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

Christian Arnold retained Binder & Binder in April 2018 to represent him in a claim for disability benefits under the Social Security Act. After the Commissioner of Social Security denied his claim, Arnold appealed to the district court, which remanded the case to the agency. An administrative law judge later determined Arnold was entitled to $160,797.10 in past-due benefits. Binder then moved for attorneys' fees under 42 U.S.C. § 406(b), seeking twenty-five percent of the retroactive benefits, amounting to $40,199.27. The district court awarded Binder $16,920, reducing the fee based on an effective hourly rate of $600.The United States District Court for the Central District of Illinois initially awarded Binder $16,920, despite the contingency fee agreement. Binder appealed, and the United States Court of Appeals for the Seventh Circuit held that the district court abused its discretion by not anchoring its reasonableness analysis on the contingency fee agreement. The case was remanded for further proceedings. On remand, the district court again awarded $16,920, maintaining that the contingency fee should be reduced to reflect a more reasonable effective hourly rate. Binder appealed once more.The United States Court of Appeals for the Seventh Circuit reviewed the case and found that the district court abused its discretion by inadequately explaining its decision to reduce Binder’s fees. The appellate court emphasized that the district court must begin with the contingency fee agreement and consider relevant factors, such as the plaintiff’s satisfaction and the attorney’s expertise. The appellate court reversed the district court’s decision and remanded with instructions to order the Social Security Administration to remit attorneys’ fees at Binder’s requested amount of $34,199.27. View "Arnold v. Bisignano" on Justia Law

Univar Solutions USA Inc. entered into a collective bargaining agreement (CBA) with Teamsters Local Union No. 283 in 2016, which required Univar to make pension contributions to a multiemployer pension fund. The CBA included an evergreen clause, automatically renewing the agreement annually unless either party provided notice of termination. In 2020, the parties extended the CBA by one year. Before the new expiration date, Univar sent a notice proposing modification or termination of the agreement and later entered a successor agreement allowing it to withdraw from the Fund and cease contributions. The Fund sued, claiming Univar's notice was too ambiguous to terminate the agreement.The United States District Court for the Northern District of Illinois ruled in favor of the Fund, finding that the 2020 extension did not prevent the CBA from automatically renewing under the evergreen clause. The court also found Univar's January 2021 letter insufficient to terminate the agreement, concluding that the CBA remained in effect through March 28, 2022. Consequently, the court granted summary judgment to the Fund, ordering Univar to pay the requested contributions and the Fund's legal fees.The United States Court of Appeals for the Seventh Circuit reviewed the case and disagreed with the district court's findings. The appellate court held that the 2020 extension did not nullify the evergreen clause and that Univar's January 2021 letter provided clear notice of its desire to terminate the CBA. The court concluded that Univar properly terminated the CBA before its expiration date, allowing it to cease contributions as per the successor agreement. The appellate court reversed the district court's summary judgment in favor of the Fund, vacated the award of attorneys' fees, and remanded the case. View "Central States Southeast and Southwest Areas Pensi v Univar Solutions USA Inc." on Justia Law

Donald Thorpe sought disability benefits, claiming that his health issues rendered him unable to work. The Administrative Law Judge (ALJ) denied his claim, relying on the testimony of a vocational expert. Thorpe appealed to the district court, which affirmed the ALJ’s decision, stating that Thorpe forfeited any challenge to the expert testimony by failing to object timely and that the decision was supported by substantial evidence.The district court found that Thorpe did not object to the vocational expert’s testimony during the hearing or in a post-hearing brief, thus forfeiting his right to challenge it. The court also determined that the ALJ’s decision was based on substantial evidence, including the expert’s testimony, which was consistent with the Dictionary of Occupational Titles (DOT) and supported by the expert’s qualifications and experience.The United States Court of Appeals for the Seventh Circuit reviewed the case and agreed with the district court. The court held that Thorpe forfeited his ability to challenge the expert’s testimony by not objecting during the hearing. The court also found that the ALJ’s decision was supported by substantial evidence, as the expert’s testimony had sufficient indicia of reliability, including consistency with the DOT and the expert’s qualifications.The Seventh Circuit affirmed the district court’s decision, concluding that the ALJ did not err in relying on the vocational expert’s testimony to determine that Thorpe was not disabled and could find other gainful employment. View "Thorpe v Bisignano" on Justia Law

Auston McLain exchanged sexually explicit messages with an undercover FBI agent posing as a fifteen-year-old boy named Codey. McLain drove from Iowa to Illinois to meet Codey, where he was arrested with condoms and a cell phone containing the messages. A jury convicted McLain of attempted enticement of a minor and traveling with intent to engage in illicit sexual activity.The United States District Court for the Central District of Illinois excluded McLain's expert witnesses and certain testimony he wished to give. The court also addressed objections to the prosecutor's closing argument remarks and a jury instruction. McLain appealed, arguing these decisions denied him a fair trial.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that the district court did not abuse its discretion in excluding the expert testimony, as it was not relevant to McLain's specific intent and could confuse the jury. The court also held that any error in excluding McLain's testimony about his past experiences was harmless, given the strong evidence against him. The prosecutor's remarks, while close to improper, did not deny McLain a fair trial. The jury instruction on intent was a correct statement of law and did not mislead the jury.The Seventh Circuit affirmed the district court's judgment, concluding that the cumulative effect of the alleged errors did not render the trial fundamentally unfair. The evidence overwhelmingly supported McLain's guilt, and none of the errors, individually or cumulatively, affected the verdict. View "United States v. McLain" on Justia Law

Dante Small faced charges of battery and two counts of attempted murder for hitting one police officer with a car and narrowly missing another. He claimed that his trial attorney misadvised him about his sentencing exposure, leading him to reject a plea offer and proceed to trial. An Illinois jury convicted him on all counts, and the trial judge sentenced him to the mandatory minimum of 40 years in prison. Small then sought federal habeas relief, alleging ineffective assistance of counsel.In the Circuit Court of Cook County, Illinois, Small's attorney indicated that Small wanted to negotiate a plea agreement. During a pretrial hearing, the prosecutor mentioned a 20-year plea offer, which was rejected. Small was ultimately convicted and sentenced to 40 years. He filed a pro se post-conviction petition, arguing that his counsel misinformed him about the sentencing range and that he would have accepted a plea if properly advised. The state trial court denied his petition, and the Appellate Court of Illinois affirmed, finding that the pretrial transcript contradicted Small's claims. The Supreme Court of Illinois denied his petition for leave to appeal.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that the state court made an unreasonable determination of fact by concluding that the pretrial transcript contradicted Small's claims about being misadvised on sentencing exposure. The Seventh Circuit held that Small was entitled to an evidentiary hearing to develop the factual record regarding his ineffective assistance of counsel claim. The court vacated the district court's order and remanded the case for an evidentiary hearing. View "Small v. Woods" on Justia Law

Robert Fletcher and Bartlow Gallery, Ltd. claimed that a painting depicting a desert scene with a pond was created by renowned artist Peter Doig while he was incarcerated in Canada in the 1970s. Fletcher alleged he purchased the painting from Doig for $100. Doig denied these claims, stating he was never incarcerated in Canada and did not create the painting. Fletcher and Bartlow sought a court declaration that Doig was the artist.The United States District Court for the Northern District of Illinois held a bench trial and found that the painting was not created by Peter Doig but by another individual named Peter Doige. The court entered judgment against Fletcher and Bartlow. Subsequently, Doig and other defendants filed a motion for sanctions against Fletcher, Bartlow, and their counsel, William Zieske, under Federal Rule of Civil Procedure 11 and 28 U.S.C. § 1927, arguing the case was litigated in bad faith. The district court granted the motion for sanctions.The United States Court of Appeals for the Seventh Circuit reviewed the case. Zieske appealed the sanctions, arguing that the district court's denial of summary judgment indicated the claims were not frivolous. The appellate court noted that the standards for summary judgment and sanctions are different, and the denial of summary judgment does not preclude sanctions if the claims later prove to be groundless. The appellate court found that the district court did not abuse its discretion in imposing sanctions, as the evidence overwhelmingly showed that Doig did not create the painting and that Fletcher, Bartlow, and Zieske should have known their claims were baseless by May 7, 2014. The appellate court affirmed the district court's award of sanctions and its judgment. View "Fletcher v Doig" on Justia Law

Donna Christensen, a twenty-year-old inmate at Vilas County Jail, died by suicide after twenty-five days in confinement. She had a history of substance abuse and mental illness and had previously reported suicidal thoughts and hallucinations. During her incarceration, she exhibited withdrawal symptoms and had an altercation with jail staff, leading to her placement on suicide watch. Despite her initial suicidal ideations, she was removed from suicide watch after a brief assessment by a social worker. She was later placed in solitary confinement, where she remained until her death.The Christensens, Donna's parents, sued Vilas County, the jail's medical service provider, and various employees, alleging that Donna's death resulted from inadequate medical treatment, excessive force, and due process violations. The United States District Court for the Western District of Wisconsin granted summary judgment in favor of the defendants, ruling against the Christensens. The court also denied the Christensens' requests to amend their complaint and extend deadlines for additional discovery.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the Christensens failed to present sufficient evidence to establish that the defendants were deliberately indifferent to Donna's serious medical condition under the Eighth Amendment. The court found no genuine dispute of material fact regarding the defendants' conduct and concluded that no reasonable jury could find in favor of the Christensens. The court also upheld the district court's denial of the Christensens' motions for additional discovery and to amend their complaint, finding no abuse of discretion in the lower court's case management decisions. View "Christensen v Weiss" on Justia Law

Edward Snukis was stopped by Officers Matthew Taylor and Trevor Koontz after a report of an impaired man refusing to leave a parking lot. The encounter escalated when Snukis resisted commands and struck Officer Koontz. Officer Taylor tased Snukis twice, and both officers pinned him to the ground, with Taylor striking Snukis in the head six times. After securing Snukis in handcuffs, the officers noticed he had lost consciousness and provided emergency assistance, but Snukis died later that evening. Snukis’s children, as co-administrators of his estate, sued the officers and the City of Evansville under 42 U.S.C. § 1983.The United States District Court for the Southern District of Indiana granted summary judgment in favor of the defendants. The estate appealed the decision, focusing on claims against the officers for excessive force, failure to intervene, and failure to render medical aid.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court held that the officers' use of force was reasonable given Snukis’s resistance and the threat he posed. The court found that Officer Taylor’s use of the taser and subsequent strikes were justified due to Snukis’s active resistance. The court also determined that the officers provided prompt and appropriate medical care once Snukis lost consciousness. Consequently, the court affirmed the district court’s grant of summary judgment in favor of the officers. View "Snukis v. Taylor" on Justia Law

David Swartz was charged with wire fraud and aiding and assisting the filing of a false tax return. He pleaded guilty to both counts. The probation department prepared a presentence investigation report (PSR) that incorrectly calculated Swartz's net worth. Despite Swartz's correction of his assets, the PSR did not update his net worth. At sentencing, the district court imposed a $10,000 fine, relying on the PSR's recommendations.Swartz objected to the PSR's net worth calculation and filed a memorandum noting the correct figure. The district court adopted the PSR's recommendations, including the fine, and ordered restitution and a special assessment. Swartz argued that the district court violated his due process rights by relying on inaccurate financial information and failed to comply with statutory requirements in imposing the fine.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that the district court did not rely on the incorrect net worth figure when imposing the fine. The district court considered Swartz's significant assets, limited liabilities, and positive monthly cash flow, which were accurately stated in the PSR. The court also found that the district court properly considered the relevant factors under 18 U.S.C. § 3572(a) and did not err in determining Swartz's ability to pay the fine.The Seventh Circuit held that the district court did not commit procedural error or violate Swartz's due process rights. The court affirmed the district court's judgment, including the imposition of the $10,000 fine. View "United States v. Swartz" on Justia Law

Christopher Pable, a software engineer with the Chicago Transit Authority (CTA), discovered a cybersecurity vulnerability in the BusTime system, which was developed by Clever Devices, Ltd. Pable reported the vulnerability to his supervisor, Mike Haynes, who tested it on another city's transit system. Clever Devices, which had a significant contract with the CTA, alerted the CTA about the incident, leading to the termination of Pable and Haynes. Pable then sued the CTA and Clever Devices under the National Transit Systems Security Act, alleging retaliation for whistleblowing.The United States District Court for the Northern District of Illinois dismissed Pable's complaint during the discovery phase, citing the deletion of evidence and misconduct by Pable's attorney, Timothy Duffy. The court also imposed monetary sanctions on both Pable and Duffy. The court found that Pable and Duffy had failed to preserve relevant electronically stored information (ESI) and had made misrepresentations during the discovery process.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the district court did not abuse its discretion in dismissing Pable's complaint under Federal Rule of Civil Procedure 37(e) due to the intentional spoliation of evidence. The court also upheld the monetary sanctions imposed under Rule 37(e), Rule 37(a)(5), and 28 U.S.C. § 1927, finding that Duffy's conduct unreasonably and vexatiously multiplied the proceedings. The appellate court declined to impose additional sanctions on appeal, concluding that the appeal was substantially justified. View "Christopher Pable v CTA" on Justia Law