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

A Wisconsin prisoner, Armin Wand III, developed appendicitis in February 2018. He was seen by Nurse Beckey Kramer on February 13, 2018, but she did not diagnose appendicitis at that time. The next day, February 14, she recognized the symptoms and sent him to the hospital for emergency surgery. Wand sued Kramer and other officials, claiming inadequate medical care under the Eighth Amendment and state law negligence for not recognizing his need for emergency care on February 13.The United States District Court for the Western District of Wisconsin denied summary judgment for Kramer and another defendant, allowing the case to proceed to trial. The court recruited an experienced lawyer for Wand, but only for settlement purposes. After settlement efforts failed, the lawyer withdrew, and Wand's subsequent motion for recruitment of another lawyer was denied. The court noted Wand's legal blindness and severe stutter but believed he could represent himself with the court's assistance.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that Wand's trial testimony contradicted his earlier claims, stating he did not report lower right quadrant pain to Kramer on February 13, which was crucial for diagnosing appendicitis. The court concluded that Wand's case was substantively weak and that he had not shown prejudice from the lack of recruited counsel. The court affirmed the district court's judgment in favor of Kramer, holding that Wand did not demonstrate a reasonable likelihood that the presence of counsel would have changed the trial's outcome. View "Wand v. Kramer" on Justia Law

Malcolm Wilson, an inmate at Indiana State Prison, was involved in an altercation where he grabbed another inmate's cane to defend himself, causing the other inmate to fall and require medical attention. Wilson was charged with battery and, after a disciplinary hearing conducted by Lieutenant Angelita Castaneda, was found guilty. Castaneda imposed a sentence that included 90 days in restrictive housing, a demotion in credit class, and up to $100,000 in restitution for medical costs.The United States District Court for the Northern District of Indiana dismissed Wilson's pro se complaint at the screening stage under 28 U.S.C. § 1915A, finding that there was sufficient evidence to support the restitution order. Wilson's motion for reconsideration was also denied. Wilson appealed the dismissal, arguing that the restitution amount was not supported by any evidence.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo, accepting the factual allegations in Wilson's complaint as true. The court found that the evidence presented at the disciplinary hearing, including Wilson's statements, video footage, and staff conduct reports, constituted "some evidence" to support the restitution order. The court held that the procedural requirements of due process were met, as Wilson received notice of the charges, an opportunity to defend himself, and a written statement of the evidence and reasons for the disciplinary action. The court affirmed the district court's judgment, concluding that Wilson received the process he was due. View "Wilson v. Castaneda" on Justia Law

Kara Mitchell, a laboratory technician at Exxon Mobil Corporation, was terminated in 2020 after a little over a year of employment. ExxonMobil claimed her termination was due to poor performance compared to her peers in the company's annual employee assessment process. Mitchell alleged that her termination was due to sex discrimination and sued the company under Title VII of the Civil Rights Act of 1964.The United States District Court for the Northern District of Illinois granted summary judgment in favor of ExxonMobil, concluding that Mitchell failed to provide sufficient evidence to support her claim of sex discrimination. Mitchell appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case and upheld the district court's decision. The appellate court found that Mitchell did not present enough evidence to show that she was treated less favorably than similarly situated male employees. The court noted that Mitchell's comparators, two male lab technicians, were not similarly situated because they were not part of the same assessment group. Additionally, the court found that Mitchell failed to prove that ExxonMobil's reason for her termination was pretextual.The Seventh Circuit also considered Mitchell's argument under the holistic approach articulated in Ortiz v. Werner Enterprises, Inc., but concluded that there was no evidence of a pattern or practice of sex discrimination at the Cicero plant. The court affirmed the district court's grant of summary judgment to ExxonMobil, finding that no reasonable jury could conclude that Mitchell was terminated because of her sex. View "Mitchell v Exxon Mobil Corp." on Justia Law

In June 2023, the Town Board of Thornapple, Wisconsin decided to stop using electronic voting machines and switched to paper ballots for elections. This change was implemented in the 2024 federal primary elections. The United States sued the Town and certain officials, alleging that they failed to provide at least one accessible voting system for individuals with disabilities, as required by section 301 of the Help America Vote Act of 2002 (HAVA). The United States also sought and obtained a preliminary injunction from the district court, requiring the Town to provide a HAVA-compliant system in the November 2024 federal election.The United States District Court for the Western District of Wisconsin granted the preliminary injunction, rejecting the Town's arguments that paper ballots did not fall under HAVA's purview and that the government failed to show a likelihood of irreparable harm. The court found that the Town's actions would likely deprive individuals with disabilities of the opportunity to vote independently and privately, as required by HAVA.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's decision, holding that the Town's use of paper ballots constitutes a "voting system" under HAVA. The court found that the government demonstrated a likelihood of success on the merits and a likelihood of irreparable harm. The court concluded that the Town's actions would likely deprive individuals with disabilities of the opportunity to vote independently and privately, thus violating HAVA's requirements. The preliminary injunction was upheld, requiring the Town to provide an accessible voting system in the upcoming election. View "United States v. Town of Thornapple" on Justia Law

Michael Mogan, an attorney, sued Airbnb in California state court on behalf of a client in 2018. After the case went to arbitration, Mogan filed a separate lawsuit against Airbnb for abuse of process and unfair business practices, which was dismissed, and he was sanctioned for filing a frivolous lawsuit. When Mogan refused to pay the sanctions, the California State Bar filed disciplinary charges against him. Law360, a legal news website, published three articles detailing these legal battles between 2022 and 2023.Mogan then sued Portfolio Media, the owner of Law360, for defamation and false light in the United States District Court for the Northern District of Illinois. Portfolio Media filed a motion to dismiss, arguing that Law360’s coverage was protected by the fair report privilege. Mogan moved to amend his complaint to include additional statements from the first article, but the district court dismissed the complaint for failure to state a claim and denied leave to amend, deeming it futile.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court affirmed the district court’s decision, holding that the fair report privilege protected Law360’s articles. The court found that Mogan failed to demonstrate how the articles were not a fair abridgment of official proceedings. The court concluded that the statements in the articles accurately recounted judicial proceedings and thus could not support a defamation or false light claim. Consequently, Mogan’s complaint and proposed amendments were deemed futile, and the dismissal was affirmed. View "Mogan v. Portfolio Media Inc." on Justia Law

Nicholas Karagianis was indicted on federal drug and firearm charges and later entered into a plea agreement, pleading guilty to all counts. The plea agreement stipulated a final offense level of 31 under the United States Sentencing Guidelines. However, the presentence report (PSR) recommended a final offense level of 33 due to an additional two-level firearm enhancement. The district court adopted the PSR’s recommendation and imposed a below-guideline sentence. Karagianis subsequently sent a letter to the court, claiming he was misled by his counsel about how his sentence would be calculated.The United States District Court for the Southern District of Indiana conducted a combined change-of-plea and sentencing hearing. During the hearing, the court confirmed that Karagianis understood the plea agreement and its terms, including that the court was not bound by the stipulations in the agreement. The court adopted the PSR’s recommendation of a final offense level of 33 and imposed a sentence of 168 months for Counts 1 and 2, and 120 months for Count 3, to be served concurrently.The United States Court of Appeals for the Seventh Circuit reviewed the case. Karagianis raised three arguments on appeal: that he entered his guilty plea unknowingly due to the district court’s failure to inform him about the waiver of his right to appeal an adverse ruling on a § 3582(c)(2) motion, that the court did not explain the impact of the PSR on sentencing, and that the government breached the plea agreement by not objecting to the PSR’s recommended offense level. The Seventh Circuit affirmed the district court’s judgment, finding no plain error in the district court’s actions and concluding that any potential breach by the government did not affect Karagianis’s substantial rights or the fairness of the judicial proceedings. View "United States v. Karagianis" on Justia Law

A female student at the University of Wisconsin-Madison, Isabelle Arana, alleged that she was sexually assaulted by two football players, Quintez Cephus and Danny Davis III. Following an investigation, the university expelled Cephus for sexual assault and harassment. However, after Cephus was acquitted in a state court trial on a related charge, he petitioned for readmission, citing new evidence. The university's Chancellor readmitted Cephus without consulting Arana or reviewing the full trial transcript, allegedly under pressure from influential donors and the football program.The United States District Court for the Western District of Wisconsin granted summary judgment in favor of the university, dismissing Arana's Title IX claim. The court acknowledged that a jury could find the university acted with deliberate indifference if it readmitted Cephus due to public pressure. However, it concluded that Arana could not show the harassment deprived her of educational opportunities, citing her continued academic success.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that there was a genuine dispute as to whether the harassment Arana experienced was severe and whether the university's response was clearly unreasonable, potentially having a detrimental effect on her education. The court noted that Arana's fear of encountering Cephus led her to avoid certain campus areas, skip classes, and delay her graduation, which could be seen as a deprivation of educational opportunities. The court also highlighted the suspicious timing of Cephus's readmission and the university's failure to involve Arana in the process. The Seventh Circuit reversed the district court's summary judgment and remanded the case for further proceedings. View "Arana v. Board of Regents of the University of Wisconsin" on Justia Law

Jason Rahimzadeh was injured while riding his bicycle and sought underinsured motorist (UIM) coverage from his employer's commercial automobile insurance policy with Ace American Insurance Company. Ace denied the claim, stating that Rahimzadeh did not qualify as an insured under the policy. Rahimzadeh then filed a lawsuit in Illinois state court, alleging breach of the insurance contract. Ace removed the case to the United States District Court for the Northern District of Illinois, which granted Ace's motion to dismiss for failure to state a claim.The district court found that the terms of the insurance policy were unambiguous and that Rahimzadeh did not meet the policy's requirement of "occupying" a covered vehicle to qualify as an insured. The court also rejected Rahimzadeh's argument that the occupancy requirement was unenforceable as contrary to public policy, distinguishing the case from Galarza v. Direct Auto Insurance Co., which involved a personal automobile insurance policy. The court relied on Stark v. Illinois Emcasco Insurance Co., which upheld occupancy requirements in commercial policies.The United States Court of Appeals for the Seventh Circuit reviewed the district court's decision de novo. The court affirmed the district court's judgment, holding that the occupancy requirement in the commercial automobile insurance policy was permissible and did not violate Illinois public policy. The court distinguished the case from Galarza, noting that the public policy concerns in personal insurance policies do not apply to commercial policies. Therefore, Rahimzadeh was not entitled to UIM coverage under his employer's policy. The court also declined to certify the question to the Supreme Court of Illinois, finding no genuine uncertainty about the state law issue. View "Rahimzadeh v. Ace American Insurance Co." on Justia Law

Dr. Alan Braid, a Texas OB/GYN, admitted in a Washington Post editorial to performing an abortion in violation of the Texas Heartbeat Act (S.B. 8). This led to three individuals from different states filing lawsuits against him under the Act's citizen-suit enforcement provision, seeking at least $10,000 in statutory damages. Facing potential duplicative liability, Dr. Braid filed a federal interpleader action in Illinois, seeking to join the claimants in a single suit and also sought declaratory relief to declare S.B. 8 unconstitutional.The United States District Court for the Northern District of Illinois dismissed Dr. Braid’s suit, citing the Wilton-Brillhart abstention doctrine due to the existence of parallel state-court proceedings. The court reasoned that the Texas state courts were better suited to resolve the issues, particularly given the unique enforcement mechanism of S.B. 8. The district court also questioned whether Dr. Braid had a reasonable fear of double liability but ultimately found that it had jurisdiction before deciding to abstain.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The appellate court agreed that the district court had jurisdiction over the interpleader action but concluded that abstention was appropriate under the Colorado River doctrine, which allows federal courts to defer to parallel state-court proceedings in exceptional cases. The court emphasized that the Texas courts were better positioned to resolve the complex state-law issues and that abstention would avoid piecemeal litigation and conflicting judgments. The court also noted that the Texas courts could adequately protect Dr. Braid’s rights and that the federal suit appeared to be an attempt to avoid the state-court system. View "Braid v. Stilley" on Justia Law

Best Inn Midwest, LLC (Best Inn) owned and operated a hotel in Indianapolis, Indiana, which faced numerous issues, including health code violations and criminal activity. In 2017, Best Inn purchased a commercial property insurance policy from Ohio Security Insurance Company (Ohio Security). The policy excluded coverage for vandalism if the building was vacant for sixty consecutive days or more. Best Inn filed a claim for vandalism to air conditioning units on the hotel’s roof, which Ohio Security denied, citing vacancy. Ohio Security requested information about the hotel's occupancy, which Best Inn failed to provide, leading Ohio Security to file a suit seeking a declaration that the policy did not cover the claim.The United States District Court for the Southern District of Indiana granted Ohio Security's motion for summary judgment on Best Inn's counterclaim for bad faith. The court found that Best Inn had failed to comply with discovery requests and court orders, leading to a sanction declaring the hotel vacant during the relevant period. This finding was based on Best Inn's repeated failure to provide requested documents and information, despite numerous attempts by Ohio Security to obtain them.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 district court did not abuse its discretion in imposing sanctions and declaring the hotel vacant. This declaration meant that the insurance policy did not cover the vandalism claim, and thus, Ohio Security was entitled to summary judgment on Best Inn's bad faith counterclaim. The appellate court concluded that the sanctions were appropriate and proportionate to Best Inn's conduct, and there were no remaining disputes as to any material fact. View "Ohio Security Insurance Company v Best Inn Midwest, LLC" on Justia Law