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

Dr. William Partin filed a lawsuit against Baptist Healthcare System, Inc. and Dr. Daniel Eichenberger after he resigned from his position. Partin alleged that Baptist and Eichenberger retaliated against him in violation of the Emergency Medical Treatment and Active Labor Act (EMTALA) and brought claims under Indiana law for breach of contract, tortious interference with contractual relations, and defamation. The dispute arose from Partin's treatment of a suicidal patient, J.C., in Baptist's emergency department, where Partin ordered procedures against J.C.'s will, leading to complaints from hospital staff.The United States District Court for the Southern District of Indiana granted summary judgment in favor of Baptist and Eichenberger. The court found that no reasonable jury could conclude that Partin engaged in EMTALA-protected activity or that he was retaliated against for such activity. The court also determined that Partin's breach of contract claim failed because the bylaws did not create a contractual relationship between Partin and Baptist, and his resignation was not under duress. Additionally, the court found no evidence to support Partin's claims of tortious interference with contract or defamation.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 Partin did not engage in EMTALA-protected activity and that his belief in reporting a potential EMTALA violation was not objectively reasonable. The court also agreed that the bylaws did not create a contract between Partin and Baptist and that Partin's resignation was voluntary. Furthermore, the court found that Baptist's actions were justified and not malicious, and that the statements made by Eichenberger and Marksbury were protected by qualified privilege and not made in bad faith. View "Partin v Baptist Healthcare System, Inc." on Justia Law

Leon Carter was charged by the State of Wisconsin with sexual assault, strangulation, and kidnapping. During his trial, the jury sent a note to the judge with a question, but the bailiff answered it without consulting the judge. The jury found Carter guilty on all counts. After learning of the bailiff’s response, Carter moved for a mistrial, which was denied.On direct appeal, Carter’s appellate counsel filed a no-merit brief, summarizing the record and explaining why potential legal arguments, including those related to the bailiff’s actions, lacked merit. The Wisconsin Court of Appeals agreed and affirmed the convictions, and the Wisconsin Supreme Court denied certiorari.Carter then sought federal habeas relief, asserting two violations: that the state appellate court denied him a meaningful appeal under Anders v. California, and that the state trial judge erred by not holding a hearing to investigate jury intrusion, contrary to Remmer v. United States. The district court rejected the Anders claim and did not consider the Remmer claim. Carter appealed to the United States Court of Appeals for the Seventh Circuit.The Seventh Circuit concluded that Carter’s Anders claim failed, as the Wisconsin Court of Appeals had adequately reviewed the record and briefs, ensuring his appeal was resolved on its merits. The court also found that Carter’s Remmer claim could not overcome the high hurdle set by the Antiterrorism and Effective Death Penalty Act (AEDPA), as the bailiff’s communication with the jury did not rise to the level of presumptive prejudice established in Remmer. Consequently, the Seventh Circuit affirmed the district court’s decision. View "Carter v. Tegels" on Justia Law

Event Media Inc. and Pack Expo Services, LLC, were contributing employers to the Central States, Southeast and Southwest Areas Pension Fund. Both companies withdrew from the Fund and incurred withdrawal liability obligations. The dispute centers on how to calculate these obligations, specifically whether post-2014 contribution rate increases should be included in the calculation.The United States District Court for the Northern District of Illinois, Eastern Division, held that the employers' post-2014 contribution rate increases should be excluded from the calculation of their withdrawal liability payments. The court reasoned that these increases were required by a rehabilitation plan and thus should be disregarded under 29 U.S.C. § 1085(g)(3).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 post-2014 contribution rate increases were indeed required by the rehabilitation plan and should be excluded from the calculation of the employers' withdrawal liability payments. The court concluded that neither of the exceptions outlined in 29 U.S.C. § 1085(g)(3)(B) applied in this case, as the increases were not due to increased levels of work, employment, or periods for which compensation is provided, nor were they used to provide an increase in benefits permitted by subsection (f)(1)(B). Therefore, the Fund must use the 2014 contribution rate, not the higher 2019 rate, in calculating the employers' withdrawal liability payments. View "Central States, Southeast and Southwest Areas Pension Fund v. Event Media Inc." on Justia Law

In the early hours of July 19, 2018, Peoria Police Officer Ryan Isonhart fatally shot Luis Cruz, who was fleeing from officers and allegedly pointing a gun at Officer Nicholas Mason. Lyrah Hernandez, Cruz’s sister, filed a lawsuit on behalf of Cruz’s estate, alleging federal claims under 42 U.S.C. § 1983 and state law claims against Officers Isonhart and Mason, and the City of Peoria. The district court granted summary judgment for Officer Mason, and the case proceeded to trial against the remaining defendants. The jury found in favor of the defendants. Hernandez appealed, arguing that the district court erred in admitting certain evidence and excluding testimony from two individuals.The United States District Court for the Central District of Illinois admitted evidence including the crimes underlying the 49 messages, the Department of Child and Family Services investigation, Cruz’s incarceration at the time of his daughters’ birth, and his pending drug charge. The court found these pieces of evidence relevant to the officers’ state of mind and Cruz’s damages. The court also barred testimony from forensic scientist Jennifer MacRitchie, ruling it was expert in nature and not properly disclosed, and excluded a recorded statement from Shaquille Alexander, finding it lacked trustworthiness.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s evidentiary rulings for abuse of discretion. The appellate court affirmed the district court’s decisions, finding that the admitted evidence was relevant and not unduly prejudicial, and that the exclusion of MacRitchie’s testimony and Alexander’s statement was appropriate. The court concluded that any potential error in admitting Cruz’s pending drug charge was harmless given the overwhelming evidence supporting the jury’s verdict. The judgment of the district court was affirmed. View "Hernandez v City of Peoria, Illinois" on Justia Law

Dennis Jones, a 42-year-old part-time grocery store cashier, applied for Social Security disability benefits, claiming that conditions related to his premature birth, including a cerebral hematoma, had worsened and prevented him from working full-time. The Social Security Administration denied his application, and Jones requested an administrative hearing. An Administrative Law Judge (ALJ) found that Jones had the residual functional capacity to perform light work with certain limitations and concluded that he was not disabled.The United States District Court for the Northern District of Illinois affirmed the ALJ's decision. Jones then appealed to the United States Court of Appeals for the Seventh Circuit, arguing that the ALJ failed to properly evaluate a statement from Dr. James Runke, a consultative examiner, which Jones contended was a medical opinion.The Seventh Circuit agreed with Jones that Dr. Runke's statement, which indicated that Jones's pain and joint strain limited him to working 20 hours per week, constituted a medical opinion under the 2017 revised regulations. However, the court held that the ALJ was not required to evaluate the persuasiveness of this medical opinion because it addressed an issue reserved to the Commissioner of Social Security—whether Jones was capable of performing regular or continuing work. Consequently, the ALJ had no obligation to provide an analysis of Dr. Runke's statement. The Seventh Circuit affirmed the district court's decision, upholding the denial of benefits. View "Jones v Dudek" on Justia Law

Reyna Cruz slipped and fell in a Costco food court, injuring her neck, back, knee, and wrist, which led to back surgery. The incident was recorded by Costco’s surveillance cameras. The video showed no evidence of a smoothie spill or any customer purchasing a smoothie in the 28 minutes before Cruz’s fall. However, a woman with a child in a shopping cart was seen in the area shortly before the fall, and Cruz testified that she saw a pink substance on the floor, her shoe, and her pant leg after the fall. Costco employees who arrived at the scene did not recall seeing anything on the floor but cleaned the area and placed a “wet floor” sign. The manager’s incident report noted “smoothie drops” on the floor.Cruz filed a lawsuit in state court, which Costco removed to federal court. The United States District Court for the Northern District of Illinois granted summary judgment to Costco, concluding that Cruz had not provided evidence that the smoothie spill was on the floor long enough for Costco to have constructive notice of its presence. The court also found that Cruz did not present evidence that Costco maintained a policy leading to dangerous conditions.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court found that Cruz presented sufficient evidence to create genuine issues of material fact regarding the presence and duration of the smoothie spill. The court noted that the surveillance video, viewed in the light most favorable to Cruz, could allow a reasonable jury to infer that the spill had been on the floor for at least 28 minutes, which could establish constructive notice. The court also found that Cruz did not provide sufficient evidence to show that Costco maintained a pattern of dangerous conditions.The Seventh Circuit reversed the district court’s summary judgment and remanded the case for further proceedings. View "Cruz v Costco Wholesale Corporation" on Justia Law

Nathaniel Jacobs was found guilty by a jury of several drug and gun possession offenses, as well as witness tampering. The case began when Jacobs appeared at a hospital with a gunshot wound and admitted to police that he had accidentally shot himself with a firearm he was not legally allowed to possess. A search of his home revealed firearms, ammunition, and drug-related evidence, including methamphetamine and paraphernalia. Jacobs was indicted on multiple counts, including illegal possession of firearms, possession with intent to distribute methamphetamine, possession of a firearm in furtherance of a drug trafficking crime, and witness tampering.The United States District Court for the Southern District of Indiana handled the initial proceedings. During pretrial, the court granted a government motion to exclude evidence of Jacobs’s girlfriend’s pending criminal charges, which Jacobs wanted to use to suggest her potential bias. The jury trial proceeded, and Jacobs was convicted on all counts.The United States Court of Appeals for the Seventh Circuit reviewed the case. Jacobs raised two issues on appeal: a violation of his Sixth Amendment rights due to the district court's restriction on cross-examining his ex-girlfriend about her potential bias, and a Fourth Amendment challenge regarding the admission of drug evidence found in his home. The appellate court found that any potential Sixth Amendment violation was harmless beyond a reasonable doubt due to the overwhelming evidence against Jacobs. Additionally, the court determined that Jacobs had not shown good cause for failing to file a suppression motion regarding the drug evidence and that the search of the tobacco cans was within the scope of the warrant.The Seventh Circuit affirmed the district court’s judgment, upholding Jacobs’s convictions. View "United States v. Jacobs" on Justia Law

Matthew Cargo, a federal prisoner, attempted to file a notice of appeal after being sentenced on July 20, 2020. He had until August 3, 2020, to file the notice, with a possible extension to September 2, 2020. Cargo, while temporarily held in an Oklahoma jail, prepared the notice on July 22, 2020, and handed it to a correctional officer. However, he incorrectly addressed the envelope, leading to its return by the U.S. Postal Service as undeliverable. Cargo did not learn of the error until November 2024, after which he promptly resent the notice.The United States District Court for the Northern District of Illinois received the notice in November 2024, four years after the deadline. The government moved to dismiss the appeal as untimely, and Cargo argued that he had complied with the prison-mailbox rule, which deems a notice of appeal filed when handed to prison officials for mailing.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that Cargo's addressing error precluded him from benefiting from the prison-mailbox rule. The rule requires that the notice be properly addressed to ensure it reaches the district court. Since Cargo's notice was returned as undeliverable, it did not meet the requirements of the rule. Consequently, the court dismissed Cargo's appeal as untimely, emphasizing that proper addressing is crucial for the prison-mailbox rule to apply. The court also noted that Cargo could have avoided this outcome by instructing his counsel to file the notice of appeal. View "USA v Cargo" on Justia Law

Efrain Leonides-Seguria, a Mexican citizen without legal status in the United States, was detained by Immigration and Customs Enforcement (ICE) on June 15, 2021, for illegal reentry. Six days later, ICE referred him for criminal prosecution. On June 23, federal prosecutors filed a criminal complaint, and a magistrate judge issued an arrest warrant. Leonides-Seguria remained in immigration custody until June 28, when he was arrested on the criminal complaint. He later waived prosecution by indictment, consenting to the filing of a criminal information on July 27.The United States District Court for the Northern District of Illinois denied Leonides-Seguria’s motions to dismiss the federal charge, arguing that the government violated the Speedy Trial Act and that 8 U.S.C. § 1326 is unconstitutional. He pled guilty but reserved the right to appeal these denials. The district court sentenced him to 51 months’ imprisonment.The United States Court of Appeals for the Seventh Circuit reviewed the case. Leonides-Seguria argued that the Speedy Trial Act was violated because the criminal information was filed more than 30 days after his apprehension. He urged the court to recognize a "ruse exception," where civil detention by immigration authorities is used to delay criminal prosecution. The Seventh Circuit declined to resolve the legal question of the ruse exception, finding that the facts did not support its application. The court found no evidence of collusion between ICE and federal prosecutors to circumvent the Speedy Trial Act. The court affirmed the district court’s denial of the motion to dismiss and upheld the constitutionality of 8 U.S.C. § 1326, consistent with precedent. The Seventh Circuit affirmed the district court’s judgment. View "USA v Leonides-Seguria" on Justia Law

Mark Sorensen, owner of SyMed Inc., a Medicare-registered distributor of durable medical equipment, was involved in a business arrangement with PakMed LLC, Byte Success Marketing, and Dynamic Medical Management. They advertised orthopedic braces, obtained signed prescriptions from patients' doctors, distributed the braces, and collected Medicare reimbursements. Byte and KPN, another marketing firm, advertised the braces, and interested patients provided their information, which was forwarded to call centers. Sales agents then contacted patients, generated prescription forms, and faxed them to physicians for approval. Physicians retained discretion to sign and return the forms, with many choosing not to.A federal grand jury indicted Sorensen on four counts: one count of conspiracy and three counts of offering and paying kickbacks for Medicare referrals. The jury found Sorensen guilty on all counts. Sorensen moved for acquittal, arguing insufficient evidence and lack of awareness of the scheme's illegality. The district court denied his motions, finding the evidence sufficient for the jury to conclude Sorensen knew the fee structure and purchase of doctors' orders were illegal. Sorensen was sentenced to 42 months in prison but was released on bond pending appeal.The United States Court of Appeals for the Seventh Circuit reviewed the case and reversed the district court's judgment due to insufficient evidence. The court found that Sorensen's payments to PakMed, KPN, and Byte were for advertising, manufacturing, and shipping services, not for patient referrals. The court emphasized that the Anti-Kickback Statute targets payments to individuals with influence over healthcare decisions, which was not the case here. The court concluded that Sorensen's actions did not violate the statute, as there was no evidence of improper influence over physicians' independent medical judgment. View "USA v Sorensen" on Justia Law