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

The case in question originated in the United States Court of Appeals for the Seventh Circuit. The dispute arose after the dissolution of a business partnership between Gregory Kleynerman and Scott Smith, which resulted in Smith obtaining a state court judgment of $499,000 against Kleynerman. This judgment was secured by Kleynerman's membership interest in Red Flag Cargo Security Systems LLC. Following this, Kleynerman filed for bankruptcy and valued his interest in Red Flag at $0. Smith argued in the bankruptcy court that the state court's judgment was a result of Kleynerman's fraud and thus could not be discharged. However, the bankruptcy court rejected this argument.After the bankruptcy case was closed, Kleynerman asked the state court to deem the $499,000 judgment discharged. Smith contended that under Wisconsin law, only debts secured by real property can be avoided. The state court agreed with Smith, which led Kleynerman to request the bankruptcy court to reopen the case and clearly state that both the $499,000 debt and the lien on Kleynerman’s interest in Red Flag no longer existed.The bankruptcy court reopened the case and the district court affirmed the decision. The appellate court agreed with the lower courts, stating that the bankruptcy judge had authority to reopen the case, and that Kleynerman had cause for reopening.Furthermore, the court held that the value of Kleynerman’s interest in Red Flag was a matter for the bankruptcy judge to decide before the discharge. Smith had an opportunity to object to Kleynerman's valuation of his interest in Red Flag but failed to do so until after the bankruptcy court had entered its discharge order. The court concluded that Smith's post-discharge subpoenas seeking information about the value of Kleynerman’s interest in Red Flag were a fishing expedition and an exercise in harassment, which was properly rejected by the bankruptcy judge. Therefore, the court affirmed the decision of the lower courts. View "Smith v. Kleynerman" on Justia Law

In this case, the United States Court of Appeals for the Seventh Circuit was asked to review a decision by the Board of Immigration Appeals (BIA) concerning F.J.A.P., a petitioner from El Salvador. F.J.A.P. had previously been removed from the U.S. but returned due to threats from the MS-13 gang. After his return to the U.S., his original removal order was reinstated. F.J.A.P. then applied for withholding-only relief under the Convention Against Torture (CAT), which an immigration judge granted. However, the BIA reversed this decision. F.J.A.P. petitioned the Seventh Circuit for review.The court first addressed whether it had jurisdiction to review F.J.A.P.'s claim. The court concluded that a reinstated order of removal was not final for purposes of judicial review under 8 U.S.C. § 1252 until the agency had completed withholding proceedings. Therefore, F.J.A.P.'s petition was timely because it was filed within 30 days of the completion of his CAT proceedings.On the merits of the case, the court found that the BIA had not applied the correct standard of review to the immigration judge's decision. The BIA was required to review the immigration judge's factual findings for clear error, not de novo. However, the BIA had failed to address the immigration judge's key factual findings, had given more weight to certain facts in the record than others, and had not explained how the immigration judge's alleged errors displayed a lack of logic, plausibility, or support in the record. As a result, the court granted F.J.A.P.'s petition and remanded the case to the BIA for reconsideration of the immigration judge's decision under the correct standard of review. View "F. J. A. P. v. Garland" on Justia Law

In the case at hand, the United States Court of Appeals for the Seventh Circuit reviewed an employment discrimination case. The plaintiff, LuzMaria Arroyo, a military reservist, brought a lawsuit against her employer, Volvo Group North America, LLC, alleging discrimination based on her military status and her post-traumatic stress disorder (PTSD). After a jury ruled in Arroyo's favor and awarded her $7,800,000 in damages, the district court granted judgment as a matter of law to Volvo on Arroyo’s Americans with Disabilities Act (ADA) claim, and ordered a new trial on the remaining Uniformed Services Employment and Reemployment Rights Act (USERRA) claim, where the jury found for Volvo. Arroyo appealed this decision.The Court of Appeals affirmed the district court's decision. The court found that Arroyo was not a "qualified individual" under the ADA as she failed to comply with Volvo's attendance policy, an essential job function. Arroyo's positive job performance reviews did not negate her violation of the attendance policy. The court also found no conflict with its previous decision in Arroyo I, which had reversed the district court's grant of summary judgment to Volvo on the ADA and USERRA claims.Further, the court upheld the district court's decision for a new trial on the USERRA claim. The court agreed that the jury’s verdict as to the ADA claim was influenced by passion and prejudice that also tainted the jury’s determination of USERRA liability. Finally, the court found no abuse of discretion in the district court's decision to exclude evidence of Arroyo’s PTSD in the new trial, as PTSD alone was not sufficient to raise a cognizable discrimination claim under USERRA. View "Arroyo v. Volvo Group North America, LLC" on Justia Law

In this case heard by the United States Court of Appeals for the Seventh Circuit, the plaintiff, Alexis Wells, sought to hold her employer, The Freeman Company, liable for sexual assault committed by a fellow employee, Timothy Vaughn. Wells asserted that the company should be held responsible under Title VII, the Indiana Wage Payment Statute, and various tort theories. The court, however, affirmed the district court's ruling that Wells was an independent contractor, not an employee, which meant that Freeman's conduct was not tortious and Vaughn's actions could not be attributed to Freeman. The court applied the Knight factors, which analyze the "economic realities" of a work relationship, to determine whether a worker is an employee for purposes of Title VII. The court concluded that most of these factors pointed towards Wells being an independent contractor. Thus, her claims under Title VII and the Indiana Wage Payment Statute failed. The court also dismissed Wells' state law claims for Intentional Infliction of Emotional Distress (IIED) and Negligent Infliction of Emotional Distress (NIED), concluding that Freeman's pre-litigation conduct was not so outrageous as to be regarded as "atrocious," and that Vaughn's conduct was outside the scope of his employment, respectively. Therefore, the court could not hold Freeman vicariously liable for Vaughn's actions. View "Wells v. Freeman Company" on Justia Law

In this case, the plaintiff, Chicago Joe's Tea Room LLC, had plans to open an adult entertainment business in a suburb of Chicago. However, the Village of Broadview denied the plaintiff's application for a special-use permit, which led to the plaintiff claiming that their constitutional rights were violated. The plaintiff sought millions of dollars in lost profits for the business that never opened. The U.S. District Court for the Northern District of Illinois excluded most of the plaintiff's evidence and theories for lost-profit damages due to substantive and procedural issues. The court then awarded the plaintiff just $15,111 in damages. The plaintiff appealed, but the United States Court of Appeals for the Seventh Circuit affirmed the decision of the lower court, finding no abuses of discretion. The appellate court stated that the plaintiff's calculations of lost profits were beyond the scope of the plaintiff's personal knowledge of a similar business and required expert-like analysis and adjustments. The court also ruled that the plaintiff failed to disclose necessary damages evidence in a timely manner, a violation of the Federal Rules of Civil Procedure. The plaintiff was also denied the opportunity to amend their complaint to challenge a state statute, as the request was made a decade after the issue became relevant. The court found that granting the amendment would have caused undue delay and prejudice to the Village. View "Chicago Joe's Tea Room, LLC v. Village of Broadview" on Justia Law

In the case before the United States Court of Appeals for the Seventh Circuit, the petitioner, Monta Anderson, sought to vacate his guilty plea for conspiring to distribute heroin, claiming that his plea was not knowing and voluntary due to his counsel's alleged ineffective assistance. Anderson argued that his counsel advised him to plead guilty without first consulting a toxicology expert on whether the heroin he distributed was a but-for cause of a user's death. Previously, the court had remanded the case for an evidentiary hearing, concluding that Anderson had articulated a viable claim of attorney ineffectiveness.On remand, Anderson presented evidence that consultation with a toxicology expert would have revealed the government's inability to prove beyond a reasonable doubt that the heroin he supplied was a but-for cause of the user's death. However, the government argued that even without the death-results enhancement, Anderson would have faced a mandatory life term due to his prior felony drug convictions and the fact that two individuals suffered serious bodily injuries from overdosing on heroin supplied by Anderson.Having considered the evidence and arguments, the court concluded that Anderson was not prejudiced by any alleged ineffectiveness of his counsel. Even if the death-results enhancement were discounted, Anderson still faced a mandatory life term due to his prior felony drug conviction and the serious bodily injuries caused by his heroin distribution. As such, his decision to plead guilty and accept a 20-year sentence was reasonable. Therefore, the court affirmed the district court's judgment denying Anderson's motion to vacate his guilty plea. View "Anderson v. United States" on Justia Law

In this case, the United States Court of Appeals for the Seventh Circuit considered an appeal by Linnel Blount, Jr., who was convicted on drug and gun charges in 2019 and sentenced to 63 months in prison. Blount's jury trial was initially set for February 2020 but was postponed to March 2020 at his request. However, due to the COVID-19 pandemic, a series of court orders suspended criminal jury trials from March 2020 through April 2021. The district judge deferred Blount's trial further during this period, citing health and safety considerations. Blount eventually waived his jury trial and agreed to a bench trial, which commenced in July 2021.On appeal, Blount argued that his indictment should have been dismissed under the Speedy Trial Act because the delay of his trial was based on the general pandemic-related court orders rather than individualized, case-specific circumstances. However, the court of appeals found that Blount's lawyer did not make a formal motion to dismiss the indictment, which is necessary under the Speedy Trial Act. Moreover, the court determined that the district judge was not required to interpret Blount's pro se filings as implicit motions to dismiss.More broadly, the court held that the Speedy Trial Act does not require judges to reiterate considerations that have already been established by the court as an institution. It concluded that the delay of criminal jury trials during the COVID-19 pandemic was justified by societal, not personal, considerations, and that such delays were permissible under the Speedy Trial Act. The court affirmed Blount's conviction and sentence. View "United States v. Blount" on Justia Law

The case concerns an appeal by Brandon Cade against a ruling by the United States District Court for the Northern District of Illinois, Eastern Division, before the United States Court of Appeals For the Seventh Circuit. Cade was arrested by Chicago police officers who noticed an open bottle of alcohol in a sedan next to which Cade and another individual were standing. During a search of the car, officers found an unlicensed firearm and Cade admitted it was his. He was charged with possession of a firearm by a felon. Cade argued to suppress evidence of the gun and his incriminating statements, but the district court denied his motion. Cade pleaded guilty but reserved his right to appeal the suppression ruling. He argued that his initial encounter with the officers was an unlawful seizure and that his incriminating statements should be suppressed because the officers did not have reasonable suspicion to seize him.The Court of Appeals affirmed the lower court's ruling. The court found that the initial encounter with the officers was consensual and did not constitute a seizure. The court also ruled that even if there was an unlawful seizure, Cade's incriminating statements were sufficiently attenuated from any allegedly unlawful conduct. The presence of the open alcohol bottle provided probable cause for the search, which led to the discovery of the firearm, and Cade's admission to owning the firearm occurred after he was read his Miranda rights. The court concluded that there was no evidence of bad faith by the officers, and that an evidentiary hearing was not needed as there were no material factual disputes. View "United States v. Cade" on Justia Law

Aluminum Recovery Technologies (ART) operates a smelter and during a renovation, one of its furnaces failed, causing molten aluminum to escape and damage the plant and the furnace itself. The insurance company, ACE American Insurance, paid for some of the damages but not the cost of replacing the furnace's refractory. ART sued ACE, arguing that an explosion in the furnace caused the damage and thus, the insurance company should cover the refractory replacement costs. However, the insurer argued that the policy specifically excludes coverage for any damage to the refractory lining unless it directly results from specific perils such as fire, lightning, windstorm, hail, or explosion. The United States Court of Appeals For the Seventh Circuit affirmed the district court's decision in favor of ACE. The court held that the explosion did not necessarily cause the leak, and ART failed to provide engineering evidence to support its claims. Additionally, the court found that ART had consented to the investigation protocol proposed by the insurer's experts, which involved destructive testing that led to the need for the refractory's replacement. Therefore, the insurer was not responsible for the additional expenses incurred due to the replacement of the refractory lining. View "Aluminum Recovery Technologies, Inc. v. Ace American Insurance Co." on Justia Law

Jeffrey Bruno, a veteran firefighter with the Kankakee Fire Department, sued Mayor Chasity Wells-Armstrong, James Ellexson, the Human Resources Director for the City of Kankakee, and the City of Kankakee, alleging discrimination and retaliation under the Americans with Disabilities Act (ADA) and the Illinois Human Rights Act (IHRA). Bruno suffered a severe cardiac event in 2017 and upon his return to work was promoted to Deputy Chief. However, in 2019, he was denied a raise and presented with an employment contract that tied additional compensation to his enrollment in college courses. When Bruno requested the removal of this education condition, citing his heart condition as a barrier to attending classes, his request was denied. After signing the contract, Bruno retired and initiated legal proceedings.The United States Court of Appeals For the Seventh Circuit affirmed the district court's decision, which had granted summary judgment for the defendants. The court concluded that Bruno's request to remove the education condition was not a request for a reasonable accommodation under the ADA, as it would not impact his ability to perform his job. The court also rejected Bruno's claim of disparate treatment, as his argument of pretext was contradicted by the evidence. Bruno's ADA retaliation claim also failed because his identified protected activity was not protected under the ADA. As Bruno's IHRA and indemnification claims were dependent on his ADA claims, these too were rejected. View "Bruno v. Wells-Armstrong" on Justia Law