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

Tara Osborn, a technical support specialist, was terminated by JAB Management Services, Inc., which provides prison healthcare. Osborn sued her former employer, alleging violations of state and federal employment law, including a claim that JAB Management failed to compensate her for overtime work as required by the Fair Labor Standards Act (FLSA). JAB Management moved for summary judgment on the overtime claim.The United States District Court for the Central District of Illinois granted summary judgment in favor of JAB Management. The court found that Osborn failed to comply with local rules in her response to the summary judgment motion, leading to her amended response being struck. Consequently, the court deemed JAB Management's facts as admitted and found that Osborn did not provide sufficient evidence to show she worked overtime.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's decision, holding that Osborn did not meet her initial burden of proving she worked uncompensated overtime. The court noted that Osborn's evidence was vague, conclusory, and lacked specificity regarding her work hours. Additionally, her claims were inconsistent with other evidence in the record. The court also found that even under the relaxed just and reasonable inference standard for proving damages, Osborn's evidence was insufficient to establish the amount and extent of her overtime work. Therefore, the Seventh Circuit affirmed the district court's grant of summary judgment in favor of JAB Management. View "Osborn v JAB Management Services, Inc." on Justia Law

An inmate at Green Bay Correctional Institution, who is a practicing Muslim, filed a lawsuit under the Religious Land Use and Institutionalized Persons Act (RLUIPA) against the Wisconsin Department of Corrections (WDOC). He challenged WDOC's policy prohibiting inmates from leading religious programs when no outside religious leader or volunteer is available, claiming it resulted in unnecessary cancellations of religious programs. He also alleged that the cancellation of these programs breached a prior settlement agreement with WDOC.The United States District Court for the Western District of Wisconsin granted summary judgment in favor of WDOC on the RLUIPA claim, finding that the policy was the least restrictive means of furthering the compelling interest of maintaining prison safety and security. The court also granted summary judgment in favor of the inmate on the state law breach-of-contract claim as to liability but relinquished supplemental jurisdiction over the request for injunctive relief.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's summary judgment in favor of WDOC on the RLUIPA claim, agreeing that the policy was the least restrictive means to ensure prison safety and security. However, the appellate court vacated the district court's partial judgment on the state law breach-of-contract claim. The court held that the district court abused its discretion by relinquishing jurisdiction over the remedy portion of the claim while retaining jurisdiction over liability. The case was remanded to the district court to determine whether to retain or relinquish jurisdiction over the entire state law claim. View "West v Hoy" on Justia Law

Kevin Johnson, an inmate in Indiana, filed a pro se lawsuit under 42 U.S.C. § 1983, alleging that he received inadequate dental and mental health care while incarcerated. The case was complicated by the COVID-19 pandemic and Johnson's frequent transfers between prisons in Indiana, Ohio, and Virginia, which disrupted his mail service. Johnson claimed he never received the defendants' summary judgment motions due to these mail issues.The United States District Court for the Southern District of Indiana initially denied the defendants' summary judgment motions without prejudice, recognizing potential mail delivery problems. The court allowed the defendants to refile their motions and instructed them to notify the court if Johnson did not receive the filings. Despite these measures, Johnson did not respond to the refiled motions within the given 28-day period. Consequently, the district court granted summary judgment in favor of the defendants and dismissed the case. Johnson later filed a motion to vacate the judgment, asserting he never received the refiled motions, but the district court denied this motion.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court acknowledged the procedural complexities but focused on whether Johnson had constructive notice of the summary judgment motions. The court concluded that Johnson had constructive notice because he received the district court's order resetting the briefing schedule and instructing him on how to proceed. The court found no substantive or procedural error in the district court's decision and affirmed the summary judgment in favor of the defendants. View "Johnson v Purdue" on Justia Law

Technical Security Integration, Inc. ("Technical Security") and EPI Technologies, Inc. ("EPI") entered into a Sales Representative Agreement in which EPI agreed to sell Technical Security's products in exchange for commissions. The agreement included a clause requiring disputes to be submitted to mediation, and if mediation failed within 180 days, the prevailing party in any subsequent litigation would be entitled to attorneys' fees. A dispute arose, and EPI demanded mediation, but Technical Security did not respond promptly. EPI then sued Technical Security in state court, where it mostly lost. Technical Security sought attorneys' fees in federal court, which the district court denied, ordering each party to pay its own fees.The Circuit Court of Cook County, Illinois, granted partial summary judgment for Technical Security on the commissions dispute. EPI's remaining claims were dismissed, and the state court denied Technical Security's motion for attorneys' fees, citing a factual dispute. Technical Security then demanded mediation to resolve the fee dispute, but EPI did not respond. Technical Security subsequently sued EPI in the Northern District of Illinois, seeking fees and costs from the state court litigation. The district court granted summary judgment for EPI, concluding that Technical Security had delayed the mediation process.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that the agreement did not specify a timeline for mediation demands or responses, creating ambiguity. The court held that the district court erred in faulting Technical Security for preventing mediation without considering whether EPI's actions were reasonable. The Seventh Circuit vacated the district court's summary judgment for EPI and remanded the case for further proceedings to determine the reasonableness of each party's conduct regarding the mediation timeline. View "Technical Security Integration, Inc. v EPI Technologies, Inc." on Justia Law

Lorenzo Johnson ran an online child-pornography scheme, inducing financially desperate women to send him sexually explicit photos of their young children by promising them money. Law enforcement identified Johnson's IP address, social media accounts, and cellphone, leading to a search of his home where they found his phone containing evidence of the crimes and a handgun. Johnson confessed to key details of his scheme in two recorded interviews with FBI agents. A jury found him guilty of conspiracy to produce child pornography, distribution of child pornography, and unlawful possession of a firearm as a felon.The United States District Court for the Northern District of Indiana, Hammond Division, handled the initial trial. Johnson's requests for new counsel were denied by both the magistrate judge and the district judge. The district judge also denied Johnson's motion for a new trial based on a late disclosure of potential Brady/Giglio evidence, which involved a romantic relationship between two FBI agents. Additionally, Johnson argued that the judge made an improper factual finding at sentencing regarding his causal role in the suicide of one of the women involved in his scheme.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the lower court's decisions, holding that the magistrate and district judges appropriately exercised their discretion in denying Johnson’s requests for new counsel. The district judge properly denied Johnson’s motion for a new trial because it was undeveloped and the new information was deemed immaterial. Lastly, the court found that the judge’s comments at sentencing about the co-conspirator’s suicide were part of a holistic assessment of the seriousness of the crimes and did not amount to a factual finding that Johnson was causally responsible. The Seventh Circuit affirmed the district court's rulings and Johnson's conviction and sentence. View "U.S. v. Johnson" on Justia Law

Bellin Memorial Hospital hired Kinsey & Kinsey, Inc. to upgrade its computer software. Kinsey failed to implement the agreed-upon software, leading Bellin to sue Kinsey in Wisconsin state court for breach of contract and other claims. Bellin also sued Kinsey’s president and a senior product consultant. Kinsey’s insurer, Philadelphia Indemnity Insurance Company, provided a defense under a professional liability insurance policy. During the trial, Bellin and Philadelphia Indemnity entered into a partial settlement, resolving some claims and specifying the conditions under which Bellin could collect damages from Kinsey. Bellin prevailed at trial and was awarded damages.The Wisconsin circuit court ruled that the limited liability provision in the Agreement did not apply due to Kinsey’s material breach. The court granted a directed verdict on the breach of contract claim against Kinsey, leaving the question of damages to the jury. The jury awarded Bellin $1.39 million, later reduced to $750,000 plus costs. The jury found Kinsey and its president not liable for intentional misrepresentation and misleading representation.Philadelphia Indemnity filed a declaratory judgment action in the United States District Court for the Northern District of Illinois, seeking a declaration that the state court’s judgment was covered by the insurance policy and that the $1 million settlement offset the $750,000 judgment. The district court ruled for Bellin, concluding that the state court judgment was not covered by the insurance policy.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The court held that the insurance policy covered only negligent acts, errors, or omissions, and the state court’s judgment was based on a breach of contract, not negligence. Therefore, the $1 million set-off provision did not apply, and Bellin could recover the full amount of the judgment. View "Philadelphia Indemnity Insurance Co. v Kinsey & Kinsey, Inc." on Justia Law

Clarence Lewis, an inmate at Hill Correctional Center, sued various medical staff members, alleging they were deliberately indifferent to his health issues, violating the Eighth Amendment. Lewis claimed misdiagnosis and mistreatment of diabetes, COPD, irritable bowel syndrome, and Hepatitis C. He also contended that his grievance about a delay in diabetes medication was not properly addressed.The United States District Court for the Central District of Illinois denied Lewis's motions for recruited counsel, stating he could represent himself and obtain relevant documents. The court granted summary judgment in favor of Dr. Sood, Dr. Bautista, Nurse Vollmer, and Administrator Lindor, concluding no reasonable juror could find deliberate indifference. The court also granted summary judgment for Dr. Paul, citing claim splitting due to a similar prior lawsuit.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the judgment in favor of Dr. Sood, Dr. Bautista, Nurse Vollmer, and Administrator Lindor, finding no reasonable likelihood that recruited counsel would have changed the outcome. The court noted that Lewis's disagreement with his diagnoses and treatments did not constitute deliberate indifference. As for Administrator Lindor, her limited role and the lack of harm from the medication delay further supported the judgment.However, the court vacated the judgment in favor of Dr. Paul, agreeing with Lewis that the district court's application of claim splitting was erroneous. Dr. Paul had raised this defense too late, effectively acquiescing to the claim. The case was remanded for further proceedings regarding Dr. Paul, with the district court advised to reconsider Lewis's request for recruited counsel if the claim proceeds to trial. View "Lewis v Sood" on Justia Law

Michael Gifford, a beneficiary of the Operating Engineers 139 Health Benefit Fund, sought reimbursement for out-of-network medical expenses incurred during his treatment for a stroke and subsequent brain aneurysm surgery. The Fund denied the claim, stating the services were not provided in an emergency and were not medically necessary. Gifford's wife, Suzanne, appealed the decision, but the Fund upheld the denial after consulting two independent medical reviewers who concluded the surgery was not an emergency and not medically necessary.The United States District Court for the Eastern District of Wisconsin granted the Fund's motion for summary judgment, agreeing that the Fund's decision was not arbitrary and capricious. The court also granted the Fund's motion for a protective order, limiting discovery to the administrative record. The Estate of Michael Gifford, represented by Suzanne, appealed the decision, arguing that the Fund failed to conduct a full and fair review by not considering a surgical note from Dr. Ahuja, which was not included in the administrative record.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court held that the Fund's denial of benefits was not arbitrary and capricious, as the Fund reasonably relied on the independent medical reviewers' reports and the administrative record. The court also found that the Fund was not required to seek out additional information not provided by the claimant. Additionally, the court upheld the district court's grant of the protective order, finding no abuse of discretion in limiting discovery to the administrative record. The court concluded that the Fund provided a full and fair review of the claim, and the denial of benefits was reasonable. View "Estate of Gifford v Operating Engineers 139 Health Benefit Fund" on Justia Law

Taibian Harris and his cousin Treveon Smith robbed a cell phone store in South Bend during a blizzard. Harris acted as the getaway driver while Smith stole items from the store. Unbeknownst to them, one of the stolen phones was a bait phone that sent GPS signals to the police. The police tracked them to a gas station, and after a brief encounter, Harris led the police on a high-speed chase through snowy, icy streets, running stop signs and red lights. The chase ended when Harris collided with a police car. Both were apprehended after attempting to flee on foot.Harris and Smith were indicted for robbery under 18 U.S.C. § 1951 and both pled guilty. The Presentence Investigation Report recommended a two-level enhancement for Harris for recklessly creating a substantial risk of death or serious bodily injury while fleeing law enforcement. Harris objected, arguing there was no reliable evidence of reckless driving and that no police officer was in actual pursuit. The government called Smith as a witness, who described the high-speed chase in detail. The district court credited Smith’s testimony and overruled Harris’s objection, applying the two-level enhancement.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the district court did not clearly err in finding that Harris drove recklessly, as his actions met the recklessness standard under U.S.S.G. § 3C1.2. The court also found that Harris was knowingly fleeing from law enforcement, as evidenced by his erratic driving and attempts to evade police. The Seventh Circuit affirmed the district court’s application of the two-level enhancement to Harris’s sentence. View "United States v Harris" on Justia Law

Linda Thompson filed a putative class action against the Army and Air Force Exchange Service (the "Exchange") in Illinois state court, alleging that the Exchange printed her credit card’s expiration date on purchase receipts, violating the Fair and Accurate Credit Transactions Act (FACTA). The Exchange removed the case to federal court under 28 U.S.C. § 1442(a)(1), which allows federal agencies to remove cases to federal court. Thompson moved to remand the case to state court, arguing lack of Article III standing, while the Exchange moved to dismiss under Federal Rule of Civil Procedure 12(b)(1).The United States District Court for the Southern District of Illinois denied Thompson’s motion to remand and granted the Exchange’s motion to dismiss for lack of subject matter jurisdiction. The court held that the Exchange, as a federal entity, could remove the case without asserting a colorable federal defense and had an absolute right to litigate in federal court.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court agreed that the Exchange did not need to present a federal defense to remove the case. However, it found that the district court erred in dismissing the suit. The Seventh Circuit held that under 28 U.S.C. § 1447(c), when a federal court lacks subject matter jurisdiction over a removed case, it must remand the case to state court. The court noted that Thompson’s lack of Article III standing did not preclude state court jurisdiction, as state courts are not bound by Article III constraints. Consequently, the Seventh Circuit vacated the district court’s judgment and remanded the case with instructions to remand it to state court. View "Thompson v Army and Air Force Exchange Service" on Justia Law