin minimum wage law. View "Brant v. Schneider National, Inc." on Justia Law

The Seventh Circuit affirmed the judgment of the district court concluding that the terms of a settlement resulted in a de facto assignment of a corporation's theoretical legal malpractice claim to Amit Shah by using the corporation as his alter ego, holding that there was no error.In 2013, Shah and another minority shareholder of Duro, Inc. brought this action against Duro and its third shareholder, alleging money laundering and racketeering. In 2015, Plaintiffs added a shareholder derivative claim of legal malpractice, nominally on behalf of Duro, against a law firm and its attorneys (May Oberfell), who had represented Defendants in the case. In 2017, Plaintiffs settled their claims, preserving any claims Duro might have against May Oberfell. Shah subsequently took effective control of Duro and transferred all of Duro's assets except the legal malpractice claim. Thereafter, Shah, through Duro, filed a complaint against May Oberfell. The district court granted summary judgment for May Oberfell, concluding that the legal malpractice claim had undergone a "de facto" assignment, and therefore, the claim was barred under Indiana law. The Seventh Circuit affirmed, holding that May Oberfell was entitled to summary judgment. View "Duro, Inc. v. Walton" on Justia Law

In this complaint brought under 42 U.S.C. 1983 and 42 U.S.C. 1985(3) relating to the custody of Plaintiffs' children, the Seventh Circuit affirmed the judgment of the district court dismissing this suit seeking damages for alleged violations of Plaintiffs' constitutional rights to familial integrity, free exercise of religion, and due process of law, holding that there was no error.Plaintiffs brought this action seeking money damages and equitable relief for actions Defendants took with respect to three of their daughters. On appeal, Plaintiffs challenged the dismissal of their claims for money damages regarding the custody of S.M. and D.M. The Seventh Circuit affirmed, holding (1) the judge properly dismissed as untimely all claims relating tot he custody of S.M.; and (2) as to the remaining claims, the trial judge properly concluded that the complaint failed to allege conduct plausibly exposing Defendants to liability and that other claims were foreclosed by absolute immunity. View "Milchtein v. Milwaukee County" on Justia Law

In this action brought the estate of Jonah Marciniak and Marciniak's son pursuing both federal and state claims stemming from Marciniak's arrest and ensuing suicide, the Seventh District held that the district court did not err in granting summary judgment in favor of the Village of Shorewood and three of its officers who arrested Marciniak after his roommate fell from a fourth story window, holding that there was no error.After arresting Marciniak and placing him in a booking cell, Marciniak used his t-shirt to hang himself. Marciniak died six days later. Plaintiffs brought this action alleging that the three officers falsely arrested Marciniak without probable cause and failed to provide medical care and attention and to protect from self-harm. The district court granted summary judgment in favor of Defendants. The Seventh Circuit affirmed, holding (1) Defendants had an absolute defense of probable cause to Plaintiffs' claims; and (2) even if the officers did not have probable cause to arrest for battery, they were still entitled to qualified immunity. View "Jump v. Village of Shorewood" on Justia Law

The Seventh Circuit reversed the order of the district court granting summary judgment and dismissing this complaint brought by Plaintiff after he was fired from his commissary job while incarcerated at Indiana State Prison, holding that the district court erred in finding that Plaintiff failed to comply with the Prison Litigation Reform Act's (PLRA) exhaustion requirement, 42 U.S.C. 1997e(a).Plaintiff was hired for a job in the commissary with the understanding that he would miss work on Fridays to attend the prison's weekly Jumu'ah Muslim prayer service. When Officer Julie Anton refused to allow Plaintiff to attend Jumu'ah and he went anyway, Anton fired Plaintiff based on a work evaluation accusing Plaintiff of theft. Plaintiff sued Anton under 42 U.S.C. 1983, alleging a violation of his First Amendment rights. The district court dismissed the complaint because Plaintiff did not file a formal grievance before bringing suit. The Seventh Circuit reversed, holding that the prison's grievance policy excepted Plaintiff's claim from the prison's administrative process. View "Miles v. Anton" on Justia Law

The Seventh Circuit affirmed the judgment of the district court imposing an above-Guidelines sentence of eighty-four months after Defendant pleaded guilty to being a felon in possession of a firearm, holding that the sentence was procedurally and substantively reasonable.The court ultimately calculated Defendant's new offense level to be seventeen, yielding an advisory Guidelines range of fifty-one to sixty-three months' imprisonment. The district court concluded that an upward variance from the advisory guidelines range was required to protect the public and sentenced Defendant to eighty-four months' imprisonment. The Seventh Circuit affirmed, holding that Defendant's sentence was both procedurally and substantively reasonable. View "United States v. Dickerson" on Justia Law