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

The employer sought review by the federal district court and obtained a judicial order vacating an award on the ground that the arbitrator improperly applied external law to contradict the terms of the collective bargaining agreement (CBA). The Seventh Circuit reversed the judgment of the district court and upheld the arbitrator's award, holding that the text of the CBA permitted the arbitrator to look to external law in interpreting the agreement. The court held that the language contained in the preamble of the CBA suspended any part of the CBA that either the company or union believed to conflict with state law. In this case, while the court would have preferred that the arbitrator cite to that language before applying the Concealed Carry Act to reinstate the employee, the extraordinarily deferential standard of review compelled the court to uphold the award. View "Ameren Illinois Co. v. International Brotherhood of Electrical Workers" on Justia Law

Plaintiff, an Illinois state prisoner, filed suit under 42 U.S.C. 1983, alleging that prison officials conspired to and did violate his First and Eighth Amendment rights while he was incarcerated at the Menard Correctional Center. The Seventh Circuit affirmed in part the district court's grant of defendants' motion for summary judgment, holding that no reasonable jury could conclude that plaintiff's grievances and complaints about the conditions of his confinement were a motivating factor in—or even factored into—Defendant Harrington's approval of placing him in segregation after a May 2012 incident. The court also held that no reasonable jury could find that Defendants Harrington or Page acted with deliberate indifference towards plaintiff or otherwise disregarded or failed to act on knowledge of a substantial risk to plaintiff's health and safety. Finally, plaintiff failed to identify any evidence, circumstantial or otherwise, of an agreement to deprive him of his constitutional rights. View "Daugherty v. Harrington" on Justia Law

The Seventh Circuit affirmed the district court's grant of defendants' motion for summary judgment in an action alleging claims under the Age Discrimination in Employment Act (ADEA), 42 U.S.C. 1983, and Illinois law. Plaintiff filed suit on behalf of himself and a certified class of similarly situated part-time and adjunct faculty, challenging Oakton Community College's change in hiring practices such that the college would no longer employ retired state employees if they were also beneficiaries of the State University Retirement System.In regard to the ADEA claim, the court held that the district court applied the appropriate burden of proof where the ADEA and the cases interpreting it make clear that a policy may have a disparate impact on older workers as long as the employer shows that the policy was based on a reasonable factor other than age (RFOA); the district court correctly concluded that a reasonable jury would be compelled to find that Oakton's reason was an RFOA; and the district court properly required defendants to prove that Oakton's policy was, in fact, based on reasonable factors other than age. Likewise, the section 1983 claim failed because there was no ADEA violation. Finally, plaintiff's retaliatory discharge claim lacked merit. View "Dayton v. Oakton Community College" on Justia Law

The Seventh Circuit affirmed the district court's grant of summary judgment for defendants after defendants refused to provide school transportation (or equivalent cash benefits) to plaintiffs' children. The court held that the record did not establish that the Superintendent or the school district furnished or withheld public benefits on the basis of non-neutral religious criteria; nor did the evidence support the claim that public officials impermissibly determined the school's affiliation on the basis of theology, ecclesiology, or ritual; but, rather, it showed that public officials applied a secular statute that limits benefits to a single school affiliated with any sponsoring group. In this case, St. Augustine declared itself to be Catholic. View "St. Augustine School v. Evers" on Justia Law

The Seventh Circuit affirmed the district court's dismissal of an action alleging the violation of the Equal Protection Clause of the Fourteenth Amendment because the county placed a disproportionate tax on commercial and industrial properties in Mattoon Township. The court analyzed plaintiffs' claim solely on comity principles and held that the district court appropriately abstained from hearing the action. View "Perry v. Coles County, Illinois" on Justia Law

The Seventh Circuit affirmed defendant's motion to dismiss an action alleging that defendant tortiously interfered with plaintiff's employment contract and knowingly misrepresented company policy, both of which resulted in plaintiff's termination. The court held that the corporate officer privilege was inapplicable here; plaintiff failed to allege facts sufficient to establish the element of intentional inducement; the district court accurately held that plaintiff failed to state a claim for tortious interference with contract; plaintiff failed to allege a common law fraud claim; plaintiff was not entitled to leave to amend at this stage; and plaintiff's counsel's actions did not warrant sanctions under Judicial Code 1927. View "Webb v. Frawley" on Justia Law

After plaintiffs successfully prosecuted their cases, the Treasury Department determined that plaintiffs had outstanding debts to various government entities. However, plaintiffs had assigned to counsel any legal fees to which they might be entitled under the Equal Access to Justice Act (EAJA). The Treasury Department, rather than paying out the fees directly, reduced plaintiffs' debts by equal amounts under the Treasury Offset Program and thus the attorneys received nothing.The Seventh Circuit held that it would be imprudent to entertain new administrative claims that were only minimally related to the judgments, and declined to exercise ancillary jurisdiction over plaintiffs' collateral challenges to the regulations. Accordingly, the court affirmed the district courts' judgments. In this case, the district courts properly granted attorney fees under the EAJA, and the government properly applied those fees to plaintiffs' outstanding debts. View "Harrington v. Berryhill" on Justia Law

The Seventh Circuit affirmed the district court's denial of defendant's motion to suppress evidence after he pleaded guilty to one count of possession with intent to distribute a controlled substance. The court held that the search was supported by the officers' good faith reliance on then-existing circuit precedent in United States v. Hines, 449 F.3d 808 (7th Cir. 2006). The court explained that, at the time the officers brought the dog onto plaintiff's driveway to conduct the sniff, Hines permitted the warrantless search of a vehicle parked close to a house on the defendant's private driveway so long as there was probable cause to believe that the search would uncover contraband or evidence of a crime. View "United States v. Velazquez" on Justia Law

Under the Prison Litigation Reform Act of 1995 (PLRA), “[n]o action shall be brought with respect to prison conditions under [42 U.S.C. 1983], … until such administrative remedies as are available are exhausted.” Ramirez, who is a Spanish speaker, sued administrators and officers of the Western Illinois Correctional Center under 42 U.S.C. 1983 for alleged constitutional wrongs. As a prisoner. he was subject to the PLRA’s exhaustion requirement. Western Illinois had administrative remedies available. Ramirez did not use those procedures in a timely fashion to complain about the issues raised in his federal action. Ramirez claimed that the existing grievance process was unavailable to him because they were described to him only in a language that prison officials knew he did not understand. The district court held an evidentiary hearing, then dismissed Ramirez’s complaint without prejudice. The Seventh Circuit reversed. Because no administrator or officer of Western Illinois ever informed Ramirez of its grievance process in a way that he might reasonably understand, that process was unavailable to him and he was excused from the PLRA’s exhaustion requirement. View "Ramirez v. Young" on Justia Law

Iowa closed the Iowa Girls State Training School. Palmer, Director of the Iowa Department of Human Services, subsequently contracted to use the Wisconsin Girls State Training School (Copper Lake). Plaintiffs claim that, since its 2011 opening, Cooper Lake “has had a very high turnover rate of employees,” leading to “over-worked and untrained staff” and has received criticism from Wisconsin judges regarding its “sordid” and “inhumane” treatment of juveniles. Iowa juvenile courts ordered Plaintiffs to be placed at Copper Lake in 2015. Both were 16 years old. Plaintiffs claim that Copper Lake subjected them to prolonged “isolation,” and that they received little or no educational instruction. Both attempted suicide. Plaintiffs also claim they were subjected to excessive force and that staff sprayed them with mace on multiple occasions. Plaintiffs sued under 42 U.S.C. 1983 for cruel and unusual punishment, excessive force, and deprivation of due process. The Seventh Circuit reversed the dismissal of their claims. The district court acted prematurely in deciding Palmer’s entitlement to qualified immunity at the motion to dismiss stage. At the time plaintiffs were allegedly in Palmer’s custody, isolation of pre-trial juvenile detainees not “reasonably related to a legitimate governmental objective”could rise to the level of a constitutional violation. On the record, it is impossible to determine whether such a constitutional violation occurred in plaintiffs’ cases. View "Reed v. Palmer" on Justia Law