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

The Seventh Circuit affirmed the order of the district court granting summary judgment to Defendants and dismissing Plaintiffs' claims that three police officers unlawfully stopped, searched, and arrested them in violation of their First and Fourth Amendment rights, holding that Plaintiffs could not prevail on the merits of any of their claims.The three plaintiffs in this case were arrested after following a woman home and confronting her, but the District Attorney's office declined to pursue criminal charges. Plaintiff brought this action under 42 U.S.C. 1983 against the arresting officers. The district court granted summary judgment to Defendants. The Seventh Circuit affirmed, holding (1) the officers had reasonable suspicion for the initial stop and probable cause to arrest, and therefore, Plaintiffs' Fourth Amendment claims failed; and (2) Plaintiffs were not engaged in constitutionally-protected speech, and therefore, their First Amendment retaliation claim failed. View "Lyberger v. Snider" on Justia Law

The Seventh Circuit affirmed the judgment of the district court dismissing this action challenging the conduct of the Lake County Election Board, holding that the Election Board did not violate Joseph Hero's First and Fourteenth Amendment rights.Hero, a registered republican for forty years, opposed the decision of his town council to exercise its eminent-domain authority to seize the property of predominantly lower-income homeowners. Hero backed two independent candidates for town council running against two incumbent, pro-development candidates. Thereafter, the Indiana Republican Party banned Hero from the Republican Party for ten years. In 2019, Hero attempted to appear as a Republican candidate in the 2019 election, but the Election Board concluded that Hero could not run. Hero subsequently filed a complaint arguing that the Election Board violated his First and Fourteenth Amendment rights. The district court dismissed for lack of standing. The Seventh Circuit affirmed, holding (1) Hero had standing to sue; and (2) the Election Board did not violate Hero's constitutional rights. View "Hero v. Lake County Election Bd." on Justia Law

The Seventh Circuit held that district courts may make the decision whether to recruit counsel for an otherwise pro se litigant under 28 U.S. 1915(e)(1) based, in part, on considerations of the strength or weakness of the underlying claims, in keeping with the practical approach of Pruitt and mindful that pro bono lawyers are not a limitless resource.Plaintiff, a federal inmate, sued Defendants after he developed glaucoma. On four occasions, Plaintiff invoked section 1915(e)(1), asking the district to recruit pro bono counsel to represent him. The district court eventually entered summary judgment for Defendants and refused to recruit counsel under the statute. The Seventh Circuit affirmed, holding (1) the district court's conclusion that Plaintiff's likelihood of success on his negligence claims was too remote to warrant marshaling legal and expert resources toward his case was wholly consistent with the Pruitt framework; and (2) none of Plaintiff's other arguments on appeal lacked merit. View "Watts v. Kidman" on Justia Law

The Seventh Circuit affirmed Defendants' convictions for arson stemming from their participation in riots in Madison, Wisconsin following the shooting of a Black man by a police officer in Kenosha, Wisconsin, holding that the district court properly held that 18 U.S.C. 844(i) is constitutional.Defendants Willie Johnson and Anessa Fierro moved to dismiss the indictment against them, arguing that the federal arson statute is facially unconstitutional because its enactment exceeded Congress's authority under the Commerce Clause. The district court denied the motion, after which Defendants entered into conditional plea agreements. The Seventh Circuit affirmed, holding that section 844(i) was validly enacted pursuant to Congress's authority under the Commerce Clause. View "United States v. Fierro" on Justia Law

The Seventh Circuit affirmed the decision of the district court entering summary judgment to Defendants and dismissing this complaint brought by Plaintiff, the former general counsel for Chicago State University, holding that the district court did not abuse its discretion in its rulings.Plaintiff brought this action under 42 U.S.C. 1983 against several University defendants alleging that the University fired him in retaliation for reporting a potential conflict of interest in violation of the First Amendment and Illinois's State Officials and Employees Ethics Act and that Defendants violated his due process rights under the Fourteenth Amendment by not paying him severance pay. The district court entered summary judgment for Defendants. The Seventh District affirmed, holding that Plaintiff's actions fell outside the Ethics Act and that Plaintiff's speech lacked protection under the First Amendment. View "Cage v. Harper" on Justia Law

The Seventh Circuit affirmed the judgment of the district court dismissing this complaint alleging that certain patents related to the medicine Humira and the settlement of litigation about them violated sections one and two of the Sherman Antitrust Act, 15 U.S.C. 1 & 2, holding that dismissal was proper.At the end of 2016, the basic U.S. patient for Humira, a monoclonal antibody, expired. AbbVie, Humira's owner, obtained 132 additional patents related to the medicine for issues such as manufacturing or administering the drug, the last of which expires in 2034. Plaintiffs, welfare-benefit plans that paid for Humira on behalf of covered beneficiaries, brought this complaint alleging that AbbVie violated the Sherman Act by obtaining the 132 patents. The district court dismissed the complaint. The Seventh Circuit affirmed, holding that Plaintiffs failed to state a claim under the Sherman Act. View "Mayor & City Council of Baltimore v. AbbVie Inc." on Justia Law

The Seventh District remanded this case brought under the Endangered Species Act's citizen-suit provision, 16 U.S.C. 1540(g)(1), for mistreatment of endangered and threatened animals at a Wisconsin private zoo for an award of reasonable attorney fees and costs, holding that the district court's stated reasons were insufficient to deny statutorily-recoverable expenses.The Animal Legal Defense Fund (ALDF) sued Special Memories Zoo and its owners and manager (collectively, Defendants) alleging that the conditions of the endangered and threatened animals' confinement constituted an unlawful "take" under the Act. Defendants first defended the action then intentionally defaulted. After the trial court entered default judgment for ALDF ALDF moved for an award of attorney's fees and costs under 16 U.S.C. 1540(g)(4). The trial court denied the motion. The Seventh District vacated the decision below, holding that the court's reasons were insufficient to justify denying fees when weighed against the purpose and structure of the Act. View "Animal Legal Defense Fund v. Special Memories Zoo LLC" on Justia Law

In this putative class action filed shortly after two fatal crashes of new Boeing 737 MAX airliners led to a worldwide grounding of those planes and a halt to production, resulting to a significant drop in the value of Boeing stock, the Seventh Circuit affirmed the judgment of the district court granting Defendants' motion to dismiss under Fed. R. Civ. P. 12(b)(6), holding that there was no error.At issue was The Boeing Company's employee stock ownership plan (ESOP) and whether Boeing plan fiduciaries' delegation to an independent outside fiduciary the selection and management of investment options for the ESOP protected the company and company insiders from liability for the plan's continued offering of Boeing stock as an independent option for employees before and during the time when the Boeing stock dropped. Plaintiffs argued that Boeing's continuous concealment of material facts relating to the 737 MAX jets caused the price of the stock to be artificially inflated and that Defendants should disclosed the safety issues to the public immediately. The district court dismissed the action. The Seventh District affirmed, holding that the delegation of investment decisions to an independent fiduciary meant that Boeing did not act in an ERISA fiduciary capacity in connection with the continued investments in Boeing stock. View "Burke v. Boeing Co." on Justia Law

The Seventh Circuit reversed the judgment of the district court in this (Cooper II) lawsuit brought by Jack Cooper against Retrieval-Masters Creditors Bureau (RMCB) asserting an additional violation of the Fair Debt Collection Practices Act (FDCPA) arising out of the same debt that was the subject of an appeal in a separate civil action between the same parties (Cooper I), holding that the sanctions award was improper.Plaintiff sued RMCB alleging that a letter from RMCB he received seeking to collect a consumer debt violated the FDCPA. Plaintiff then filed this separate action against RMCB claiming additional violations of the FDCPA arising from the same debt. RMCB filed a motion to dismiss the Cooper II complaint, arguing that it was improper claim splitting. The trial court dismissed the action with prejudice. Thereafter, RMCB moved for sanctions. The court granted the motion in part and imposed sanctions on two lawyers and their firm. The Seventh Circuit reversed, holding that the district court's stated grounds for imposing monetary sanctions against counsel did not support the sanctions. View "Cooper v. Retrieval Masters Creditors" on Justia Law

The Seventh Circuit vacated the fee award entered by the district court in this dispute over attorney fee awards to prevailing plaintiffs under consumer-protection statutes where damages are modest and the plaintiff has rejected a substantial early settlement offer, holding that the fee award was an abuse of discretion.Plaintiff sued Defendant for violating the Fair Debt Collection Practices Act, 15 U.S. 1692 et seq., in attempting to collect a debt. The district court granted summary judgment to Plaintiff on liability and awarded Plaintiff $500. Plaintiff and his attorneys then sought an award of attorney fees and costs of more than $66,000. The district court awarded fees and costs of less than $8,000. The Seventh Circuit vacated the award, holding that the district court's refusal to grant any post-offer fees was an abuse of discretion. View "Cooper v. Retrieval-Masters Creditors Bureau, Inc." on Justia Law