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

In January 2021, Bertrand Nedoss, an 87-year-old resident of an assisted-living facility in Morton Grove, Illinois, wandered out of the facility, developed hypothermia, and died of cardiac arrest. His estate filed a negligence and wrongful-death lawsuit against Welltower Tenant Group, the facility’s owner, and Frontier Management, its operator. Welltower and Frontier were insured under a "claims made" policy by Church Mutual Insurance Company, effective from July 1, 2020, to July 1, 2021. The estate filed the lawsuit in October 2021, after the policy expired. However, nine days after Bertrand’s death, an attorney for the Nedoss family sent a letter to the facility, claiming an attorney’s lien and demanding evidence preservation.The United States District Court for the Northern District of Illinois ruled that the attorney’s letter qualified as a "claim" under the policy, triggering Church Mutual’s duty to defend. The court entered partial summary judgment for Welltower and Frontier and stayed the rest of the federal case pending the outcome of the state lawsuit.The United States Court of Appeals for the Seventh Circuit reviewed the case. On the eve of oral argument, Welltower and Frontier settled with the estate, and the state-court case was dismissed. This development mooted the appeal. The stay order was the only possible basis for appellate jurisdiction, and the partial summary judgment was not a final order. The Seventh Circuit dismissed the appeal as moot, noting that the dismissal of the state-court case removed the justification for the stay and rendered any appellate ruling on the stay irrelevant. View "Church Mutual Insurance Company v. Frontier Management, LLC" on Justia Law

Ricky Patterson was convicted by an Illinois jury in 2003 for first-degree murder, arson, and felony concealment of a homicide related to the 2002 death of Derrick Prout. Patterson had arranged to buy marijuana from Prout, who went missing after their meeting. Evidence showed Patterson killed Prout, attempted to clean the crime scene, set his house on fire, and later burned Prout’s car with the body inside. DNA evidence linked Prout’s blood to Patterson’s home. Patterson was sentenced to 55 years in prison, and the Illinois Supreme Court affirmed the judgment.Patterson filed a petition for state postconviction relief and a motion for additional DNA testing, which led to protracted state court proceedings. The Illinois Appellate Court affirmed the denial of his postconviction petition but remanded for further DNA testing, which confirmed the initial DNA match. Patterson’s subsequent appeals were denied, and his motion to file a late petition for leave to appeal was also rejected by the Illinois Supreme Court.The United States Court of Appeals for the Seventh Circuit reviewed Patterson’s federal habeas petition, which was filed more than six years after the one-year limitation period had expired, even accounting for tolling. Patterson argued for an exception based on actual innocence, but the court found his evidence insufficient to meet the demanding standard required to bypass the time bar. The court affirmed the district court’s dismissal of Patterson’s habeas petition as untimely, concluding that the new evidence presented did not establish a probability that no reasonable juror would have found him guilty. View "Patterson v. Adkins" on Justia Law

Dr. Judith Robinson, a former employee of HealthNet, a federally qualified health center in Indiana, brought a qui tam action against HealthNet, alleging fraudulent billing practices, including improper Medicaid billing for ultrasound readings. She claimed that HealthNet billed Medicaid for face-to-face encounters that did not occur. Dr. Robinson initially filed a suit in 2013 (Robinson I), which was settled in 2017, excluding the wrap-around claims. These claims were dismissed without prejudice, allowing for future litigation.In 2019, Dr. Robinson filed a new suit (Robinson II) to address the wrap-around claims. The United States declined to intervene, but Indiana did. Indiana moved to dismiss all claims except for the wrap-around claims from October 18, 2013, to February 28, 2015, as the rest were time-barred. The district court dismissed Count III of Dr. Robinson's complaint, which sought to enforce an alleged oral settlement agreement, due to lack of standing, as Dr. Robinson failed to provide competent proof of the agreement's existence.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's dismissal of Count III, agreeing that Dr. Robinson lacked standing because she did not demonstrate any breach of the alleged oral agreement by HealthNet. The court also upheld the district court's approval of the settlement between Indiana and HealthNet, finding it fair, adequate, and reasonable. The court noted that the reduction in the relator’s share was due to Dr. Robinson's own actions, including the failure to obtain a tolling agreement, which led to many claims being time-barred. The court also agreed with the application of the Federal Medical Assistance Percentage (FMAP) in calculating the settlement amount. View "Robinson v. Healthnet, Inc." on Justia Law

Eulalia Mateo-Mateo and her two minor children, all Guatemalan citizens, sought asylum, humanitarian asylum, withholding of removal, and relief under the Convention Against Torture (CAT) in the United States. Mateo claimed that the mother of her children's father had physically and verbally abused her and would continue to do so if she returned to Guatemala. Mateo and her children were apprehended by U.S. Customs and Border Patrol upon arrival, and the Department of Homeland Security initiated removal proceedings. They conceded removability, and Mateo applied for asylum and related relief.An Immigration Judge (IJ) held a hearing and found Mateo credible but denied her applications. The IJ concluded that Mateo did not demonstrate past persecution or a well-founded fear of future persecution on account of a protected ground. The IJ also found that Mateo did not establish that the Guatemalan government was unable or unwilling to protect her. Mateo appealed to the Board of Immigration Appeals (Board), which affirmed the IJ's decision, finding no clear error in the IJ's findings and deeming Mateo's claim for CAT relief waived due to lack of meaningful identification of error.The United States Court of Appeals for the Seventh Circuit reviewed both the IJ's and the Board's opinions. The court found that Mateo's claims for asylum, humanitarian asylum, and withholding of removal failed for two independent reasons: she did not challenge the finding that the Guatemalan government was not unable or unwilling to protect her, and substantial evidence supported the finding that she did not experience persecution on account of a protected ground. The court also concluded that Mateo's CAT claim failed on exhaustion grounds, as she did not challenge the Board's finding of waiver. Consequently, the Seventh Circuit denied the petition for review. View "Mateo-Mateo v. Garland" on Justia Law

Nathaniel Pryor was stopped by police in Aurora, Illinois, after officers received a tip about drug activity linked to a van. Pryor exited the van quickly, and an officer ordered him to the ground, took him down, struck him twice, and searched him. No drugs were found, and Pryor was charged with obstructing/resisting a police officer, but the charge was later dropped. Pryor then sued several officers and the City of Aurora, alleging multiple federal and state law claims, including under 42 U.S.C. § 1983.The United States District Court for the Northern District of Illinois granted in part the defendants' motion for summary judgment, dismissing some claims and allowing others to proceed to trial. At trial, the jury found in favor of the defendants on the remaining claims. Pryor appealed, arguing that the district court erred in its summary judgment decision and in various evidentiary and procedural rulings during the trial.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the district court did not err in granting summary judgment on Pryor’s false arrest claim, finding that the officers had probable cause to arrest him for obstruction of justice and resisting arrest. The court also upheld the district court’s decision to grant qualified immunity to the officer for the leg sweep and tackle, as Pryor failed to show that the use of force was clearly established as excessive under the circumstances. Additionally, the court found that the searches conducted by the officer were proper incidents to Pryor’s arrest and were not extreme or patently abusive.The Seventh Circuit also affirmed the district court’s evidentiary and procedural rulings, including the admission of drug surveillance evidence, the exclusion of certain testimony by Pryor, and the handling of jury instructions. The court concluded that the district court did not abuse its discretion in these decisions and that any errors were harmless. The judgment of the district court was affirmed in full. View "Pryor v. Corrigan" on Justia Law

Henry Jones, a prisoner, filed a lawsuit against nurse Amanda Lamb, alleging that she refused to provide him medical treatment for a broken hand and later denied him pain medication. Jones claimed he could not exhaust administrative remedies because prison officials did not deliver responses to his grievances. Lamb raised the affirmative defense of failure to exhaust administrative remedies under the Prison Litigation Reform Act (PLRA).The United States District Court for the Central District of Illinois granted summary judgment in favor of Lamb, concluding that Jones had unexhausted administrative remedies available for both claims. The court found Jones's assertion that he did not receive the grievance responses not credible, particularly because he had attached his counselor's response to his complaint.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that there was a genuine dispute of material fact regarding whether administrative remedies were available to Jones for his medical treatment claim. Specifically, the court found that Jones's declaration that he did not receive the warden's decisions created a genuine issue of fact that should have precluded summary judgment. Therefore, the court reversed the district court's decision on this claim and remanded for an evidentiary hearing to resolve the exhaustion dispute.However, the court affirmed the district court's decision regarding Jones's pain medication claim. Jones did not contest that he received a response directing him to resubmit his grievance and failed to do so. Thus, the court concluded that Jones had unexhausted administrative remedies available for this claim.The Seventh Circuit affirmed in part, reversed in part, and remanded the case for further proceedings consistent with its opinion. View "Jones v. Lamb" on Justia Law

Charles Curry, Jr., a former competitive powerlifter and bodybuilder, started a nutritional supplements business called Get Diesel Nutrition in 2002. He began selling a testosterone-boosting supplement called "Diesel Test" in 2005. Revolution Laboratories, LLC, founded by Joshua and Barry Nussbaum, also sold a supplement called "Diesel Test" starting in 2016. Curry, acting without a lawyer, filed a lawsuit against Revolution and the Nussbaums in 2017, asserting trademark claims under the federal Lanham Act and Illinois common law. Curry later obtained counsel, and the case proceeded to a jury trial in May 2023, resulting in a verdict for Curry.The jury awarded Curry $2,500 in actual damages for loss of goodwill and reputation and $500,000 as disgorgement of Revolution’s profits from the infringement. Additionally, the jury awarded Curry $300,000 in punitive damages against each of Joshua, Barry, and Revolution, totaling $900,000. The district court later ruled that disgorgement of profits under the Lanham Act is an equitable remedy for the judge to decide and recalculated the appropriate profits award to be $547,095.44.The United States Court of Appeals for the Seventh Circuit reviewed the case. Defendants challenged the district court's decision to allow Curry's punitive damages request to go to the jury and argued that the punitive damage awards were excessive in violation of the Fourteenth Amendment’s due process clause. The Seventh Circuit affirmed the district court's decision, holding that the district court did not abuse its discretion in allowing Curry to seek punitive damages and that the punitive damage awards were not unconstitutionally excessive. The court concluded that the ratio of punitive damages to the combined compensatory and disgorgement awards was constitutionally permissible. View "Curry v. Revolution Laboratories, LLC" on Justia Law

Amra Schmitz, a 52-year-old former public relations representative, applied for Social Security disability benefits in February 2020, claiming disability since January 2018. After a telephonic hearing, the Administrative Law Judge (ALJ) applied the five-step disability analysis and concluded that despite Schmitz's limitations and inability to perform her past job, there were still jobs she could perform. The ALJ found that Schmitz had severe impairments but did not meet the criteria for disability. The ALJ determined that Schmitz could perform light work with certain restrictions and identified six types of unskilled jobs she could do.The Appeals Council denied review of the ALJ's decision, and Schmitz filed suit in the United States District Court for the Central District of Illinois. Schmitz argued that the ALJ's decision was not supported by substantial evidence, particularly criticizing the vocational expert's (VE) testimony regarding the number of available jobs. The district court found that Schmitz had forfeited this objection by not raising it during the hearing or in post-hearing briefs and upheld the ALJ's decision.The United States Court of Appeals for the Seventh Circuit reviewed the district court's decision de novo, applying the same deferential standard. The court noted that Schmitz did not object to the VE's testimony during the hearing, thus forfeiting her objection. The court found that the VE's testimony was coherent, plausible, and based on her expertise. The court also determined that the ALJ had no duty to further investigate the VE's job-number estimates in the absence of an objection. The court concluded that the ALJ's decision was supported by substantial evidence and affirmed the district court's judgment. View "Schmitz v. Colvin" on Justia Law

Capitol Street Surgery Center, an outpatient surgical clinic, hired Marty Lauster, a licensed interventional radiology technologist (IR tech), in 2019. In November 2020, during a staff meeting, Lauster objected to a nurse moving an imaging device called a C-arm, stating that nurses are not permitted to operate it. Two weeks later, Lauster was fired by Brandon Ehret, the clinic’s top administrator. Lauster filed a charge of unfair labor practices with the National Labor Relations Board (NLRB), claiming he was terminated due to his objection at the meeting.An administrative law judge (ALJ) heard the case and found that Capitol fired Lauster because of his protected labor activity, issuing a make-whole award. The NLRB affirmed the ALJ’s decision. Capitol petitioned for review, arguing that Lauster was fired due to performance issues, not because of his comment about the C-arm.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court noted that to prove a prima facie section 8(a)(1) violation, the NLRB must establish that the employee engaged in protected activity, the employer’s decisionmaker was aware of this activity, and the decisionmaker took adverse action because of animus toward the protected activity. The court found that the ALJ’s determination that Ehret knew about Lauster’s comment was not supported by substantial evidence. Ehret testified that he was unaware of the comment when he decided to fire Lauster, and this was corroborated by other witnesses.The Seventh Circuit granted Capitol’s petition for review, vacated the NLRB’s decision and order, and denied the petition for enforcement, concluding that the NLRB failed to prove that Ehret knew of Lauster’s protected activity when he made the termination decision. View "National Labor Relations Board v. Capitol Street Surgery Center, LLC" on Justia Law

Wisconsin Central Ltd. and Soo Line Railroad Company are in dispute over the location for exchanging rail traffic in the Chicago area. Wisconsin Central prefers the Belt Railway yard near Chicago, while Soo Line prefers the Spaulding yard near Bartlett, 35 miles away. The Surface Transportation Board initially ruled against Wisconsin Central, stating that it could not use Belt Railway's yard because it did not own it outright, despite having a contractual right to use it. The Seventh Circuit Court of Appeals remanded the case, clarifying that a railroad could have the power to designate facilities by contract as well as by ownership.Upon remand, the Surface Transportation Board held that the Belt Railway yard was not a reasonable location for the exchange. The Board found that both locations could cause congestion but concluded that it was unreasonable for Wisconsin Central to insist that Soo Line bear the costs of moving cars to Chicago and the fees charged by Belt Railway. Additionally, the Board emphasized the importance of negotiation and agreement in selecting exchange locations, rather than allowing one party to unilaterally change the location.The United States Court of Appeals for the Seventh Circuit reviewed the Board's decision. The court held that the Board's interpretation of "reasonable" was within its discretion and that considering costs as part of reasonableness was appropriate. The court also noted that Wisconsin Central did not preserve its argument regarding substantial evidence for review. Consequently, the court found that the Board's decision was neither arbitrary nor capricious and did not embody a legal error. The petition for review was denied. View "Wisconsin Central Ltd. v. Surface Transportation Board" on Justia Law