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

Several plaintiffs, including a truck driver and employees, alleged that their employers or associated companies collected their biometric data, such as fingerprints or hand geometry, without complying with the requirements of the Illinois Biometric Information Privacy Act (BIPA). Each plaintiff claimed that every instance of data collection constituted a separate violation, resulting in potentially massive statutory damages. Some claims were brought as class actions, raising the possibility of billions in liability for the defendants.In the United States District Court for the Northern District of Illinois, the district judges addressed whether a 2024 amendment to BIPA Section 20, which clarified that damages should be assessed per person rather than per scan, applied retroactively to cases pending when the amendment was enacted. The district courts determined that the amendment did not apply retroactively and certified this question for interlocutory appeal under 28 U.S.C. § 1292(b).The United States Court of Appeals for the Seventh Circuit reviewed the certified question de novo. The court considered Illinois’s established law of statutory retroactivity, which distinguishes between substantive and procedural (including remedial) changes. The Seventh Circuit held that the BIPA amendment was remedial because it addressed only the scope of available damages and did not alter the underlying substantive obligations or standards of liability. The court reasoned that, under Illinois law, remedial amendments apply to pending cases unless precluded by constitutional concerns, which were not present here.The Seventh Circuit concluded that the 2024 amendment to BIPA Section 20 applies retroactively to all pending cases. The court reversed the district courts’ rulings and remanded the cases for further proceedings consistent with its holding. View "Clay v Union Pacific Railroad Company" on Justia Law

A United States citizen originally from Yemen filed family-based visa petitions (Form I-130) in 2002 on behalf of several relatives, including his stepdaughter. The immigration authorities sent a notice of intent to deny these petitions and a subsequent denial letter to the address provided on the petition. The petitioner did not respond, and the petitions were denied. Twenty years later, the petitioner sued, asserting that he never received the notices because the agency had mistakenly sent them to an address where he did not live, and that this lack of notice violated the Due Process Clause and the Administrative Procedure Act. He attached a redacted version of his petition to his complaint, omitting the address at issue.The United States District Court for the Northern District of Illinois, Eastern Division, initially denied the government’s motion to dismiss, finding that the complaint plausibly supported the application of the discovery rule or equitable tolling and otherwise stated a claim. However, when the government moved for judgment on the pleadings and submitted an unredacted copy of the I-130 petition showing that the petitioner himself had listed the very address to which the notices were sent, the court found this document dispositive. The petitioner did not meaningfully contest the authenticity or content of the unredacted petition, failed to appear at the hearing, and did not object to the government’s supporting affidavit.On appeal, the United States Court of Appeals for the Seventh Circuit held that the unredacted I-130 petition conclusively refuted the petitioner’s factual claims. The court held that when a plaintiff’s own incorporated documents contradict the complaint’s allegations, those documents control. The court affirmed the district court’s entry of judgment for the government, finding that the due process and APA claims failed as a matter of law. View "Muthana v Mullin" on Justia Law

A trademark holder brought an action against numerous foreign online vendors, alleging that they infringed her registered mark by selling counterfeit goods through e-commerce platforms such as Walmart.com and eBay.com. The vendors, all based in China, operated online storefronts that were accessible from the United States and offered shipping to U.S. customers, including those in Illinois. The plaintiff attached a “Schedule A” list to her complaint identifying the vendors. The defendants did not initially appear in the case.The United States District Court for the Northern District of Illinois, Eastern Division, entered a default judgment against the defendants. The court found personal jurisdiction over them on the basis that they operated online stores targeting U.S. consumers, offered shipping to Illinois, and had allegedly sold infringing products to Illinois residents. The evidence supporting the finding of Illinois sales included website screenshots showing that a product could be ordered and shipped to a Chicago address, but did not show that any actual sales to Illinois occurred. After the default judgment, the defendants appeared and moved to vacate the judgment, arguing lack of personal jurisdiction and improper service. The district court denied the motion, reaffirming its prior findings.Upon appeal, the United States Court of Appeals for the Seventh Circuit found that there was no evidence of any actual sales to Illinois residents. The court held that merely operating an online store accessible in Illinois and offering shipping to Illinois, without completed sales in the forum, is insufficient to establish personal jurisdiction. The district court’s findings to the contrary were clearly erroneous. The Seventh Circuit vacated the default judgment and remanded the case with instructions to dismiss for lack of personal jurisdiction. View "Liu v. Monthly" on Justia Law

Two Illinois residents obtained online loans of $600 each from a lender operating under the laws of the Otoe-Missouria Tribe of Indians, with interest rates approaching 500% per year. The loan agreements included an arbitration clause, which delegated to the arbitrator all questions including the enforceability and formation of the agreement, specifying that such issues would be determined under “tribal law and applicable federal law.” At the time the loans were issued, the referenced tribal law did not exist.After receiving the loans, the borrowers filed a putative class action in the United States District Court for the Northern District of Illinois, alleging violations of Illinois consumer-protection statutes and federal laws. The defendants moved to compel arbitration under the terms of the loan agreements. The district court denied the motion, finding that the arbitration and delegation provisions were unenforceable because they effectively forced the plaintiffs to waive their substantive rights under Illinois law, applying the “prospective waiver” doctrine.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s denial de novo. The Seventh Circuit affirmed, holding that there was no mutual assent to the arbitration and delegation provisions. The court determined that, at the time of contracting, the specified tribal law did not exist, and federal law does not supply substantive contract-formation rules. Because the contract’s governing law provision referred to a body of law that was nonexistent and subject to unilateral creation by the defendants’ affiliate, there was no meeting of the minds as to an essential term. The Seventh Circuit concluded that the absence of mutual assent rendered the arbitration and delegation provisions unenforceable and affirmed the district court’s order denying the motion to compel arbitration. View "Harris v W6LS, Inc." on Justia Law

The petitioner was convicted of two separate murders in Indiana and sentenced to death for each. He unsuccessfully challenged his convictions and sentences in Indiana’s courts, including direct appeals and post-conviction proceedings, with the Indiana Supreme Court affirming the outcomes. After the Supreme Court of the United States denied review, the petitioner’s deadline to seek federal habeas corpus relief under 28 U.S.C. § 2254 expired in February 2021. Despite being represented by counsel appointed during the COVID-19 pandemic, communication difficulties and alleged mental health issues were cited as reasons for the late filing of his federal petition, which was submitted two years past the deadline.Following the late filing, the State moved to dismiss the petition as untimely. The petitioner argued for equitable tolling, claiming extraordinary circumstances prevented timely filing and requested discovery and an evidentiary hearing to support this claim. As part of the process, he also sought an order under the All Writs Act to be transported to a hospital for brain scans to support his argument regarding his mental health limitations.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s order granting the transportation request. The appellate court held that, under Shoop v. Twyford, a transportation order for evidence-gathering is warranted only if there is a demonstrated nexus between the sought evidence and its admissibility or relevance to a particular claim for relief. The court found that the petitioner failed to establish how the requested brain scans would be relevant or admissible in support of equitable tolling. Therefore, the Seventh Circuit reversed the district court’s transportation order and remanded the case for further proceedings. View "Gibson v. Neal" on Justia Law

Several landowners in Indiana, who acquired their properties subject to agreements made in 1959, sought to enroll their land in a federal conservation program. During the process, a title examination revealed that Trunkline Gas Company held easements over their properties, allowing it to construct and maintain pipelines. The landowners contended that Trunkline’s easement was limited to a fixed 66-foot corridor along the existing pipeline, which had been installed in 1960. Trunkline, however, asserted that the original agreements granted it rights to lay additional pipelines anywhere on the properties and to alter the route of the existing pipeline.The landowners filed suit in the United States District Court for the Northern District of Indiana, seeking a declaration that Trunkline’s easement was fixed and limited in scope. Trunkline counterclaimed, seeking confirmation of its broader, unexercised rights. The district court divided the litigation into two phases and, in both, granted partial summary judgment in Trunkline’s favor. The court concluded that the 1959 agreements created a floating or blanket easement, meaning the location for future pipelines was not fixed, and that Indiana law did not allow unexercised, future easement rights to be fixed to a defined location.On appeal, the landowners asked the United States Court of Appeals for the Seventh Circuit to certify a question to the Indiana Supreme Court regarding the fixity of floating easements, or, alternatively, to reverse the district court. The Seventh Circuit declined to certify, finding Indiana law sufficiently clear that unexercised, future rights under a floating easement are not fixed. The court affirmed the district court’s summary judgment, holding that Trunkline’s unexercised easement rights remain unfixed under Indiana law. View "Close Armstrong, LLC v Trunkline Gas Company, LLC" on Justia Law

Three individuals entered an apartment in Plover, Wisconsin, and committed an armed robbery, physically assaulting the two residents and stealing electronics and guitars. Two of the robbers, Lyndell Dale and Archie Biddell, were apprehended shortly after and implicated Maurice Holt as the third participant. Initially, the victims identified Gosha, Holt’s nephew, as the third assailant, but later expressed uncertainty. Two days after the robbery, Holt sold some of the stolen guitars, using his real name. A search of Holt’s residence, which Gosha frequented, yielded additional stolen property. Holt denied involvement and claimed he was elsewhere during the crime.Holt was tried in Wisconsin state court on charges including armed robbery. The prosecution relied on the sale of stolen items, pretrial identifications by Dale and Biddell, and circumstantial evidence. Neither victim could positively identify Holt at trial. Holt’s defense was twofold: that Gosha was the third robber, and that Holt had an alibi. Holt’s counsel attempted to introduce photographs to support the defense theory, but the trial court excluded them as irrelevant and cumulative. Holt was convicted on all counts and sentenced to twelve years. He pursued post-conviction relief, arguing the exclusion of evidence and ineffective assistance of counsel. The state post-conviction court and the Wisconsin Court of Appeals denied his claims, and the Wisconsin Supreme Court declined review.Holt sought habeas relief in the United States District Court for the Western District of Wisconsin, which granted his petition. On appeal, the United States Court of Appeals for the Seventh Circuit reversed. The Seventh Circuit held that the Wisconsin Court of Appeals reasonably applied Supreme Court precedent in rejecting Holt’s constitutional claims regarding exclusion of evidence and ineffective assistance of counsel. The court concluded that any errors did not have a substantial and injurious effect on the verdict and did not warrant habeas relief. View "Holt v. Boughton" on Justia Law

A Polish citizen was approved for an immigrant visa in 2009 based on a petition filed by her U.S. citizen sister. While awaiting visa availability, she remained in the United States unlawfully for over a year, making her inadmissible and subject to a ten-year bar from reentering the country. In 2020, her mother, a lawful permanent resident, died. She then applied for a waiver of her inadmissibility, citing her mother’s death as the qualifying hardship, and sought relief under a statutory provision that allows certain applications to proceed despite the death of a qualifying relative.The United States Citizenship and Immigration Services (USCIS) denied her waiver application, explaining that the relevant policy only applies if the deceased relative had been the qualifying petitioner for the underlying visa, which in her case was her sister, not her mother. Attempts to reopen or reconsider the decision were also denied. She then sought relief in the United States District Court for the Northern District of Illinois, requesting a declaratory judgment on her eligibility and challenging the agency’s decision under the Administrative Procedure Act (APA). The district court dismissed her case for lack of subject-matter jurisdiction, finding that the relevant immigration statutes precluded judicial review of the agency’s waiver decisions.Upon appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The court held that the statute unequivocally bars judicial review of all agency decisions regarding waivers of inadmissibility, including eligibility determinations, and that such decisions are committed to agency discretion. The presumption of reviewability under the APA was rebutted by the statute's clear jurisdiction-stripping language. The court also publicly admonished the plaintiff’s attorney for including fictitious citations in the appellate brief but imposed no further sanctions. View "Dec v Mullin" on Justia Law

Paul Daugerdas was convicted in federal court for orchestrating a fraudulent tax shelter scheme that defrauded the U.S. Treasury of significant tax revenue. A jury found him guilty of conspiracy to defraud the IRS, mail fraud, client tax evasion, and obstructing the internal revenue laws. The federal district court sentenced him to 15 years in prison, ordered forfeiture of $164.7 million, and imposed $371 million in restitution, to be paid jointly and severally with co-conspirators. The criminal restitution order set a payment schedule of 10% of Daugerdas’s gross monthly income following his release from prison.After the United States Court of Appeals for the Second Circuit affirmed the convictions and sentence, the Internal Revenue Service, relying on 26 U.S.C. § 6201(a)(4)(A), assessed the same $371 million restitution as a civil tax liability, making the entire amount immediately due. The IRS also filed a notice of federal tax lien against Daugerdas’s property in Illinois. Daugerdas challenged the IRS’s authority to impose and collect restitution in this manner, particularly objecting to the acceleration of the payment schedule. The United States Tax Court upheld the IRS’s actions, ruling that the statutory provision authorized the IRS to assess and collect restitution for tax-related offenses, even when the underlying criminal conviction was under Title 18 rather than Title 26.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the Tax Court’s judgment de novo. The court held that 26 U.S.C. § 6201(a)(4)(A) empowers the IRS to assess and collect restitution ordered under 18 U.S.C. § 3556 for tax-related crimes, including those prosecuted under Title 18, and that the IRS is not bound by the payment schedule set by the criminal court. The Seventh Circuit affirmed the Tax Court’s judgment for the Commissioner. View "Daugerdas v CIR" on Justia Law

Law enforcement officers executed a search warrant for methamphetamine at a rural Wisconsin property, where they believed Ryan Steinhoff, suspected of violent criminal activity, was present. During the early morning search, Steinhoff was found in a camper and, after initially appearing to comply with police orders, was tackled by an officer. In the course of his restraint, Steinhoff sustained a head injury from a rifle barrel, which required stitches. Body-camera footage captured the incident, but it was unclear whether the head injury was caused intentionally or accidentally.Steinhoff filed a lawsuit under 42 U.S.C. § 1983 in the United States District Court for the Western District of Wisconsin, alleging that Detective Kowalczyk and Investigator Malovrh used excessive force in violation of the Fourth Amendment. The district court granted summary judgment to Captain Ramberg, as Steinhoff conceded no excessive force was used by him. The court denied summary judgment to Investigator Malovrh on the claim regarding kneeling during handcuffing, and a jury later found in Malovrh’s favor on that issue. The district court granted summary judgment and qualified immunity to Detective Kowalczyk regarding the tackle, finding no clearly established law prohibiting his actions. The court also granted summary judgment to Investigator Malovrh on the rifle strike, concluding no reasonable jury could find the strike intentional.The United States Court of Appeals for the Seventh Circuit affirmed qualified immunity for Detective Kowalczyk, holding that his actions during a high-risk drug raid did not violate clearly established law. However, the appellate court reversed summary judgment for Investigator Malovrh, finding factual disputes about whether the rifle strike was intentional. The court remanded for a jury to resolve those disputes, as a blow to the head with a rifle could constitute excessive force if intentional. View "Steinhoff v Malovrh" on Justia Law