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

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

Mesco Manufacturing, LLC ("Mesco") held a business insurance policy from Motorists Mutual Insurance Company ("Motorists Mutual") covering direct physical loss or damage caused by covered causes, including hail. After a storm in August 2018, Mesco claimed hail damage to its manufacturing facility roofs. Motorists Mutual initially adjusted the claim for $7,806.75, but Mesco disagreed and invoked the policy's appraisal provision. The appraisers selected an umpire who determined that the modified bitumen roofs were hail damaged, awarding $1,020,490.32 in replacement cost value. Motorists Mutual only paid $265,296.21, excluding the modified bitumen and EPDM roofs from the award.Mesco filed a complaint in the United States District Court for the Southern District of Indiana, alleging breach of contract and bad faith under Indiana law. The district court granted Mesco's motion for summary judgment, concluding that Motorists Mutual breached the contract by not paying the full appraisal award. The court relied on the precedent set in Villas at Winding Ridge v. State Farm Fire & Casualty Co., which held that a similar appraisal provision was binding and unambiguous. The court found no exceptional circumstances to set aside the appraisal award and denied Motorists Mutual's motion for reconsideration.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court affirmed the district court's judgment, holding that the appraisal award was binding and that Motorists Mutual breached the insurance contract by not paying the full award. The court determined that the appraisal process properly included determining the extent of hail damage, and Motorists Mutual's "right to deny" clause did not permit it to set aside the binding appraisal award. The court emphasized that the purpose of the appraisal process is to provide a speedy and inexpensive means of settling disputes. View "Mesco Manufacturing, LLC v. Motorists Mutual Insurance Co." on Justia Law

Timothy Upchurch, a Black man, has worked at the Indiana Department of Correction’s Correctional Industrial Facility (CIF) for over thirty years. He filed discrimination and retaliation claims under Title VII against the State of Indiana, challenging his demotion from Correctional Lieutenant to Officer, subsequent written reprimands, a suspension, and non-promotions. The district court substituted the Indiana Department of Correction for the State of Indiana as the defendant and granted summary judgment to the Department.The United States District Court for the Southern District of Indiana found insufficient evidence of race discrimination or retaliation to support Upchurch's claims. Upchurch appealed, challenging the substitution of the Department for the State as the defendant and the summary judgment decision.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court agreed with the district court that the Indiana Department of Correction was the proper defendant under Title VII, as it had actual hiring and firing responsibility. The court also reviewed the grant of summary judgment de novo, finding that the Department provided nondiscriminatory explanations for its actions, and Upchurch failed to show these explanations were pretextual. The court noted that Upchurch did not provide sufficient evidence to support his claims of race discrimination or retaliation, including failing to show that comparators were similarly situated or that the Department's actions were motivated by his race or complaints about discrimination.The Seventh Circuit affirmed the district court's judgment, concluding that no reasonable jury could find that race discrimination or retaliation motivated the adverse employment actions against Upchurch. View "Upchurch v. Indiana" on Justia Law

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