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

John Nawara, a former correctional officer at Cook County Jail, had several altercations with other county employees. As a result, the Cook County Sheriff's Office required him to undergo a fitness-for-duty examination and sign medical information release forms. Nawara initially resisted but eventually complied. Before doing so, he sued Cook County and Sheriff Thomas Dart, alleging that the examination requirement and inquiry into his mental health violated § 12112(d)(4) of the Americans with Disabilities Act (ADA).The United States District Court for the Northern District of Illinois found in favor of Nawara, but the jury awarded him zero damages. Nawara filed a post-trial motion requesting back pay, lost pension benefits, and restoration of his seniority. The court granted the restoration of seniority but denied the request for back pay, concluding that the violation of § 12112(d)(4) could not support an award of back pay. Nawara appealed the denial of back pay, and the Sheriff cross-appealed the restoration of seniority.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's decision to restore Nawara's seniority, finding that it could still benefit him in his current role as a police officer within the Sheriff's Office. However, the court reversed the district court's denial of back pay. The Seventh Circuit held that a violation of § 12112(d)(4) of the ADA constitutes discrimination on the basis of disability, thus entitling Nawara to request back pay. The case was remanded for further proceedings consistent with this opinion. View "Nawara v Cook County Municipality" on Justia Law

In this case, plaintiffs in a class action alleged that several corporations in the broiler chicken market violated antitrust laws by engaging in bid rigging and reducing the supply of broiler chickens. The plaintiffs claimed that these actions led to anomalous dips in sales, which they attributed to collusion on price and output. The class action was divided into two tracks: Track 1, which omitted bid-rigging allegations for faster discovery and trial, and Track 2, which included bid-rigging theories and state law claims by indirect purchasers.The United States District Court for the Northern District of Illinois allowed the class to place claims against Simmons Foods, Inc. and Simmons Prepared Foods, Inc. on Track 1. Simmons settled for $8 million, but several class members, including the Boston Market group, objected to the settlement. They argued that the settlement was inadequate and that they should not be included in the class because they had filed their own antitrust suits. However, they missed the deadline to opt out of the class, and the district court approved the settlement.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the settlement's release language was broad enough to cover bid-rigging claims and that the $8 million settlement was reasonable. The court noted that the Boston Market group did not provide evidence that the settlement amount was unreasonably low. Additionally, the court observed that the class had lost a related trial and that criminal antitrust prosecutions against some firms had ended in mistrials or acquittals, indicating uncertainty about the plaintiffs' prospects. The court affirmed the district court's approval of the settlement. View "Boston Market Corporation v Mountainaire Farms, Inc." on Justia Law

Raymond Tackett, an inmate with the Indiana Department of Corrections (IDOC), suffered from Hepatitis C (HCV) and did not receive direct-acting antivirals (DAAs), a treatment that cures HCV. He died on November 29, 2019, from complications related to HCV. His daughter, Skyler Tackett, as the personal representative of his estate, filed an Eighth Amendment deliberate indifference claim and a state law medical malpractice claim against the medical professionals who treated him, Wexford Health Services, and Dr. Kristen Dauss, the Chief Medical Officer of the IDOC. She later dismissed all claims except the deliberate indifference claim against Dr. Dauss.The United States District Court for the Southern District of Indiana granted summary judgment in favor of Dr. Dauss, finding that she took reasonable steps to expand access to DAAs and was not responsible for the treatment decisions that led to Mr. Tackett’s death. Ms. Tackett appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court’s judgment. The court found that Ms. Tackett presented insufficient evidence for a reasonable jury to find Dr. Dauss liable in her individual capacity. The court noted that Mr. Tackett was in a treatment priority group and that Nurse Myers had requested DAAs for him, but there was no evidence that Dr. Dauss’s actions or the IDOC policy prevented him from receiving the treatment. The court concluded that while Mr. Tackett’s death was tragic, there was no evidence that Dr. Dauss’s actions amounted to deliberate indifference under the Eighth Amendment. View "Tackett v Dauss" on Justia Law

Christine Swiecichowski worked in a warehouse for over thirty years until 2018, when she quit due to increasing symptoms and pain from fibromyalgia, depression, issues with her right arm and wrist, and spinal disorders. She applied for disability benefits in October 2018, claiming she was disabled from October 16, 2018. Her application and testimony described debilitating pain that limited her ability to work and perform daily activities.The Administrative Law Judge (ALJ) denied her application in June 2020, following the Social Security Administration's five-step process for determining disability. The ALJ found that Swiecichowski had severe impairments, including fibromyalgia, but concluded that none were automatically disabling. The ALJ determined that her residual functional capacity (RFC) allowed her to perform light work with some restrictions. The ALJ discounted her subjective complaints of pain, citing mixed clinical findings and her ability to perform some daily activities. The Appeals Council denied her request for review, making the ALJ's decision final. The United States District Court for the Eastern District of Wisconsin affirmed the ALJ's decision.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that the ALJ did not adequately follow the Social Security Administration's guidance on evaluating fibromyalgia, which requires a longitudinal review of the claimant's symptoms due to their waxing and waning nature. The ALJ's decision did not sufficiently consider the numerous medical visits and reports of pain over time. The court vacated the judgment affirming the denial of benefits and remanded the case for further proceedings consistent with its opinion. View "Swiecichowski v Dudek" on Justia Law

Plaintiffs David Vance Gardner and Gary Merchant filed a lawsuit against MeTV National Limited Partnership, alleging that MeTV violated the Video Privacy Protection Act (VPPA) by disclosing their personally identifiable information without consent. MeTV operates a website where users can watch classic TV shows. Users can sign up with their email addresses and zip codes to personalize their experience, which includes receiving reminders and using a channel finder feature. Plaintiffs claimed that MeTV embedded a "Meta pixel" in its videos, allowing Facebook to link users' viewing habits to their Facebook accounts for targeted advertising.The United States District Court for the Northern District of Illinois dismissed the plaintiffs' complaint, ruling that they were not "consumers" under the VPPA because they did not pay for MeTV's services. The court allowed the plaintiffs to file an amended complaint, which was also dismissed on the same grounds.The United States Court of Appeals for the Seventh Circuit reviewed the case and reversed the district court's decision. The appellate court held that the term "consumer" under the VPPA includes anyone who subscribes to services from a video tape service provider, regardless of whether they pay money. The court found that providing personal information, such as an email address and zip code, in exchange for personalized services constitutes a subscription. Therefore, the plaintiffs are considered "consumers" under the VPPA, and their complaint should not have been dismissed.The Seventh Circuit remanded the case for further proceedings consistent with its opinion, allowing the plaintiffs' claims to proceed. View "Gardner v MeTV" on Justia Law

Jaron Jackson pleaded guilty to sex trafficking of a minor and transportation of child pornography. He was sentenced to 240 months in prison. Jackson appealed, arguing that the district court should have suppressed evidence found on his cell phone, claiming the police took too long (40 days) to seek a search warrant after his arrest. Jackson conceded that the warrant was supported by probable cause.The United States District Court for the Eastern District of Wisconsin denied Jackson's motion to suppress, concluding that the delay did not allow the police to obtain any evidence they would not have received had they sought a warrant immediately. The district judge also found the motion untimely, as it was filed ten months past the deadline for pretrial motions. The court held a hearing to consider whether "good cause" justified the delay and concluded it did not.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 40-day delay in seeking the warrant did not make the search unreasonable, as the phone had been in official custody since Jackson's arrest, and there was no risk of evidence being altered or destroyed. The court also noted that Jackson did not attempt to regain possession of the phone or express concern about the delay. Therefore, the district court properly denied the motion to suppress the evidence recovered from the phone. View "USA v Jackson" on Justia Law

John Johnson pleaded guilty in 2020 to distributing large volumes of cocaine on two occasions in 2014 while he was on supervised release for a 2001 crack cocaine conviction. His guilty plea led to the revocation of his supervised release. The district court held a combined sentencing hearing, imposing a 180-month imprisonment and six years of supervised release for each count of the new offenses, to be served concurrently. Additionally, the court imposed a 24-month imprisonment for the supervised release violation, also to be served concurrently with the 180-month sentence.Johnson filed a motion to reduce the 24-month sentence under the First Step Act, which the district court denied, believing he was not eligible for a reduction. Johnson appealed this decision.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court concluded that Johnson's revocation sentence is eligible for a reduction under the First Step Act because the revocation penalties relate to the original offense, which is a covered offense under the Act. However, the court found that the district court's error in denying the reduction was harmless because the 24-month sentence runs concurrently with the 180-month sentence for the new offenses. Therefore, even if the 24-month sentence were reduced, it would not affect the total length of Johnson's imprisonment. Consequently, the Seventh Circuit affirmed the district court's decision. View "United States v. Johnson" on Justia Law

Susan Kinder, a white woman, was employed by the Marion County Prosecutor’s Office (MCPO) and alleged racial discrimination when she was reassigned to a new role. She claimed violations of Title VII and the Equal Protection Clause. Kinder had conflicts with a black colleague, Lydia Richardson, who accused her of making racially insensitive remarks. An investigation found the animosity was mutual. The prosecutor decided to reassign both employees, but Kinder viewed her new role as a demotion.The Equal Employment Opportunity Commission (EEOC) issued a right-to-sue letter on April 28, 2022, but Kinder’s counsel could not access it until July 6, 2022. Kinder filed her complaint on October 4, 2022, alleging Title VII and Equal Protection Clause violations. The MCPO moved for summary judgment, arguing the Title VII claim was untimely and that the office was not a suable entity under 42 U.S.C. § 1983. The United States District Court for the Southern District of Indiana granted summary judgment to the MCPO, finding the Title VII claim was filed outside the 90-day window and that the MCPO was an arm of the state, immune from § 1983 claims.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The court held that the 90-day period for filing the Title VII claim began when Kinder’s counsel was notified on June 15, 2022, that the right-to-sue letter was available, making the October 4 filing untimely. The court also held that the MCPO is an arm of the state and not a suable “person” under § 1983, as the office is financially interdependent with the state and enjoys state indemnification for employment-related actions. View "Kinder v Marion County Prosecutor's Office" on Justia Law

Jacob Powers was convicted by a Wisconsin jury in 2006 for enticing and sexually assaulting a 13-year-old girl. Powers challenged his convictions in state court, claiming he was incompetent at the time of his trial and that his lawyer was ineffective for not raising this issue. After exhausting his state court remedies, Powers sought federal habeas corpus review on the same grounds.The United States District Court for the Eastern District of Wisconsin denied Powers's habeas petition. The court considered three post-trial evaluations of Powers's competency, his demeanor at trial, and the fact that his appellate attorney, after consulting with his trial counsel, chose not to pursue an incompetency claim. The district court concluded that Powers was competent at the time of his trial and that his trial counsel was not ineffective for failing to raise the issue of competency.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court noted that Powers's trial testimony and behavior did not indicate incompetency. Additionally, the court found that the evaluations conducted by Dr. Schoenecker and Dr. Dolezal, which concluded that Powers was competent, were more persuasive than Dr. Glassman's inconclusive report. The court also emphasized that Powers's trial counsel did not raise any concerns about his competency during the trial, and his appellate attorney found it frivolous to argue incompetency.The Seventh Circuit held that Powers was competent at his 2006 trial and that his trial counsel was not ineffective for failing to raise the issue of competency. Consequently, the court affirmed the district court's denial of Powers's habeas corpus petition. View "Powers v Noble" on Justia Law

Vonzell Scott was shot while waiting in his car at a Wendy’s drive-thru in Chicago around 3:00 am on December 31, 2018. Scott had a brief altercation with another driver, but it ended peacefully. Shortly after, two armed individuals approached Scott’s car and opened fire, injuring him. Scott sued Wendy’s, alleging negligence for not providing overnight security guards, which he claimed could have prevented the shooting.The United States District Court for the Northern District of Illinois granted summary judgment in favor of Wendy’s. The court found that while Wendy’s owed a duty to protect Scott from intentional third-party assaults, the specific shooting incident was so aberrant that Wendy’s failure to provide security guards did not proximately cause Scott’s injury. The court concluded that the shooting was unforeseeable and that additional security would not have prevented it.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s decision, holding that the extreme, isolated, and unprovoked nature of the shooting made it unforeseeable as a matter of law. The court noted that while there was evidence of prior crimes in the area, none were similar to the shooting Scott experienced. The court concluded that Wendy’s could not have reasonably foreseen the attack, and therefore, the lack of security guards did not proximately cause Scott’s injury. The court emphasized that the foreseeability of an injury is context-dependent and that the specific type of violence Scott endured was not reasonably foreseeable based on the prior incidents. View "Scott v Wendy's Properties, LLC" on Justia Law