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

Three former satellite service technicians filed a class action lawsuit against their employer, DirectSat USA, LLC, alleging violations of the Illinois Minimum Wage Law (IMWL) and the Fair Labor Standards Act (FLSA). They claimed that DirectSat failed to compensate them for work-related tasks performed beyond forty hours per week. The district court initially certified a class of full-time Illinois DirectSat technicians but later vacated this certification and certified a Rule 23(c)(4) issue class to resolve fifteen questions related to DirectSat’s liability.The case was reassigned to another district judge in 2019. Before the trial, the district court decertified the Rule 23(c)(4) class. The plaintiffs settled their individual claims but reserved the right to appeal the decertification decision. The district court found that the class action was not a superior method for adjudicating the plaintiffs' controversy due to the variance in the amount of time technicians spent on work-related tasks and the individualized nature of their piece-rate compensation system.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that a party seeking certification of an issue class under Rule 23(c)(4) must show that common questions predominate in the resolution of the specific issues to be certified, not the entire cause of action. However, the court affirmed the district court’s decision to decertify the class, concluding that a class action was not a superior method for resolving the controversy due to the individualized nature of the claims and the necessity for numerous separate trials to determine liability and damages. View "Jacks v. DirectSat USA, LLC" on Justia Law

James Harris, with a significant criminal history, was on federal supervised release following a 2013 federal drug conviction. After his release in 2016, he was arrested and convicted in a state drug case, leading to the revocation of his federal supervised release. He was sentenced to one year in prison, followed by three years of supervised release. In 2020, Harris was arrested again on state gun charges, which led to further alleged violations of his federal supervised release conditions.The United States District Court for the Northern District of Illinois held a two-day evidentiary hearing in July 2023. The court found that Harris had violated the conditions of his supervised release by using controlled substances and failing to comply with the rules of a community corrections program. Additionally, the court found by a preponderance of the evidence that Harris had unlawfully possessed a firearm, despite his acquittal in the state gun case. The court sentenced Harris to 36 months in prison for the firearm violation and 24 months for the community corrections program violation, to be served concurrently, with no additional supervised release.The United States Court of Appeals for the Seventh Circuit reviewed the case. Harris argued that the district court lacked jurisdiction to rule on the supervised release violations and that procedural errors were made during the revocation hearing. The Seventh Circuit held that the district court had jurisdiction, as Harris's federal supervised release term was tolled during his five-month imprisonment for violating state supervised release. The court also found no procedural errors, concluding that Harris had admitted to the Salvation Army violations and that the district court did not rely on inaccurate information. The Seventh Circuit affirmed the district court's ruling. View "United States v. Harris" on Justia Law

The City of Chicago’s Department of Water Management hired Tinka Vassileva as a Filtration Engineer (FE) in 2001. Vassileva, who started as an FE II, was promoted to FE III in July 2019. She applied unsuccessfully for promotions to FE V in April 2018 and FE IV in July 2019. Vassileva claimed that the City’s decisions not to interview her for these positions were based on age, gender, national origin, and retaliation for previous discrimination charges she filed with the Illinois Department of Human Rights (IDHR) and the Equal Employment Opportunity Commission (EEOC).The United States District Court for the Northern District of Illinois granted summary judgment in favor of the City on all claims. The court found that Vassileva did not provide sufficient evidence that her age, gender, national origin, or EEOC charges motivated the City’s decision not to interview her for the 2018 FE V position. Additionally, the court concluded that Vassileva had not administratively exhausted her claims related to the 2019 FE IV openings, as she failed to file an EEOC charge based on the City’s 2019 actions before filing the lawsuit.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The appellate court held that Vassileva did not present evidence suggesting that the City’s explanation for not interviewing her in 2018 was pretext for discrimination or retaliation. The court also noted that Vassileva failed to show that the decision-maker was aware of her EEOC charges. Regarding the 2019 claims, the court found that Vassileva waived her argument about administrative exhaustion by not addressing it until oral argument. Thus, the appellate court affirmed the summary judgment in favor of the City. View "Vassileva v. City of Chicago" on Justia Law

Lafiamma Orona was indicted for mail theft, identity theft, and related crimes after a scheme involving the theft of mail, including credit cards and checks, from mailboxes in Elkhart County, Indiana. He pleaded guilty to all charges about six weeks before trial. Under the Sentencing Guidelines, a defendant who pleads guilty and admits their conduct can receive a two-point reduction in their offense level, with an additional one-point reduction possible if the government files a motion affirming that the defendant's acceptance of responsibility saved prosecutorial and court resources.The district judge awarded Orona the two-level reduction, but the prosecutor declined to move for the extra one-level reduction, citing Orona's baseless challenge to the loss amount, which required the government to prepare for a contested sentencing hearing. Orona objected, asking the judge to order the prosecutor to file the motion. The judge overruled the objection, holding that the government had permissibly withheld the motion based on Orona's frivolous challenge. This decision was consistent with circuit precedent, specifically United States v. Nurek and United States v. Sainz-Preciado.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's judgment. The court held that the Sentencing Commission's Amendment 775 did not abrogate the precedent set by Nurek and Sainz-Preciado. Therefore, the government was within its rights to withhold the motion for the additional one-level reduction under § 3E1.1(b) based on Orona's objections to the loss amount, which necessitated additional prosecutorial resources. The court concluded that the district judge correctly overruled Orona's objection and affirmed the judgment. View "United States v. Orona" on Justia Law

On the night of July 18, 2019, in Charlestown, Indiana, bystanders called 911 to report a fight between RJ Slaymaker and his wife, Amylyn Slaymaker. Two police officers responded, separated the couple, and learned from Amylyn that RJ was drunk, had hit her, had guns, and was threatening to kill her and himself. RJ denied the allegations. The officers called an ambulance for RJ to seek mental health help at a hospital but did not place him under a 24-hour mental health hold. RJ left the hospital shortly after arriving, returned home, and killed Amylyn before committing suicide.The administrator of Amylyn’s estate sued Officer Roederer and the estate of Officer Johnson, claiming they created a danger by misleading Amylyn into believing RJ would be held for 24 hours, thus making her believe it was safe to return home. The United States District Court for the Southern District of Indiana granted summary judgment to the defendants, concluding they were entitled to qualified immunity.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s judgment regarding Officer Roederer, finding no evidence of his personal involvement in making assurances to Amylyn. However, the court reversed the judgment regarding Officer Johnson, finding that a jury could reasonably infer that he misled Amylyn about RJ’s detention, creating a danger she would not have otherwise faced. The court held that Officer Johnson’s actions could be seen as a violation of clearly established law under the state-created danger doctrine, as established in Monfils v. Taylor. The case against Officer Johnson’s estate was remanded for further proceedings. View "Rakes v. Roederer" on Justia Law

A student at Rosalind Franklin University was accused of sexual assault by another student after a night of heavy drinking and marijuana use. The accused student, Nicholas Gash, had no memory of the events due to his intoxication. The university conducted an investigation, during which Gash received notices of allegations and participated in interviews. Despite attempting to withdraw from the university, Gash was informed that his withdrawal was not approved, and the Title IX hearing proceeded. The hearing panel found Gash responsible for the alleged assault and sanctioned him with expulsion.The United States District Court for the Northern District of Illinois dismissed Gash’s claims of sex-based discrimination under Title IX and breach of contract under Illinois law. The court found that the procedural errors cited by Gash did not suggest sex-based discrimination. Gash’s state law contract claims were also dismissed, as the court determined that he did not meet the high burden of showing that the university acted arbitrarily or in bad faith.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court affirmed the district court’s dismissal, holding that the procedural errors and alleged biases did not plausibly suggest sex-based discrimination. The court noted that the errors could indicate a pro-victim or pro-complainant bias but not an anti-male bias. Additionally, the court found that Gash did not provide sufficient evidence to support his breach of contract claim, as he failed to show that the university acted without a rational basis or in bad faith. The court concluded that the university’s actions, while flawed, did not constitute sex-based discrimination or breach of contract. View "Gash v. Rosalind Franklin University" on Justia Law

Michael Mogan, a condominium owner, challenged the City of Chicago's Shared Housing Ordinance, which prevented him from listing his unit on short-term rental platforms like Airbnb. Mogan claimed that the Ordinance constituted an unconstitutional taking and inverse condemnation under Illinois law. He also sought a declaratory judgment against the City and his homeowners association, Roscoe Village Lofts Association, to allow him to lease his unit on a short-term basis.The United States District Court for the Northern District of Illinois dismissed Mogan's takings and inverse condemnation claims and declined to exercise jurisdiction over any remaining state law claims. Mogan appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The court held that Mogan lacked standing to challenge the Ordinance because he failed to demonstrate a concrete and particularized injury. The court also found that Mogan's property rights were subject to the Declaration of Condominium Ownership, which prohibited leases of less than 30 days. Therefore, Mogan could not claim that the Ordinance interfered with any reasonable investment-backed expectations or caused any economic impact. The court concluded that the district court did not abuse its discretion in declining to exercise supplemental jurisdiction over the remaining state law claims. View "Mogan v. City of Chicago" on Justia Law

Andre Bowyer, a Jamaican national, pleaded guilty to re-entering the United States without permission after being previously removed. During his sentencing, Bowyer attempted to highlight his ties to a family he had formed in the U.S. The district judge interrupted him frequently, characterizing Bowyer's account as lacking insight and unconvincing. Bowyer received a below-guidelines sentence.Bowyer appealed, arguing that his right to make his own statement at sentencing was violated. He conceded that he did not object during the district court proceedings, so the review was limited to the plain-error standard. Bowyer did not specify what additional arguments he would have made if given more time. The district court had read a letter from Bowyer detailing his background and his relationship with the family, but the judge found this information irrelevant to the sentencing factors.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court noted that while the district judge's interruptions were frequent, they did not completely prevent Bowyer from speaking. The judge also solicited further comments from Bowyer at the end of the allocution. The court found that even if there was an error, it was not plain because there was no unambiguous case law against such interruptions. Additionally, Bowyer's arguments were already considered by the judge, and there was no indication that further allocution would have led to a different sentence.The Seventh Circuit concluded that Bowyer did not meet the plain-error test for reversal and affirmed the district court's decision. View "USA v. Bowyer" on Justia Law

Carl McDaniel, a Wisconsin prisoner with multiple serious medical conditions, sued the Wisconsin Department of Corrections under the ADA and the Rehabilitation Act, claiming the Department violated his rights by denying him a cell in a no-stairs unit, a single-occupancy cell, and a bed without a top bunk. He also brought an Eighth Amendment claim against Dr. Salam Syed, alleging deliberate indifference to his medical needs. The district court granted summary judgment for the Department on all claims and for Dr. Syed on the Eighth Amendment claim. McDaniel appealed.The United States District Court for the Eastern District of Wisconsin initially handled the case. McDaniel, representing himself, submitted evidence that he missed approximately 600 meals in one year due to the pain and difficulty of navigating stairs to access meals and medications. The district court, however, largely discounted McDaniel’s factual statements and granted summary judgment for the defendants, concluding that McDaniel’s cell assignment was reasonable and that his medical treatment did not violate the Eighth Amendment.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the summary judgment for the Department on the claims for a single-occupancy cell and no top bunk, as well as the Eighth Amendment claim against Dr. Syed. However, it reversed the summary judgment on the refusal to assign McDaniel to a no-stairs unit. The court found that McDaniel presented sufficient evidence that the denial of a no-stairs unit effectively denied him access to meals and medications, which could be seen as an intentional violation of the ADA and the Rehabilitation Act. The court also held that McDaniel’s ADA and Rehabilitation Act claims for compensatory damages survived his release from prison and his death.The Seventh Circuit concluded that a reasonable jury could find that the denial of a no-stairs unit amounted to an intentional violation of McDaniel’s rights under the ADA and the Rehabilitation Act, and that the Department was not entitled to sovereign immunity. The case was remanded for further proceedings consistent with this opinion. View "McDaniel v. Syed" on Justia Law

José Mireles was involved in a drug distribution conspiracy that transported large quantities of cocaine and heroin from Los Angeles to Chicago. Mireles's role included retrieving drug shipments, delivering them to customers, and laundering the proceeds back to Los Angeles. The Drug Enforcement Agency eventually dismantled the network, arresting Mireles and other conspirators. Mireles escaped custody while being transported to court but was re-arrested 18 months later. He was convicted and sentenced to 342 months in prison.The United States District Court for the Northern District of Illinois handled the initial trial. Mireles challenged the admission of certain evidence and the calculation of his sentence. The district court admitted evidence of Mireles's failure to file tax returns, his escape from custody, and a conversation about procuring a firearm. The court also calculated the drug quantity attributable to Mireles and applied sentencing enhancements for obstruction of justice and reckless endangerment.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed Mireles's conviction, finding no abuse of discretion in the admission of the challenged evidence. However, the court ordered a limited remand for resentencing. The appellate court could not discern the factual basis for one of the sentencing enhancements related to obstruction of justice. The court upheld the enhancement for reckless endangerment but required further proceedings to clarify the obstruction enhancement. The court vacated Mireles's sentence and remanded the case for further proceedings consistent with its opinion. View "United States v. Mireles" on Justia Law