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

3M Company operates a manufacturing facility in Cordova, Illinois, producing chemical products containing PFAS. The State of Illinois sued 3M, alleging that PFAS from the Cordova Facility contaminated the Mississippi River, violating state environmental laws. The State's complaint specifically excluded PFAS contamination from any other source, including AFFF used by the U.S. military at the nearby Rock Island Arsenal.The case was initially filed in Illinois state court. 3M removed it to the United States District Court for the Central District of Illinois, citing the federal officer removal statute, arguing that some contamination might have come from AFFF provided to the military, thus invoking a federal government contractor defense. The State moved to remand the case back to state court. The district court granted the motion, finding that the State's complaint excluded AFFF-related contamination, focusing solely on PFAS from the Cordova Facility.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court held that 3M could not satisfy the fourth element required for removal under the federal officer removal statute, which necessitates a colorable federal defense. The court noted that the State had unequivocally conceded that it would not seek relief for mixed PFAS contamination and that any recovery would be barred if contamination was not solely from the Cordova Facility. Consequently, 3M's government contractor defense was deemed irrelevant under the State's theory of recovery. The Seventh Circuit affirmed the district court's decision to remand the case to state court. View "Raoul v. 3M Company" on Justia Law

Five former participants in the Salvation Army's residential rehabilitation program filed a lawsuit alleging that the organization subjected them to forced labor. The plaintiffs, who participated in the program to address issues such as homelessness and substance abuse, were required to work approximately forty hours per week in exchange for food, clothing, and housing. They claimed that the work was not therapeutic but rather a coercive labor arrangement benefiting the Salvation Army financially. The plaintiffs included both individuals who voluntarily enrolled in the program and those referred by courts or parole/probation departments.The United States District Court for the Northern District of Illinois dismissed the plaintiffs' claims. The court found that the justice-referred plaintiffs' claims were barred by the Rooker-Feldman doctrine, as they were allegedly compelled to participate by state court orders. For the walk-in plaintiffs, the court concluded that the threats of losing food, clothing, and shelter were not sufficiently serious to constitute forced labor under federal law. The court also found that the plaintiffs failed to allege that the Salvation Army acted with the requisite intent to compel labor through threats of serious harm. The district court denied the plaintiffs' request to amend their complaint, leading to an immediate entry of judgment for the Salvation Army.The United States Court of Appeals for the Seventh Circuit affirmed the district court's judgment. The appellate court held that the Rooker-Feldman doctrine did not bar the justice-referred plaintiffs' claims, as their participation was not compelled by state court orders but by parole or probation officers. However, the court found that the plaintiffs' allegations did not plausibly indicate that the Salvation Army violated the forced labor provisions. The walk-in plaintiffs were free to leave the program at any time, and the justice-referred plaintiffs did not adequately demonstrate how the conditions of their participation constituted forced labor. The court also agreed that the proposed second amended complaint would not cure the deficiencies of the original complaint. View "Taylor v. The Salvation Army National Corporation" on Justia Law

Donald Reynolds began a 60-month term of supervised release in 2020 after serving a lengthy prison sentence. During his supervision, he tested positive for methamphetamine twice. Despite efforts by the United States Probation Office to help him access drug treatment services, Reynolds failed to participate in the recommended programs. Consequently, the Probation Office petitioned to revoke his supervised release. At the revocation hearing, Reynolds admitted to violating his release conditions, and the district court revoked his supervised release, sentencing him to 21 months of custody.The United States District Court for the Northern District of Indiana initially handled the case. After Reynolds tested positive for methamphetamine, the Probation Office referred him to a recovery center. When he tested positive again, an intensive outpatient program was recommended, but Reynolds did not comply. The Probation Office then petitioned for revocation. A magistrate judge ordered Reynolds to participate in an inpatient drug treatment program, but he struggled with obtaining his mental health medications and attempted suicide. After leaving the treatment facility without permission, he was arrested.The United States Court of Appeals for the Seventh Circuit reviewed the case. Reynolds argued that the district court erred by not recognizing its discretion to consider substance abuse treatment as an alternative to revocation and incarceration. The appellate court affirmed the district court's decision, noting that even if the district court had realized its discretion under 18 U.S.C. § 3583(d), it would not have opted for further treatment given Reynolds's history of noncompliance. The court concluded that any error in the district court's understanding of its discretion was harmless, as the outcome would have been the same. View "United States v. Reynolds" on Justia Law

The case involves the crash of Lion Air Flight JT 610, a Boeing 737 MAX, which took off from Jakarta, Indonesia, and crashed into the Java Sea on October 29, 2018, killing all on board. The plaintiffs are family members and representatives of the estates of two passengers, Liu Chandra and Andrea Manfredi. They filed lawsuits against Boeing and other defendants, seeking damages under various legal theories, including the Death on the High Seas Act (DOHSA), state law, and other federal statutes.The Chandra case was initially filed in Illinois state court and then removed to the United States District Court for the Northern District of Illinois. The Manfredi case was filed directly in the same federal court. Both sets of plaintiffs demanded a jury trial and asserted claims under DOHSA, state law, and other federal statutes. Boeing filed motions to limit the plaintiffs' claims to DOHSA and to preclude a jury trial. The district court ruled in favor of Boeing, holding that DOHSA was the exclusive remedy and that the plaintiffs were not entitled to a jury trial. The court dismissed all non-DOHSA claims and certified the jury trial issue for interlocutory appeal.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's rulings, holding that DOHSA preempts all other claims and mandates a bench trial. The court reasoned that DOHSA's language and legislative history indicate that claims under the statute must be brought in admiralty, which does not carry the right to a jury trial. The court also noted that Congress has not amended DOHSA to allow for jury trials in federal court, despite longstanding judicial interpretations to the contrary. Therefore, the plaintiffs' claims must proceed without a jury. The court's decision was to affirm the district court's rulings. View "Buehler v. Boeing Company" on Justia Law

A family of six Mexican citizens entered the United States without authorization and were subsequently placed in removal proceedings. They hired an attorney to help them apply for asylum. Despite having nearly fifteen months to prepare, the attorney requested a continuance only eight days before the hearing, citing the government shutdown as a reason for her lack of preparation. The Immigration Judge (IJ) denied the continuance and, due to the attorney's unpreparedness, deemed the asylum applications abandoned, ordering the family's removal. The Board of Immigration Appeals (BIA) affirmed the IJ's decision.The family appealed to the United States Court of Appeals for the Seventh Circuit. The court dismissed the cases of two family members due to lack of jurisdiction, as their removal proceedings had been terminated after they received special immigrant status. The remaining four family members argued that the IJ erred in denying the continuance and that their attorney was ineffective. The court found that the IJ did not abuse his discretion in denying the continuance, as the attorney had ample time to prepare and failed to do so. The court also noted that the attorney's unpreparedness did not violate the family's due process rights.Regarding the ineffective assistance of counsel claim, the court acknowledged the attorney's failure to prepare but noted that the family did not present this claim to the BIA, thus failing to exhaust administrative remedies. Consequently, the court could not consider the ineffective assistance claim. The court suggested that the family could seek to reopen the proceedings through a motion to reopen or by requesting equitable tolling of the deadline.The United States Court of Appeals for the Seventh Circuit dismissed the petitions of two family members and denied the petitions for review of the remaining four family members. View "Bustos-Millan v. Garland" on Justia Law

AXIS Insurance Company sought indemnification from American Specialty Insurance & Risk Services for claims AXIS settled, based on a contract between the two parties. The contract did not require AXIS to offer American Specialty the choice to approve the settlement or assume the defense. However, American Specialty argued that Indiana law imposed such an obligation. The district court agreed with American Specialty and granted summary judgment in its favor.The United States District Court for the Northern District of Indiana found that AXIS's settlement payment was voluntary because AXIS did not give American Specialty the opportunity to approve the settlement or assume the defense. The court concluded that AXIS had to show actual liability on the underlying claim to seek indemnification, which AXIS could not do. Therefore, the district court ruled that American Specialty had no duty to indemnify AXIS for the settlement payment.The United States Court of Appeals for the Seventh Circuit reviewed the case and reversed the district court's decision. The appellate court held that the contract did not require AXIS to tender the defense to American Specialty before settling claims. The court also found that Indiana law does not imply such a requirement in indemnification agreements. The Seventh Circuit concluded that AXIS was not obliged to offer American Specialty the opportunity to approve the settlement or assume the defense as a condition precedent to indemnification. The case was remanded for further proceedings consistent with this opinion. View "Axis Insurance Company v. American Specialty Insurance & Risk Services" on Justia Law

The plaintiff, Word Seed Church, now known as Grace Fellowship Covenant Church, sought to establish a permanent location in the Village of Hazel Crest but faced difficulties due to the village's zoning ordinance. The church claimed that the ordinance discriminated against religious assemblies by not listing churches as a permitted use in any zoning district and requiring a special use permit for churches in certain residential districts. The church argued that this process was burdensome and discriminatory, violating the Equal Protection Clause and the Religious Land Use and Institutionalized Persons Act (RLUIPA).The United States District Court for the Northern District of Illinois initially denied the church's motion for a preliminary injunction, finding that the church had standing but was unlikely to succeed on the merits. Later, the district court granted summary judgment in favor of the village, concluding that the church did not have a property interest in Hazel Crest and had not shown that comparable secular organizations were treated more favorably. The court also rejected the church's vagueness challenge to the zoning ordinance. The church did not appeal the summary judgment but instead filed a Rule 60(b) motion for relief from judgment, arguing that the district court had evaluated the wrong version of the zoning ordinance. The district court denied this motion.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's denial of the Rule 60(b) motion. The appellate court found that the district court did not abuse its discretion in its decision. The court noted that the church's argument regarding the zoning ordinance amendments was not raised during the summary judgment proceedings and that the church had waived any challenge to the B-2 district, which was affected by the 2008 amendment. The appellate court concluded that the church's difficulties in finding a property were due to the lack of suitable parcels, not the zoning ordinance. View "Word Seed Church v. Village of Hazel Crest" on Justia Law

The FBI conducted an investigation into a dark-web child pornography website called "Playpen." In 2015, the FBI took control of the website's servers and obtained a warrant to deploy a Network Investigative Technique (NIT) to identify users. Donald Dorosheff, a resident of Springfield, Illinois, was identified as a user and subsequently charged with receiving and possessing child pornography. Dorosheff sought to suppress the evidence obtained from his digital devices, arguing that the magistrate judge who issued the NIT warrant lacked authority under Rule 41 of the Federal Rules of Criminal Procedure to authorize an extraterritorial electronic search.The United States District Court for the Central District of Illinois agreed that the magistrate judge exceeded her authority under Rule 41 but applied the good-faith exception and declined to suppress the evidence. The court found that the officers acted in an objectively reasonable manner in relying on the magistrate judge's assessment of the law. Dorosheff's motion for reconsideration and a second suppression motion, which argued that high-ranking Department of Justice officials knew the warrant was invalid, were both denied.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 good-faith exception to the exclusionary rule applied because the agents involved acted reasonably in relying on the magistrate judge's determination of her authority. The court rejected Dorosheff's argument that the DOJ's advocacy for an amendment to Rule 41 indicated knowledge of the warrant's invalidity, noting that the amendment was an attempt to clarify the rule's application to new circumstances. The court concluded that the benefits of suppression did not outweigh its costs, as the case did not involve deliberately culpable police conduct. The decision of the district court was affirmed. View "USA v. Dorosheff" on Justia Law

Timothy Upchurch engaged in a prolonged campaign of harassment against his neighbors, Timothy and Margaret O’Brien, over a disputed easement on their property. Upchurch was convicted of disorderly conduct, criminal damage to property, and theft after trespassing and stealing a security camera from the O’Briens. In retaliation, Upchurch filed a baseless RICO lawsuit against the O’Briens, their lawyer, the local district attorney, and three sheriff’s deputies, alleging interference with his claimed easement. The lawsuit was frivolous as Upchurch did not own an easement. Facing sanctions motions, Upchurch dropped the case, but the district judge awarded sanctions, ordering Upchurch and his attorney, Timothy Provis, to pay the defendants’ costs and attorney’s fees.The United States District Court for the Western District of Wisconsin handled the initial case. The court found Upchurch’s lawsuit to be without merit and filed for the purpose of harassment. The judge imposed sanctions under Rules 11 and 37 of the Federal Rules of Civil Procedure due to the baseless nature of the claims and Upchurch’s failure to comply with discovery obligations. Upchurch and his attorney were ordered to pay the defendants’ costs and attorney’s fees, and Provis was required to disgorge any fees paid by Upchurch.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court dismissed Upchurch’s appeal for lack of jurisdiction, as the notice of appeal was filed outside the 30-day statutory deadline. The court also found the appeal to be frivolous and granted the defendants’ motion for sanctions under Rule 38 of the Federal Rules of Appellate Procedure. The court held that Upchurch and Provis were jointly and severally liable for the costs and reasonable attorney’s fees incurred in defending the appeal. The court directed the O’Briens and Lucareli to submit an accounting of their fees and costs within 15 days. View "Upchurch v. O'Brien" on Justia Law

Lanlan Li, a 51-year-old woman of Chinese descent, worked as a senior scientist at Fresenius Kabi USA, LLC. In 2019, she developed back pain and eye strain, which led her to take various types of leave. Despite accommodations, her back injury persisted, and she could not return to her position. Consequently, Fresenius terminated her employment. Li sued the company for disability discrimination, retaliation, and failure to accommodate under the Americans with Disabilities Act (ADA) and the Illinois Human Rights Act (IHRA), as well as for national origin and age discrimination under Title VII and the Age Discrimination in Employment Act (ADEA).The United States District Court for the Northern District of Illinois granted summary judgment in favor of Fresenius on all claims. The court found that Li failed to exhaust her administrative remedies for her age and national origin claims, as she did not include a right-to-sue letter from the Equal Employment Opportunity Commission (EEOC) or the Illinois Department of Human Rights (IDHR). The court also held that her disability and retaliation claims failed on the merits, noting that Li was not a qualified individual under the ADA because she could not perform the essential functions of her job, including bench work.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court agreed that Li was not a qualified individual under the ADA and that Fresenius had provided reasonable accommodations. The court also found that Li failed to present evidence of age or national origin discrimination and that her retaliation claim lacked a causal connection between her EEOC charges and her termination. Therefore, the court upheld the summary judgment in favor of Fresenius. View "Li v. Fresenius Kabi USA, LLC" on Justia Law