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

Pearl Ray and Andrew Ray, Sr. sued medical providers in Illinois state court for medical malpractice, which allegedly injured Pearl and caused Andrew to suffer a loss of consortium. They settled with all but one defendant. Pearl was enrolled in a federal health benefits plan, and Blue Cross and Blue Shield Association (BCBSA) was the plan’s carrier. Under the plan, BCBSA sought reimbursement from the settlement for benefits paid to Pearl. The plaintiffs filed a motion to reduce BCBSA’s reimbursement by their attorney’s fees and costs under Illinois’s common fund doctrine.The case was removed to federal court by BCBSA, arguing federal question jurisdiction and federal officer removal. The United States District Court for the Northern District of Illinois initially denied the remand motion but later reconsidered and remanded the entire case, concluding it lacked federal question jurisdiction. BCBSA appealed, asserting federal question jurisdiction and federal officer removal.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision de novo. The court held that federal question jurisdiction was not present, as federal common law did not govern the reimbursement dispute, following the precedent set by Empire Healthchoice Assurance, Inc. v. McVeigh and Blue Cross Blue Shield of Illinois v. Cruz. However, the court found that BCBSA met the requirements for federal officer removal under 28 U.S.C. § 1442, as it was acting under a federal agency (OPM) and had a colorable federal defense.The Seventh Circuit affirmed the district court’s decision in part, reversed in part, and remanded, instructing the district court to exercise jurisdiction over the motion for adjudication while remanding the rest of the case to state court. View "Ray v. Tabriz" on Justia Law

A group of employees sued their employer, Metalcraft of Mayville, for not paying them for time spent working just before or after their shifts. The employees alleged that Metalcraft's timekeeping system, which allowed clocking in up to 15 minutes before and after shifts, did not accurately reflect the time they worked. They claimed that adjustments to their clock-in times were made even when they performed compensable work during these periods.The United States District Court for the Eastern District of Wisconsin decertified the collective action in April 2020, leading to 24 additional cases being filed and consolidated. Nine cases were dismissed for various reasons, and the district court granted summary judgment to Metalcraft in the four selected cases, ruling that the employees' evidence was speculative and insufficient. The remaining 12 plaintiffs voluntarily dismissed their cases, acknowledging that the summary judgment ruling likely determined their claims. Metalcraft then moved for sanctions against the plaintiffs' counsel, arguing that the lawsuits were frivolous.The United States Court of Appeals for the Seventh Circuit reviewed the case and upheld the district court's denial of sanctions. The appellate court found that the plaintiffs had enough factual and legal support for their claims to avoid sanctions. The court noted that FLSA claims can be based on reconstructed memories when an employer's record-keeping is inadequate. The court also determined that the plaintiffs' legal arguments regarding the Portal-to-Portal Act and the de minimis doctrine were not baseless. The appellate court emphasized that the standard for summary judgment is different from the standard for Rule 11 sanctions and that the plaintiffs' failure to win on summary judgment did not make their cases frivolous. Therefore, the denial of sanctions was affirmed. View "Farina v. Metalcraft of Mayville, Inc." on Justia Law

The plaintiff, GEFT Outdoor, LLC, challenged an Evansville, Indiana ordinance that distinguishes between on-premises and off-premises signs, arguing it violated the First Amendment. Initially, the district court agreed, but the Supreme Court's decision in Austin v. Reagan National Advertising of Austin, LLC, led to a remand. GEFT then focused on the ordinance's permit and variance criteria, claiming the City might consider a sign's message. However, the City does not request message information for permits, and the ordinance's criteria do not involve the sign's message. GEFT's variance application was denied due to non-compliance with size and spacing rules, which GEFT argued was unconstitutional.The district court dismissed GEFT's complaint, finding the ordinance's size and placement rules valid and the variance criteria specific enough to avoid content discrimination. The court referenced Leibundguth Storage & Van Service, Inc. v. Downers Grove, which upheld a similar ordinance. GEFT appealed, but the Seventh Circuit's decision in GEFT Outdoor, LLC v. Monroe County, which upheld similar variance criteria, further weakened GEFT's position. GEFT argued potential content discrimination, but the court found no substantial invalidity in the ordinance's application.The United States Court of Appeals for the Seventh Circuit reviewed the case and found that GEFT's facial challenge failed because it did not show that a substantial portion of the ordinance's applications were unconstitutional. GEFT had not contested the size and location rules, effectively conceding their validity. The court noted that GEFT's focus on a variance disqualified it from a facial challenge. The district court's decision was modified to clarify that GEFT lost on the merits, not for lack of standing, and the judgment was affirmed. View "GEFT Outdoor, LLC v. City of Evansville" on Justia Law

The case involves Michelle Gilbank, who lost custody of her daughter, T.E.H., in state court proceedings in Wisconsin. Gilbank alleged that various officials involved in those proceedings violated her federal constitutional rights. The events began when Gilbank, who had a history of drug use, moved into her ex-partner Ian Hoyle's apartment. Following an anonymous tip, police and social workers investigated and found evidence of Gilbank's drug use. On August 21, 2018, Gilbank was arrested for drug possession, and her daughter was temporarily placed with Hoyle. Subsequent state court hearings resulted in the continued placement of T.E.H. with Hoyle until Gilbank regained custody in March 2020.In the United States District Court for the Western District of Wisconsin, the court granted summary judgment for the defendants. The court found that some of Gilbank’s claims were barred by the Rooker-Feldman doctrine, which prevents federal courts from reviewing state court judgments. The court also ruled that the remaining claims failed on the merits, including claims of unreasonable search, denial of due process, and unlawful eviction.The United States Court of Appeals for the Seventh Circuit reviewed the case en banc. The court affirmed the district court's judgment, agreeing that the Rooker-Feldman doctrine barred claims based on injuries caused by state court judgments. The court also affirmed summary judgment on the merits for claims not barred by Rooker-Feldman, including those related to the urinalysis, interrogation without an attorney, and the removal of T.E.H. The court found that Gilbank had consented to the urinalysis, that her Fifth Amendment rights were not violated as her statements were not used in a criminal proceeding, and that there was no seizure of T.E.H. by government actors. The court also rejected the existence of a "fraud exception" to the Rooker-Feldman doctrine. View "Gilbank v. Wood County Department of Human Services" on Justia Law

Christopher Truett operated a methamphetamine distribution network while incarcerated in the Marion County Jail. He coordinated drug purchases and sales through phone calls, directing his girlfriend to handle the transactions and collect proceeds. Truett and his co-conspirators faced various drug and firearm charges, but he was specifically charged with conspiracy to possess with intent to distribute methamphetamine. He pleaded guilty and disclosed his mental, cognitive, and memory impairments during the change-of-plea hearing.The United States District Court for the Southern District of Indiana did not hold a competency hearing despite Truett's impairments and behavior during the plea hearing. His counsel assured the court of his competence, and Truett actively participated in the proceedings. At sentencing, additional evidence of his impairments was presented, but the court again did not order a competency hearing. The court adopted the Presentence Investigation Report's findings, attributing the entire drug quantity to Truett and sentencing him to 240 months of imprisonment, five years of supervised release, and a $250 fine. The written judgment included a condition for fine payment not orally pronounced at sentencing.The United States Court of Appeals for the Seventh Circuit reviewed the case. It held that the district court did not abuse its discretion by not holding a competency hearing, as Truett's behavior and counsel's assurances indicated his understanding of the proceedings. The court also found no error in attributing the entire drug quantity to Truett, as he was personally involved in all transactions. Finally, the appellate court affirmed the inclusion of the fine payment condition in the written judgment, deeming it a mandatory condition of supervised release. The court affirmed the district court's decisions. View "USA v. Truett" on Justia Law

Paul Osterman was prosecuted for sex trafficking a child after a detective in Oneida County, Wisconsin, obtained a warrant to place a GPS tracker on his truck. The warrant was based on an affidavit that included incorrect information. Osterman argued that these inaccuracies meant the affidavit did not establish probable cause, and he sought to suppress the evidence obtained from the GPS tracking.The United States District Court for the Eastern District of Wisconsin held an evidentiary hearing and found that the affidavit did establish probable cause despite the inaccuracies. The court denied Osterman’s motion to suppress, leading to his appeal.The United States Court of Appeals for the Seventh Circuit reviewed the case and agreed that the detective acted recklessly by not correcting the affidavit. However, the court independently reviewed the affidavit and concluded that it still established probable cause even without the misstatements. Therefore, the court affirmed the district court’s decision to deny the motion to suppress. The main holding was that the inaccuracies in the affidavit were immaterial to the probable cause determination, and thus, the evidence obtained from the GPS tracking was admissible. View "USA v. Osterman" on Justia Law

In September 2020, Michael Karmo informed a friend that he was traveling to Kenosha, Wisconsin, with firearms during a period of civil unrest. The friend reported this to local police, who then notified the FBI. The FBI, believing Karmo intended to shoot people and loot, requested real-time cell site location information (CSLI) from AT&T under exigent circumstances. Law enforcement located Karmo in a hotel parking lot, where he consented to searches of his vehicle and hotel room, revealing multiple firearms. Later, it was clarified that Karmo did not explicitly state he intended to shoot people and loot.The United States District Court for the Eastern District of Wisconsin reviewed the case. Karmo moved to suppress the evidence obtained from the CSLI collection, arguing that the exigent circumstances form contained false information. He also requested a Franks hearing to challenge the veracity of the form. The district court denied his motion, and Karmo subsequently pleaded guilty while reserving his right to appeal the suppression issue.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court assumed, without deciding, that the CSLI collection constituted a Fourth Amendment search. It held that law enforcement reasonably believed probable cause and exigent circumstances existed, justifying the warrantless search. The court found that even without the misrepresentation in the exigency form, the totality of circumstances supported a reasonable belief of a public safety threat. The court also determined that a Franks hearing was inapplicable because no judge had made a probable cause determination based on the form. The Seventh Circuit affirmed the district court's decision. View "United States v. Karmo" on Justia Law

Thompson Corrugated Systems, Inc. (TCS) entered into an oral agreement in 2004 to act as the North American sales representative for Engico, S.r.l., an Italian manufacturer of corrugated box machinery. TCS was to receive an 8% commission on sales, later modified to a sliding scale in 2012. Despite low sales, TCS procured two significant sales for Engico in 2005 and 2017. In 2016, Engico attempted to terminate the agreement due to low sales, but TCS resisted, citing market conditions. The parties renegotiated in 2018, agreeing that TCS would remain the representative until 2021 and continue to receive commissions. However, disputes arose over commissions for sales made in 2019 and 2020, leading TCS to sue Engico for breach of contract and other state law claims.The United States District Court for the Southern District of Illinois granted partial summary judgment in favor of TCS, finding the 2004 oral agreement valid and enforceable. The court determined that the essential terms of the agreement, including the commission structure, territory, and services, were sufficiently definite. The court also found that the agreement was terminable at will under Illinois law. The remaining claims were left to the jury, which found Engico liable for breach of contract and awarded TCS damages.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s grant of partial summary judgment de novo. The appellate court affirmed the district court’s decision, agreeing that the 2004 oral agreement contained sufficiently definite terms and that the Statute of Frauds did not bar enforcement of the 2018 agreement. The court concluded that the essential terms of the agreement were clear and that the deposition testimony satisfied the Statute of Frauds’ writing requirement. Thus, the judgment of the district court was affirmed. View "Thompson Corrugated Systems, Inc. v. Engico S.r.l." on Justia Law

Darkel Martin, after serving a custodial sentence for possessing a firearm as a felon, began a three-year term of supervised release. The government petitioned to revoke his supervised release, alleging multiple violations, including committing another crime, possessing a controlled substance, and failing to participate in treatment programs. Martin admitted to several violations, and the district court revoked his supervised release, sentencing him to twenty months of imprisonment and one year of supervised release.The United States District Court for the Southern District of Illinois handled the initial proceedings. The court found Martin had committed several violations of his supervised release conditions. The U.S. Probation Office recommended an advisory Guidelines range of eighteen to twenty-four months of imprisonment. The district court sentenced Martin within this range, imposing twenty months of imprisonment and one year of supervised release.The United States Court of Appeals for the Seventh Circuit reviewed the case. Martin argued that the district court erred by not calculating his Guidelines range and improperly relying on certain facts in violation of 18 U.S.C. § 3583(e). The appellate court found that the district court had considered the Guidelines range and the relevant statutory factors. The court noted that the district court referenced the Guidelines and the Probation Office’s recommendations during the hearing. Additionally, the appellate court determined that the district court primarily relied on permissible factors under § 3583(e) when sentencing Martin, rather than the factors listed in § 3553(a)(2)(A). Consequently, the Seventh Circuit affirmed the district court’s judgment. View "USA v. Martin" on Justia Law

Jessica Gehner was implanted with a Cook Medical inferior vena cava (IVC) filter in Ohio. She later experienced abdominal pain, and a CT scan in March 2013 revealed that the filter had perforated her IVC. Her doctors recommended the filter's removal, which occurred in April 2013, but a fragment was left behind due to the filter fracturing. Gehner filed a lawsuit in May 2016 against Cook Incorporated, Cook Medical LLC, and William Cook Europe APS, alleging products liability and implied warranty claims. The defendants argued that her claims were time-barred under Ohio’s two-year statute of limitations.The United States District Court for the Southern District of Indiana granted the defendants' motion for judgment on the pleadings, which was converted to a summary judgment motion. The court concluded that Gehner's claims were time-barred, as she was informed by her doctors in March 2013 that the IVC filter caused her injury, starting the statute of limitations clock. Gehner contended that she was unaware of the defect until 2016 when her mother saw a television commercial about defective IVC filters.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court held that under Ohio law, the statute of limitations for product liability claims begins when the plaintiff is informed by competent medical authority of an injury related to the product or when the plaintiff should have known of the injury through reasonable diligence. The court found that Gehner was aware of her injury and its relation to the IVC filter by April 2013 at the latest. The court rejected Gehner's argument that the statute of limitations should start when she learned of the defect, noting that awareness of the injury itself was sufficient to start the clock. The court affirmed the district court's summary judgment in favor of the defendants, concluding that Gehner's claims were indeed time-barred. View "Gehner v. Cook Medical, LLC" on Justia Law