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

Lisa Johnson and Gale Miller Anderson, former Amazon warehouse employees, alleged that Amazon violated federal and Illinois wage laws by not compensating them for time spent in mandatory pre-shift COVID-19 screenings. These screenings, which included temperature checks and symptom questions, took 10-15 minutes on average and were required before employees could clock in for their shifts. Johnson and Miller Anderson argued that this time should be compensable as it was necessary for their work and primarily benefited Amazon by ensuring a safe workplace during the pandemic.The United States District Court for the Northern District of Illinois dismissed their claims under the Fair Labor Standards Act (FLSA) and the Illinois Minimum Wage Law (IMWL). The court found that the FLSA claims were barred by the Portal-to-Portal Act of 1947 (PPA), which excludes certain pre-shift activities from compensable time. The district court also concluded that the IMWL claims failed because it assumed the IMWL incorporated the PPA’s exclusions.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether the IMWL incorporates the PPA’s exclusions for compensable time. The court noted the lack of Illinois state court decisions directly addressing this issue and found the arguments from both parties plausible. To resolve this important and unsettled question of state law, the Seventh Circuit decided to certify the question to the Illinois Supreme Court, seeking a definitive answer on whether the IMWL includes the PPA’s limitations on pre-shift compensation. The court stayed further proceedings pending the Illinois Supreme Court's decision. View "Johnson v. Amazon.com Services LLC" on Justia Law

James Reilly, a deputy in the Will County Sheriff's Office, alleged that his employer and Sheriff Michael Kelley retaliated against him for criticizing Kelley during a 2018 election campaign by not promoting him to sergeant. Reilly filed his complaint over two years after his eligibility for promotion expired. The defendants moved to dismiss the complaint, arguing it was untimely. The district court agreed, granted the motion to dismiss, and entered judgment in favor of the defendants. Reilly then requested the district court to set aside its judgment and allow him to amend his complaint, but the court denied this request, applying a heightened standard and requiring extraordinary circumstances for relief.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that the district court had mistakenly applied a heightened standard to Reilly's Rule 59(e) motion instead of the liberal standard for amending pleadings. The appellate court concluded that Reilly's proposed amended complaint stated a plausible claim for relief and that he had not pled himself out of court based on the statute of limitations. The court noted that Reilly's claim could not be conclusively determined as time-barred at this stage and that the defendants could raise the statute of limitations defense later in the case on a more complete factual record.The Seventh Circuit vacated the district court's judgment and remanded the case for further proceedings, allowing Reilly to proceed with his amended complaint. View "Reilly v Will County Sheriff's Office" on Justia Law

Several rail carriers challenged a Final Rule issued by the Surface Transportation Board (STB) that allows a railway shipper or receiver to request a "reciprocal switching agreement." This agreement requires a rail carrier with a monopoly over a certain rail line to compete with another carrier for specific rail traffic. The carriers argued that the Final Rule exceeded the STB's statutory authority under the Staggers Rail Act of 1980, which grants the agency authority to prescribe reciprocal switching. They also contended that aspects of the Final Rule exceeded the Board's ancillary powers and were arbitrary, capricious, and unsupported by the record.The STB issued the Final Rule after a notice-and-comment period, aiming to address service performance issues of Class I rail carriers, which were exacerbated by the COVID-19 pandemic. The Board held a hearing in April 2022 and required several Class I carriers to submit service recovery plans. Subsequently, the Board proposed new regulations to improve service by increasing competition, leading to the Final Rule. The rule establishes procedures for shippers or receivers to request reciprocal switching agreements if the incumbent carrier fails to meet certain performance standards.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the Final Rule exceeded the STB's statutory authority because it did not require a finding of inadequate service by the incumbent carrier before prescribing a reciprocal switching agreement. The court emphasized that the Staggers Rail Act requires such a finding to determine that a reciprocal switching agreement is "in the public interest." Consequently, the court granted the petition, vacated the Final Rule, and remanded the case to the STB for further proceedings. View "Grand Trunk Corporation v STB" on Justia Law

David Bourke, a disabled employee of the U.S. Department of Veterans Affairs (VA), was granted a reserved parking space near his workplace to accommodate his disability. However, during the COVID-19 pandemic, the VA implemented new measures that required employees to enter through designated entrances for screening, which made Bourke's reserved parking spot unusable. The VA offered Bourke an alternate parking space near Building 1, which included a secluded storage area for his mobility scooter. Bourke declined this accommodation, fearing his scooter could be stolen, and sued the VA under the Rehabilitation Act of 1973.The United States District Court for the Northern District of Illinois granted summary judgment in favor of the VA. The court found that the alternate accommodation offered by the VA was reasonable and that there was no significant risk of Bourke's scooter being stolen. The court also rejected Bourke's argument that the VA could not alter his accommodation in response to changing circumstances, such as the pandemic.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court held that the VA's alternate accommodation was reasonable, as it allowed Bourke to perform his job functions while complying with COVID-19 prevention measures. The court noted that an employer is not required to provide the specific accommodation requested by an employee, but rather a reasonable one. The court also found that the VA's actions did not violate the Rehabilitation Act, as the alternate accommodation was sufficient to meet Bourke's needs during the pandemic. Consequently, the Seventh Circuit affirmed the district court's grant of summary judgment in favor of the VA. View "Bourke v. Collins" on Justia Law

Michael Lairy petitioned for a writ of habeas corpus under 28 U.S.C. § 2255, arguing that he did not qualify for the Armed Career Criminal Act’s (ACCA) mandatory 15-year sentence and that his counsel was ineffective for not raising this issue. The government did not address the merits of Lairy’s claims but argued that they were raised after the statute of limitations had expired. The district court denied his petition, rejecting Lairy’s arguments that the government forfeited the statute of limitations defense, that he was actually innocent of ACCA, and that he was entitled to equitable tolling.The United States District Court for the Southern District of Indiana held that Lairy’s petition was untimely and that the government did not forfeit the statute of limitations defense. The court also found that Lairy’s claim of actual innocence did not apply because it was a legal, not factual, argument. Additionally, the court denied Lairy’s request for equitable tolling without conducting an evidentiary hearing.The United States Court of Appeals for the Seventh Circuit reviewed the case and agreed with the district court’s evaluation of forfeiture and actual innocence. However, the appellate court found that the district court abused its discretion by rejecting equitable tolling without first conducting an evidentiary hearing. The Seventh Circuit vacated the denial of the petition and remanded the case to the district court to conduct an evidentiary hearing on equitable tolling. The court affirmed the judgment in all other respects. View "Lairy v. United States" on Justia Law

Ruben Santoyo, proceeding without counsel, filed a lawsuit under 42 U.S.C. § 1983 against the City of Chicago and two police officers, challenging the constitutionality of his arrest. Over three years, Santoyo repeatedly filed frivolous motions, many of which attacked the competence and integrity of the district judge. Despite numerous warnings from the judge that further frivolous filings would result in sanctions, Santoyo continued his behavior.The United States District Court for the Northern District of Illinois granted summary judgment in favor of the defendants and denied Santoyo's motions to vacate the judgment. While Santoyo's appeal of the denial was pending, the defendants moved to recover their costs. Instead of addressing the merits of this motion, Santoyo accused the defendants of bad faith and requested disciplinary action against their counsel. The district judge, having lost patience, granted the defendants' motion for costs, imposed a $1,500 sanction on Santoyo, and referred him to the district's Executive Committee, which barred future filings until the sanction was paid.The United States Court of Appeals for the Seventh Circuit reviewed the case. Santoyo argued that the district judge violated his due process rights by not notifying him of the sanction or giving him an opportunity to respond. The appellate court disagreed, noting that Santoyo had been warned multiple times about the consequences of further frivolous filings. The court held that the district judge provided sufficient notice and opportunity for Santoyo to respond, satisfying due process requirements. The Seventh Circuit affirmed the district court's imposition of sanctions. View "Santoyo v. City of Chicago" on Justia Law

A group of nine plaintiffs, led by Alexander Carter, filed a class action lawsuit against the Cook County Sheriff, challenging a policy at the Cook County Jail that destroys inmates' government-issued identification cards if left unclaimed after the inmate is transferred to the Illinois Department of Corrections (IDOC). The plaintiffs argued that this policy violated the Fourth, Fifth, and Fourteenth Amendments of the Constitution. The district court dismissed the case, finding that precedent foreclosed each of the plaintiffs' claims.The United States District Court for the Northern District of Illinois granted the Sheriff’s motion to dismiss, concluding that the plaintiffs' Fourth Amendment claim was foreclosed by the precedent set in Lee v. City of Chicago. The court also found that the Fifth and Fourteenth Amendment claims were indistinguishable from those rejected in Conyers v. City of Chicago and Kelley-Lomax v. City of Chicago. The plaintiffs appealed the dismissal of their Fourth, Fifth, and Fourteenth Amendment substantive due process claims but did not appeal the procedural due process claim.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 Fourth Amendment claim was foreclosed by Lee, which rejected the notion of a "continuing seizure" of lawfully seized property. The court also found that the Fifth Amendment takings claim failed because the plaintiffs had abandoned their property by not following the jail's property retrieval procedures. Finally, the court concluded that the Fourteenth Amendment substantive due process claim failed because the plaintiffs did not show the inadequacy of state law remedies or an independent constitutional violation. View "Carter v. Cook County Sheriff" on Justia Law

A class member objected to the district court's award of attorney's fees in a class action antitrust litigation involving broiler chicken producers. The district court had awarded attorney's fees based on a hypothetical ex ante market for legal services, considering the risk of nonpayment and the normal rate of compensation at the litigation's outset. The objector argued that the district court included skewed fee awards in its calculation.Previously, the United States District Court for the Northern District of Illinois had awarded attorney's fees, but the objector, John Andren, successfully argued on appeal that the court erred by discounting certain auction bids and excluding fee awards from the Ninth Circuit. The Seventh Circuit remanded the case, instructing the district court to reconsider these factors. On remand, the district court awarded a new fee, excluding certain bids and Ninth Circuit awards, and giving significant weight to a specific fee agreement from a comparable case.The United States Court of Appeals for the Seventh Circuit reviewed the district court's revised fee award. The court found that the district court did not abuse its discretion in excluding certain bids and Ninth Circuit awards but erred in relying on a skewed sample of ex post awards. The Seventh Circuit adjusted the fee award by removing non-representative data points, resulting in a revised award of 26.6% of the net common fund. The court affirmed the district court's fee award as modified and remanded the case for further proceedings. View "Andren v End User Consumer Plaintiff Class" on Justia Law

Marissa Darlingh, a guidance counselor at an elementary school in the Milwaukee Public School District, attended a rally in April 2022 where she delivered a profanity-laden speech denouncing gender ideology and transgenderism. She identified herself as a school counselor and vowed that no student at her school would transition under her watch. After a video of her speech was posted on YouTube, school officials investigated and eventually fired her for violating employment policies, including using abusive language and undermining the district's mission to provide an equitable learning environment.The United States District Court for the Eastern District of Wisconsin, with a magistrate judge presiding, applied the Pickering balancing test and concluded that the school district's interests as a public employer outweighed Darlingh's speech rights. The judge denied her request for a preliminary injunction and dismissed her First Amendment claim.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the lower court's decision. The court held that while Darlingh spoke on a matter of public concern, her speech was incompatible with her role as a school counselor. The court emphasized that her extreme vulgarity and belligerent tone diminished her First Amendment interests. Additionally, her role required a high degree of public trust, and her speech conflicted with the school district's obligation to provide a supportive educational environment. The court concluded that the school district's interests outweighed Darlingh's free-speech rights, and her speech fell outside the scope of First Amendment protection in the public-employment context. View "Darlingh v Maddaleni" on Justia Law

Ferida H. Moy suffers from severe PTSD due to her experiences during the Yugoslav Wars. She applied for disability insurance benefits and supplemental security income, citing her PTSD and related mental health issues. An administrative law judge (ALJ) denied her application, finding that she had the residual functional capacity to perform simple, routine tasks with minimal contact with supervisors and co-workers. This decision was upheld by the district court, leading Moy to appeal.The ALJ found that Moy had moderate limitations in concentrating, persisting, or maintaining pace but concluded that she could work at a consistent production pace. The ALJ's decision was based on the testimony of a vocational expert who stated that a person with Moy's limitations could work as a dining room attendant, bus person, scrap sorter, industrial cleaner, or dishwasher. However, the vocational expert also testified that regular absences or being off-task for more than 15% of the workday would result in job loss. The ALJ's decision was affirmed by the district court.The United States Court of Appeals for the Seventh Circuit reviewed the case and found that the ALJ failed to build a logical bridge between Moy's limitations and the conclusion that she could work at a consistent production pace. The court noted that the ALJ's determination did not adequately account for Moy's limitations in concentration, persistence, and pace. The court emphasized that the ALJ's reasoning was internally inconsistent and did not reflect Moy's documented symptoms and treatment needs. Consequently, the Seventh Circuit vacated the judgment and remanded the case to the Commissioner of Social Security for further consideration consistent with its opinion. View "Moy v Bisignano" on Justia Law