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

Reginald Pittman, a pretrial detainee at the Madison County jail, attempted suicide and suffered a severe brain injury. He claimed that two guards ignored his requests for crisis counseling before his suicide attempt. Pittman sued Madison County and various jail officials under 42 U.S.C. § 1983, alleging a violation of the Fourteenth Amendment for failing to provide adequate medical care. The case has a lengthy procedural history, including three appeals and three trials.The United States District Court for the Southern District of Illinois initially granted summary judgment for the defendants, but this was reversed in part by the Seventh Circuit in Pittman I. After a first trial, the Seventh Circuit in Pittman II reversed and remanded for a new trial due to the erroneous exclusion of evidence. In Pittman III, the Seventh Circuit found a jury instruction error and remanded for a third trial. In the third trial, the district court instructed the jury in line with Pittman III, requiring proof that the officers were subjectively aware or strongly suspected a high likelihood of self-harm. The jury returned a verdict for the defendants.The United States Court of Appeals for the Seventh Circuit reviewed the case and found that the jury instruction was erroneous. The court clarified that Pittman did not need to prove subjective awareness of the risk of harm. Instead, the jury should have been instructed to determine whether the defendants made an intentional decision regarding Pittman’s conditions of confinement and whether they acted objectively unreasonably by failing to mitigate the risk. Despite this error, the court concluded that the erroneous instruction did not prejudice Pittman, as the case was presented as a credibility contest between the testimony of the guards and an inmate. Therefore, the Seventh Circuit affirmed the verdict for the defendants. View "Pittman v. Madison County, Illinois" on Justia Law

Karl Nichols was convicted in a Wisconsin state court of first-degree sexual assault and sentenced to five years of probation. The conviction was based on allegations by a child, M.R.W., who claimed Nichols touched her inappropriately during a sleepover years earlier. M.R.W. participated in two forensic interviews, during which she made notes to correct her initial statements. These notes were lost by the prosecution, leading Nichols to argue that the prosecution failed to preserve exculpatory evidence and that his trial counsel was ineffective for not raising this issue before trial.Initially, Nichols won relief in the state trial court, which found that the prosecution acted in bad faith by not preserving the notes and that the notes contained exculpatory evidence. The court vacated Nichols' conviction and dismissed the case with prejudice. However, the Wisconsin Court of Appeals reversed this decision, concluding that Nichols failed to demonstrate the exculpatory value of the missing notes. Nichols' petition for review by the Wisconsin Supreme Court was denied.Nichols then filed a federal habeas corpus petition in the Western District of Wisconsin. The district court denied relief, citing the deferential standard of review under 28 U.S.C. § 2254(d) and procedural default on the ineffective assistance claim. The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The Seventh Circuit held that the Wisconsin Court of Appeals reasonably concluded that the missing notes had no apparent exculpatory value and that the prosecution did not act in bad faith. The court also upheld the procedural default of Nichols' ineffective assistance of counsel claim. View "Nichols v. Wiersma" on Justia Law

Jebari Craig, a black employee, worked for Wrought Washer Manufacturing, Inc. from 2010 until his termination in April 2019. Craig, who became the union president in 2018, filed a racial discrimination grievance against Wrought. He alleged that his termination was in retaliation for this grievance. The incident leading to his termination involved a disagreement with a supervisor and subsequent use of his cell phone on the shop floor, which violated company policy. Craig was suspended and later offered a "Last Chance Agreement" to return to work, which he refused to sign, leading to his termination.The United States District Court for the Eastern District of Wisconsin granted summary judgment to Wrought on Craig's claim that his termination was retaliatory. The court found that Craig had not established a prima facie case of retaliation for his written warning and allowed his claim regarding his suspension to proceed. However, it granted summary judgment on the termination claim, crediting Wrought's explanation that the "Last Chance Agreement" did not require Craig to relinquish his discrimination claims, contrary to Craig's later assertions.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court affirmed the district court's judgment, agreeing that Schaefer, Wrought's plant manager, was confused during his deposition about the terms of the "Last Chance Agreement" and the severance agreement. The court found that Craig's declaration, which contradicted his earlier statements, did not create a genuine issue of material fact. The court concluded that no reasonable litigant would have withheld the information Craig later provided, supporting the district court's decision to grant summary judgment to Wrought. View "Craig v. Wrought Washer Manufacturing, Inc." on Justia Law

Samuel Boytor, an engineer and businessman, and his wife Carol, defaulted on loans they had personally guaranteed. They entered into a settlement agreement with EFS Bank’s successor, restructuring their debt into three new promissory notes secured by mortgages on their properties. PNC Bank, which eventually held these notes, filed a complaint in 2018 against the Boytors for defaulting on two of the notes. PNC sought foreclosure on the Boytors’ residential property and a money judgment for the nonpayment of a separate note.The United States District Court for the Northern District of Illinois held a bench trial and found in favor of PNC on both counts. The court ordered foreclosure on the Boytors’ residential property and issued a deficiency judgment after the property was sold. The Boytors appealed the decision.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The appellate court held that PNC had established a prima facie case for foreclosure by presenting the mortgage and underlying note. The Boytors’ affirmative defenses, including lack of consideration and payment of the notes, were rejected. The court found that the $203,000 note was supported by consideration and that the Boytors had not paid the note. Additionally, the court determined that the $200,000 note was not paid, and the release of the mortgage did not extinguish the underlying debt. The court also rejected the Boytors’ argument of accord and satisfaction, finding no evidence of a new arrangement to pay less than the outstanding debt. View "PNC Bank, National Association v. Boytor" on Justia Law

Gordon Green filed for Chapter 7 bankruptcy on May 11, 2021, listing his "Sun Life: Life Income Fund," a Canadian Registered Retirement Savings Plan, as an asset. Green sought to exempt the fund under Illinois statute 735 ILCS 5/12-1006, which exempts assets intended in good faith to qualify as a retirement plan under applicable provisions of the Internal Revenue Code (IRC). The bankruptcy trustee objected, arguing that the fund, organized under Canadian law, did not qualify for the exemption. The bankruptcy court agreed, holding that a retirement plan must be organized under IRC § 401(a), which requires the trust to be created or organized in the United States.Green appealed to the United States District Court for the Northern District of Illinois. The district court rejected the bankruptcy court's country-of-origin requirement but still found that the Sun Life Fund was not a tax-qualified retirement plan under the IRC. Consequently, the district court affirmed the denial of the exemption.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court examined whether the Sun Life Fund qualified as a retirement plan under applicable provisions of the IRC. The court noted that the IRC does not specifically define "retirement plan" for this purpose and that Illinois law requires the plan to qualify under applicable IRC provisions. The court found that the Sun Life Fund did not meet the criteria for tax-qualified retirement plans under the IRC, as it was not governed by any specific IRC provision that regulates retirement plans. The court affirmed the district court's decision, holding that the Sun Life Fund was not exempt under Illinois statute 735 ILCS 5/12-1006. View "Green v. Leibowitz" on Justia Law

Lorenzo Davis, a pretrial detainee at the McLean County Detention Facility, suffered serious eye injuries after being attacked by fellow detainees Wanyae Massey and Terrell Hibbler. Davis had reported threats and requested a transfer, but the identity of the officer he spoke to is unknown. On the morning of the attack, Officer Christopher Gibson placed cleaning supplies in the common area and left to supervise the recreation room. Massey and Hibbler used the cleaning supplies to beat Davis. Officer Gibson learned of the fight from a hall worker and passed the keys to Officer Billy Rook, who called for assistance and waited for backup before intervening.Davis sued Officers Gibson and Rook under 42 U.S.C. § 1983, alleging they violated the Due Process Clause of the Fourteenth Amendment by failing to protect him. The United States District Court for the Central District of Illinois granted summary judgment for the officers, finding that the evidence did not support the claim that a reasonable officer would have appreciated the risk to Davis. The court also found that Officer Rook acted reasonably by waiting for backup before intervening. The court did not address the defendants' qualified immunity defense.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s grant of summary judgment de novo. The court affirmed the lower court’s decision, holding that a reasonable officer in Officer Gibson’s position would not have perceived the risk of harm to Davis, as there was no evidence that Gibson knew about the threats or Davis’s request for a transfer. Additionally, the court found that Officer Rook acted reasonably by waiting for backup before intervening in the fight, as it was a standard and safe procedure. The court concluded that neither officer acted in an objectively unreasonable way under the circumstances. View "Davis v. Rook" on Justia Law

Demona Freeman secured a loan to purchase her home, which was assigned to the Bank of New York Mellon (BNY Mellon) and serviced by Ocwen Loan Servicing, LLC. After falling behind on her mortgage payments, BNY Mellon initiated a foreclosure action. Freeman filed for bankruptcy and eventually cured her mortgage default through bankruptcy payments. Despite this, Ocwen inaccurately reported her loan as delinquent and began rejecting her monthly payments, leading BNY Mellon to file a second foreclosure action, which was later dismissed. Freeman sued Ocwen and BNY Mellon, alleging violations of the Fair Credit Reporting Act (FCRA) and the Fair Debt Collection Practices Act (FDCPA).The United States District Court for the Southern District of Indiana dismissed Freeman’s FCRA claim and granted summary judgment on her FDCPA claim, citing lack of standing. Freeman appealed both rulings. She argued that Ocwen failed to conduct a reasonable investigation after being notified by consumer reporting agencies (CRAs) of her dispute over the delinquent loan reporting. She also claimed that Ocwen’s erroneous reporting and collection practices caused her various injuries.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s dismissal of the FCRA claim, finding that Freeman failed to specify which CRA she notified, thus not providing Ocwen fair notice of the claim. The court also upheld the summary judgment on the FDCPA claim, concluding that Freeman lacked standing. The court determined that Freeman did not provide sufficient evidence of concrete injuries, such as monetary harm or intangible injuries closely related to common law analogues like defamation or invasion of privacy. Consequently, the court affirmed the district court’s rulings. View "Freeman v. Ocwen Loan Servicing, LLC" on Justia Law

Dr. John Insall, an orthopedic surgeon, developed and patented knee replacement devices, which he licensed to Zimmer Biomet Holdings, Inc. In return, Zimmer agreed to pay royalties to Insall, and later to his estate after his death. When Insall’s last patent expired in 2018, Zimmer ceased royalty payments, claiming the obligation had ended. The dispute was submitted to arbitration, where the Estate prevailed. Zimmer then sought to vacate the arbitration award in district court, arguing that continuing royalty payments violated public policy. The district court confirmed the arbitration award.The United States District Court for the Northern District of Illinois reviewed the case. Zimmer argued that the arbitration award should be vacated based on public policy grounds, citing Supreme Court decisions in Brulotte v. Thys Co. and Kimble v. Marvel Entertainment, LLC, which prohibit collecting royalties on expired patents. The district court rejected Zimmer’s argument and confirmed the arbitration award, leading to Zimmer’s appeal.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court emphasized the limited scope of judicial review over arbitration awards under the Federal Arbitration Act (FAA). The court found that the arbitration panel had correctly interpreted the 1998 amendments to the agreement, which untethered the royalty payments from the patents themselves, making them based on the marketing and branding of the NexGen Knee products. Consequently, the court held that the arbitration award did not violate public policy as outlined in Brulotte and Kimble. The Seventh Circuit affirmed the district court’s decision and confirmed the arbitration award in favor of Insall’s Estate. View "Zimmer Biomet Holdings, Inc. v. Insall" on Justia Law

The Consumer Financial Protection Bureau (CFPB) brought an action against Townstone Financial, Inc. and its CEO, Barry Sturner, alleging that they discouraged black prospective applicants from applying for mortgage loans, violating Regulation B of the Equal Credit Opportunity Act (ECOA). The CFPB cited several statements made by Townstone on their radio show that it claimed would discourage black applicants. These statements included derogatory comments about predominantly black areas and other racially insensitive remarks. The CFPB also provided statistical evidence showing that Townstone received fewer mortgage applications from black applicants compared to its peers.The United States District Court for the Northern District of Illinois granted Townstone's motion to dismiss. The court held that the ECOA does not authorize liability for discouraging prospective applicants, focusing on the ECOA’s definition of "applicant" as someone who has applied for credit. The court concluded that the ECOA’s protections do not extend to prospective applicants who have not yet applied for credit.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 ECOA, when read as a whole, does authorize the imposition of liability for discouraging prospective applicants. The court found that the ECOA’s broad purpose of preventing discrimination in credit transactions includes actions taken before an application is submitted. The court also noted that the ECOA’s text and legislative history support the interpretation that discouraging prospective applicants is prohibited. The case was remanded for further proceedings consistent with this opinion. View "Consumer Financial Protection Bureau v. Townstone Financial, Inc." on Justia Law

Robert Smith pleaded guilty to conspiracy to distribute methamphetamine and money laundering conspiracy. Nearly eleven months later, on the eve of his sentencing, Smith's attorney filed a motion to withdraw at Smith's request, citing dissatisfaction with representation. The court denied the motion and refused to appoint substitute counsel. Smith was sentenced to 324 months in prison, below the guidelines range. He appealed the denial of his request for substitute counsel and the substantive reasonableness of his sentence.The United States District Court for the Southern District of Illinois initially scheduled Smith's sentencing for January 2023, but granted several continuances at Smith's request. The court eventually set the sentencing for July 12, 2023, and warned against further delays. On July 11, Smith's attorney filed a motion to withdraw, which the court denied after a hearing. The court found no breakdown in communication between Smith and his attorney, attributing the motion to a tactical delay. Smith's subsequent attempts to retain new counsel were unsuccessful, and his attorney represented him at sentencing.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the district court did not abuse its discretion in denying the motion for substitute counsel, noting the motion's untimeliness and the adequacy of the court's inquiry into Smith's concerns. The court also found that the disagreements between Smith and his attorney were strategic and did not constitute a total breakdown in communication. Additionally, the court ruled that Smith's below-guidelines sentence was substantively reasonable, given the district court's thorough consideration of the relevant factors. The judgment of the district court was affirmed. View "United States v. Smith" on Justia Law