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

Heather Schroeder and Misty Tanner, representing a class of Indiana car owners insured by Progressive Paloverde Insurance Company and Progressive Southeastern Insurance Company, filed a lawsuit claiming that Progressive breached its contractual duty by applying "Projected Sold Adjustments" to the list prices of comparable cars when determining the actual cash value of totaled cars. The insurance policy in question specifies that the actual cash value is determined by the market value, age, and condition of the vehicle at the time of the loss.The United States District Court for the Southern District of Indiana, Indianapolis Division, recognized that whether Progressive paid each class member the actual cash value of their car is not susceptible to classwide proof. However, it concluded that common evidence could establish that Progressive employed an unacceptable method for calculating actual cash value payments by applying Projected Sold Adjustments. The court certified a class on this basis.The United States Court of Appeals for the Seventh Circuit reviewed the case and concluded that Progressive’s policy does not preclude the use of Projected Sold Adjustments in calculating actual cash value payments, as long as the insureds are ultimately paid the actual cash value of their totaled cars as defined under the policy and Indiana law. The court found that individual questions about whether Progressive failed to pay each class member the actual cash value of their car would overwhelm any common ones. Consequently, the Seventh Circuit reversed the district court’s class certification decision and remanded the case for further proceedings. View "Schroeder v. Progressive Paloverde Insurance Co." on Justia Law

The Northwestern Illinois Area Agency on Aging (NIAAA) filed lawsuits against Paula Basta, the former Director of the Illinois Department on Aging (IDA), alleging that Basta unlawfully refused to hold hearings on three administrative petitions filed by NIAAA. These petitions concerned grievances about withheld funding and rejected service provider designations. NIAAA claimed that these actions violated their rights under the Older Americans Act (OAA) and Illinois state law.The Illinois Supreme Court ruled in favor of Basta, determining that NIAAA did not have a constitutionally protected property interest in the funding or service provider designations. Subsequently, the federal district court dismissed NIAAA’s suit, finding it time-barred and failing to state a claim. NIAAA then appealed to the United States Court of Appeals for the Seventh Circuit.The Seventh Circuit affirmed the district court’s dismissal. The court held that NIAAA’s claims related to the denials of the Initial Petition and APS Petition were barred by the statute of limitations, as they accrued by September 2019 and were not tolled by NIAAA’s state court litigation. The court also agreed with the district court that NIAAA failed to plausibly allege a due process violation, as the Illinois Supreme Court had determined that NIAAA did not have a property interest in the funding or service provider designations.Furthermore, the Seventh Circuit found that the OAA provisions at issue did not create individual rights enforceable under 42 U.S.C. § 1983. The court concluded that the OAA’s language and context did not unambiguously confer individual rights upon NIAAA, and thus, NIAAA could not enforce these provisions through § 1983. The court affirmed the district court’s judgment in favor of Basta. View "Northwestern Illinois Area Agency on Aging v. Basta" on Justia Law

In 2016, the Village of Schaumburg enacted an ordinance requiring commercial and multifamily properties to route fire alarm signals directly to a regional emergency-dispatch center. This ordinance aimed to reduce fire department response times and had financial benefits for the Village. Several alarm companies, which previously used a different model for transmitting alarm signals, claimed that the ordinance caused them to lose business and led to more expensive and lower-quality alarm services for customers.The alarm companies sued the Village, alleging that the ordinance violated the Contracts Clause and tortiously interfered with their contracts and prospective economic advantage. The United States District Court for the Northern District of Illinois initially dismissed the federal claims and relinquished jurisdiction over the state-law claims. On appeal, the Seventh Circuit reversed in part, allowing the Contracts Clause claim to proceed. However, on remand, the district court granted summary judgment for the Village, finding that the alarm companies failed to provide evidence that the ordinance caused customers to breach existing contracts or that the Village intended to interfere with their business relationships.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The court held that the alarm companies did not present sufficient evidence to show that the ordinance caused customers to breach contracts or that the Village acted with the intent to harm the alarm companies' businesses. The court also found that the alarm companies' claims of tortious interference with prospective economic advantage failed because the Village's actions were motivated by public safety and financial considerations, not a desire to harm the alarm companies. View "Alarm Detection Systems, Inc. v. Village of Schaumburg" on Justia Law

Ayla Royan, a student in Chicago State University's (CSU) Doctor of Pharmacy program, was dismissed after failing two clinical rotations. Royan, who has clinical depression and an eating disorder, claimed her dismissal was due to her disabilities. CSU had accommodated her conditions by granting exam and assignment extensions and a yearlong medical leave. Despite these accommodations, Royan failed her first clinical rotation under Dr. Patel and her second under Dr. Kerner, leading to her dismissal.The United States District Court for the Northern District of Illinois granted summary judgment in favor of CSU, finding that Royan failed to present sufficient evidence that her dismissal was solely based on her disability. The court held that CSU had accommodated her disabilities and applied its academic standards without discrimination.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court held that Royan was not "otherwise qualified" for the program as she failed to meet the academic requirements, specifically passing the clinical rotations. The court also found no evidence of pretext in CSU's stated reasons for her dismissal. Additionally, the court concluded that no reasonable jury could find that CSU dismissed Royan solely because of her disabilities, as required under Section 504 of the Rehabilitation Act. The court emphasized that academic institutions have broad discretion in setting and enforcing academic standards, and CSU's actions were consistent with its policies and procedures. View "Royan v. Chicago State University" on Justia Law

Avanzalia Panamá and its parent company, Avanzalia Solar, built a solar plant in Panama and sought to connect it to the El Coco substation, owned by Goldwind USA's affiliate, UEPI. Avanzalia alleged that Goldwind tortiously blocked their access to the substation, preventing them from selling electricity. Avanzalia filed a complaint with Panama's Autoridad de Servicios Públicos (ASEP), which required them to submit updated electrical studies and obtain an access agreement with UEPI. Despite obtaining the agreement, Avanzalia faced further delays and was unable to connect to the substation until May 2020.The United States District Court for the Northern District of Illinois granted summary judgment to Goldwind. The court found that Avanzalia could not satisfy the Illinois state law requirement for tortious interference, which necessitates that the defendant's actions be directed at a third party. The court also applied collateral estoppel, concluding that ASEP's findings were binding and precluded Avanzalia's claims related to pre-access agreement delays.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's decision to afford comity to ASEP's order and apply collateral estoppel, barring Avanzalia's claims related to pre-access agreement delays. However, the appellate court found that the district court erred in not considering the impossibility theory of tortious interference under Restatement (Second) of Torts § 766A. The court vacated the summary judgment on this issue and remanded for further proceedings to determine whether Goldwind wrongfully prevented Avanzalia from performing its contractual obligations. The judgment was affirmed in all other respects. View "Avanzalia Solar, S.L. v. Goldwind USA, Inc." on Justia Law

East Gate-Logistics Park Chicago, LLC and NorthPoint Development, LLC (the East Gate parties) are involved in a dispute with CenterPoint Properties Trust and its affiliates (the CenterPoint parties) over development projects in the Joliet Intermodal Zone in Illinois. CenterPoint entered into a Memorandum of Understanding (MOU) with local authorities to build a toll bridge, while East Gate later secured an agreement allowing heavy trucks to bypass this toll bridge, which CenterPoint claims violates the MOU.The CenterPoint parties sued in Will County Court to enjoin the East Gate agreement, initially losing but later securing a preliminary injunction on remand from the Illinois Appellate Court. The state court has yet to rule on the merits. Subsequently, the East Gate parties filed a federal antitrust lawsuit, claiming the MOU unlawfully restricted competition. The CenterPoint parties argued the federal court lacked jurisdiction under the Rooker-Feldman doctrine, should abstain under the Colorado River doctrine, and that the Noerr-Pennington doctrine shielded them from antitrust liability.The United States District Court for the Northern District of Illinois rejected the Rooker-Feldman argument, dismissed the Noerr-Pennington motion without addressing the merits, but stayed the federal proceedings under Colorado River. The East Gate parties appealed the stay, while the CenterPoint parties cross-appealed the rejection of their motions.The United States Court of Appeals for the Seventh Circuit dismissed the appeal for lack of jurisdiction, determining that the stay did not effectively end the federal case and was merely a case management decision. The court also found no basis for immediate appeal of the interlocutory orders denying the motions to dismiss, as these could be reviewed after a final decision. View "East Gate-Logistics Park Chicago, LLC v. CenterPoint Properties Trust" on Justia Law

Frederick Brewer was convicted by a jury of distributing fentanyl, possessing with intent to distribute fentanyl, and participating in a conspiracy to distribute fentanyl. The jury, however, found that the government did not prove beyond a reasonable doubt that Brewer's conspiracy and possession convictions involved at least 40 grams of fentanyl. Brewer moved for acquittal twice, arguing insufficient evidence, but the district court denied both motions. Brewer appealed, contending that the evidence was insufficient to support his convictions and that the district court erred in calculating the drug quantity for sentencing.The United States District Court for the Eastern District of Wisconsin initially denied Brewer's motions for acquittal. The court found sufficient evidence to establish that Brewer and his co-defendant, Don James, Jr., were engaged in a conspiracy to distribute fentanyl, rather than a simple buyer-seller relationship. The court also rejected Brewer's argument that the jury's finding regarding the drug quantity undermined the guilty verdicts. At sentencing, the district court attributed 1.2 to 4 kilograms of fentanyl to Brewer, resulting in a higher base offense level and a sentence of 144 months in prison followed by 120 months of supervised release.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 evidence was sufficient to support Brewer's convictions for conspiracy, possession, and distribution of fentanyl. The court also upheld the district court's drug quantity determination for sentencing purposes, noting that the sentencing court could consider conduct underlying acquitted charges if proven by a preponderance of the evidence. Brewer's conviction and sentence were affirmed. View "United States v. Brewer" on Justia Law

United Wisconsin Grain Producers LLC, along with six other ethanol producers, filed an antitrust lawsuit against Archer Daniels Midland Company (ADM). They alleged that ADM manipulated indexes used to set U.S. ethanol prices, forcing them to charge lower prices in their ethanol sales contracts. The plaintiffs claimed monopolization, attempted monopolization, and market manipulation under § 2 of the Sherman Act and parallel state laws.The United States District Court for the Central District of Illinois dismissed the case. The court found that United Wisconsin Grain failed to allege that ADM recouped its losses from below-cost prices by charging monopoly prices, which is necessary for a monopolization claim. Additionally, the plaintiffs waived their challenge to the dismissal of the attempted monopolization claim. The court also noted that the Sherman Act does not recognize a generalized market manipulation claim.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's dismissal, agreeing that United Wisconsin Grain did not allege the necessary recoupment by way of monopoly prices for a monopolization claim. The court also concluded that United Wisconsin Grain waived its attempted monopolization claim by not adequately addressing it in their appeal. Lastly, the court held that the Sherman Act does not support a separate market manipulation claim based on generalized harm to the market. Thus, the district court's dismissal of the amended complaint was affirmed. View "United Wisconsin Grain Producers LLC v. Archer Daniels Midland Co." on Justia Law

Tarlochan Singh, a Sikh man from India, fled to the United States in 2010 after suffering repeated violence due to his political affiliations. The Department of Homeland Security charged him with inadmissibility, and Singh applied for asylum, withholding of removal, and protection under the Convention Against Torture. An immigration judge denied his applications in 2017, finding his claims credible but insufficient to establish past persecution or a well-founded fear of future persecution. The Board of Immigration Appeals (BIA) affirmed this decision in 2018.Singh attempted to file a petition for review with the Seventh Circuit Court of Appeals, but his attorney failed to meet the statutory deadline. Singh then filed a motion to reopen and reissue the BIA's decision, citing ineffective assistance of counsel. The BIA denied this motion, stating that Singh did not meet the procedural requirements. Singh filed another motion to reconsider, which was also denied by the BIA for being untimely and number barred, among other reasons. The Seventh Circuit remanded the case to the BIA to consider the merits of Singh's ineffective assistance claim, but the BIA again denied the motion, citing failure to meet procedural requirements.The United States Court of Appeals for the Seventh Circuit reviewed Singh's petition and upheld the BIA's decision. The court found that Singh failed to comply with the procedural requirements for an ineffective assistance of counsel claim as outlined in Matter of Lozada. Specifically, Singh did not provide a detailed account of his agreement with his attorney, did not notify his attorney of the allegations, and did not provide proof of filing a disciplinary complaint. Consequently, the Seventh Circuit denied Singh's petition for review. View "Singh v. Bondi" on Justia Law

Elizabeth Mejia-Hernandez, a native and citizen of Honduras, arrived in the United States with her children in June 2018. They were placed in immigration removal proceedings in October 2018. Mejia conceded removability and sought asylum, withholding of removal, or protection under the Convention Against Torture (CAT), claiming fear of persecution in Honduras from a man who allegedly killed six members of her family. The immigration judge (IJ) found her ineligible for asylum, denied her requests for withholding of removal and protection under the CAT, and ordered her removal to Honduras.Mejia appealed to the Board of Immigration Appeals (Board), which upheld the IJ's decision and dismissed the appeal. The Board agreed with the IJ that Mejia did not timely object to the Notice to Appear (NTA) defects and had waived her objection by conceding removability. The Board also found insufficient evidence that Mejia had suffered past persecution or had a well-founded fear of future persecution, attributing the violence to a personal dispute rather than her membership in a particular social group.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that Mejia had suffered past persecution due to credible, serious threats and actual violence against her family by Cesar Ramirez Mejia. The court also determined that Mejia had a well-founded fear of future persecution, as Cesar had carried out his threats by killing many of her relatives. The court concluded that Mejia's family relationships were the reason she was targeted, establishing the requisite nexus between her family membership and the persecution.The Seventh Circuit granted the petition for review and remanded the case to the Board for further consideration of whether the Honduran government was sufficiently involved in Cesar’s persecution of Mejia. View "Mejia-Hernandez v. Bondi" on Justia Law