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

In this toxic tort case, a group of plaintiffs alleged that they were harmed by exposure to white lead carbonate (WLC), a lead paint pigment, while growing up in Milwaukee homes in the 1990s and early 2000s. They sought to hold several manufacturers of WLC liable under state-law negligence and strict liability theories. The case was managed such that groups of plaintiffs would try their claims in a series of waves. The initial waves of plaintiffs met defeat in both the district court and the Court of Appeals, resulting in summary judgment for the defendants on all claims. The district court then extended these rulings to the remaining plaintiffs based on the law of the case and issue preclusion.On appeal, the United States Court of Appeals for the Seventh Circuit determined that most of the plaintiffs indeed were bound by the district court's rulings due to their decision to proceed under a single complaint. However, a small group of plaintiffs who filed their own cases were found to be entitled to try their claims, as due process protected their rights. The court affirmed the district court's decision in large part, but reversed it in small part, sending the case back to the district court for further proceedings with respect to this small group of plaintiffs. View "Cannon v. Armstrong Containers Inc." on Justia Law

In this toxic tort case, about 170 individuals allege that they were harmed by lead paint pigment. The plaintiffs, who were joined together in a single complaint, brought claims against several manufacturers of the pigment. After a series of trials, the district court granted summary judgment for the defendants on all claims. The court then extended these rulings to the remaining plaintiffs on law of the case and issue preclusion grounds. The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision in large part but reversed in small part. The appellate court held that the law of the case doctrine properly applied to a group of plaintiffs who had opted to proceed under a single complaint and whose claims were sunk after summary judgment. However, the court reversed the district court's decision as to a small group of plaintiffs who filed their own cases, noting that due process protects their right to try their claims. The court also rejected the plaintiffs' request to revisit or certify certain questions addressed in a prior ruling, and affirmed that ruling based on the principle of stare decisis. View "Allen v. Armstrong Containers Inc." on Justia Law

In the case before the United States Court of Appeals for the Seventh Circuit, the defendant, Demetrius Harvey, pled guilty to knowingly possessing a firearm after having previously been convicted of a crime punishable by a term of imprisonment exceeding one year. The court had to decide whether a 4-level enhancement was proper under USSG § 2K2.1(b)(6) because Harvey transferred a firearm to a confidential source (CS) who he had reason to believe was a felon. Harvey initially challenged the enhancement, arguing that the purchaser's statement that he was a convicted felon was an insufficient basis for Harvey to conclude that the purchaser was, in fact, a convicted felon. On appeal, Harvey changed his argument, claiming he was not told that the CS was a felon until the transaction was complete.The court concluded that even under the less onerous standard, Harvey's claim could not succeed. The enhancement was proper if the evidence before the district court supported the determination that the transfer of the firearm by the defendant occurred "with knowledge, intent, or reason to believe that it would be used or possessed in connection with" the felon-in-possession offense. Therefore, the court affirmed the decision of the district court and upheld the 4-level enhancement. View "USA v. Harvey" on Justia Law

The plaintiff, Todd Hess, applied for supplemental security income, disability insurance benefits, and disabled adult child benefits, all of which are administered by the Social Security Administration. While his claims for supplemental security income and disability insurance benefits were approved, his claim for disabled adult child benefits was denied. To qualify for disabled adult child benefits, Hess had to prove that he had a disability that continued uninterrupted from before his 22nd birthday until the filing of his application for benefits. He claimed that his depression, panic disorder, obsessive-compulsive disorder, and other impairments made him disabled during that entire period. However, after two hearings, an Administrative Law Judge disagreed, concluding that Hess was disabled as of June 9, 2009, but not before then. The ALJ's decision was based on gaps in Hess's treatment history, notes from his physicians, and occasional work he performed as an independent contractor. The Appeals Council did not assume jurisdiction, and the district court found that the ALJ's decision was supported by substantial evidence. The United States Court of Appeals for the Seventh Circuit agreed and affirmed the judgment of the district court. View "Hess v. O'Malley" on Justia Law

In this case, the plaintiff, Laura Mullen, claimed that the defendants, a youth volleyball club and its owners, fraudulently concealed previous sexual abuse allegations. The district court granted summary judgment in favor of the defendants, but also imposed sanctions against them and their lawyer for improperly interfering with the class notice process. The defendants appealed the sanctions.The United States Court of Appeals for the Seventh Circuit held that the district court did not abuse its discretion or commit clear error in imposing the sanctions. The court found that the defendants had intentionally interfered with the class notice and opt-out process and that their communications with class members during the notice period were potentially coercive. The court also upheld the decision of the district court to impose monetary sanctions against the defendants, which included the plaintiff’s reasonable attorney’s fees and expenses, as well as a civil penalty for each defendant.The court also affirmed the non-monetary sanctions imposed against the defendants' lawyer, who had contacted a class member directly and made a false statement to the court. Although the defendants argued that the lawyer had acted in good faith and did not knowingly or intentionally violate the rules of ethics, the court found that she had taken deliberate action to avoid confirming a high probability of wrongdoing.Finally, the court rejected the defendants' argument that the plaintiff should have been sanctioned. The defendants claimed that the plaintiff’s use of the term “rape” was inaccurate and irrelevant, that her actions before and after filing the complaint were inconsistent, that she did not have a proper basis for bringing the suit, and that she misrepresented evidence. The court found no merit in these arguments and affirmed the district court’s decision to deny sanctions against the plaintiff. View "Mullen v. Butler" on Justia Law

Four Iranian nationals, who had previously completed mandatory military service in Iran's Islamic Revolutionary Guard Corps (IRGC), were denied visas to enter the United States. Their family members, three U.S. citizens and one lawful permanent resident, filed a suit against the President and several federal officials responsible for visa applications. They alleged that the defendants unlawfully deprived visa applicants the opportunity to establish eligibility for terrorism-related inadmissibility grounds (TRIG) exemptions, violating their rights under the Administrative Procedure Act and the Fifth Amendment’s Due Process Clause. The district court dismissed the case under the doctrine of consular nonreviewability, which bars judicial review of consular decisions. The Plaintiffs appealed, and the United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court held that the doctrine of consular nonreviewability applied, and that the plaintiffs failed to show any evidence of bad faith that could overcome this doctrine. The court also held that the applicants were not entitled to any more explanation for their visa denials than the citation to the section of the law on which the denial was based. View "Pak v. Biden" on Justia Law

In the case at hand, the plaintiff, Benjamin Adams, an inmate at Indiana’s Plainfield Correctional Facility, sued the current and former commissioners of the Indiana Department of Corrections and various other officials pursuant to 42 U.S.C. § 1983, alleging that they violated his First and Eighth Amendment rights, as well as his Fourteenth Amendment rights to due process and equal protection. Adams was sentenced to a prison term of 30 years for attempted murder and a consecutive term of four years for involuntary manslaughter. He was assigned to work in the prison kitchen, but that assignment was rescinded due to concerns that he might use the assignment to smuggle drugs into the prison. He was later charged with offense A-100 for engaging in criminal gang activity related to an assault in the prison. Disciplinary Hearing Officer J. Peltier found Adams guilty of that offense on March 16. He was ordered to spend one year in disciplinary segregation, 365 days of his earned good time credits were revoked, and he was demoted from credit-earning class 1 to class 3.The United States Court of Appeals for the Seventh Circuit affirmed the district court's grant of summary judgment in favor of the defendants. The appellate court concluded that Adams' claim of First Amendment retaliation lacked sufficient evidence to suggest that the defendants were motivated by a retaliatory intent to pursue the assault charge against him. The court also held that Adams was not deprived of his Fourteenth Amendment due process rights, as prison disciplinary hearings require only informal due process, which leaves substantial flexibility in the hands of prison administrators. Regarding the Equal Protection claim, the court found no evidence that Adams was treated differently based on his race. Lastly, the court concluded that the defendants could not be held liable for violating Adams' Eighth Amendment rights as there was no evidence that they had control over the conditions of restrictive housing where Adams was placed. View "Adams v. Reagle" on Justia Law

The defendant, Joseph Wilcher, was convicted of attempted enticement of a minor and travel with intent to engage in illicit sexual activity after he drove across state lines to meet someone he believed was a fifteen-year-old girl, who was actually a federal agent. The United States District Court for the Central District of Illinois sentenced Wilcher to a custodial prison term and a term of supervised release. In explaining the sentence, the district court only discussed the seriousness of the offense and did not address any of Wilcher's arguments for mitigation.On appeal, the United States Court of Appeals for the Seventh Circuit found that the district court erred in its sentencing. The appellate court held that the district court had relied on the seriousness of the offense as the sole justification for the sentence, including the term of supervised release. However, the seriousness of the offense is not a factor that courts can consider when imposing a term of supervised release. The appellate court also found that the district court had failed to consider Wilcher's principal mitigation arguments. The appellate court concluded that the district court's failure to adequately explain the sentence precluded meaningful appellate review.The Court of Appeals for the Seventh Circuit vacated Wilcher's sentence and remanded the case for a full resentencing hearing. The court clarified that on remand, the district court could not consider the seriousness of the offense when imposing a term of supervised release and must consider Wilcher's principal mitigation arguments. View "USA v. Wilcher" on Justia Law

The case arises from severe burns suffered by a minor, B.D., when a Samsung SDI battery exploded in his pocket in Indiana. B.D. sued Samsung SDI, a corporation organized under the laws of the Republic of Korea with no physical presence in Indiana, in Indiana state court for product liability. Samsung SDI moved the case to federal court and sought to dismiss the case for lack of personal jurisdiction. The district court denied Samsung SDI's motion to dismiss, finding that specific personal jurisdiction existed over Samsung SDI in Indiana. Samsung SDI subsequently appealed the decision to the United States Court of Appeals for the Seventh Circuit.The Seventh Circuit Court of Appeals found that the district court's record did not contain sufficient facts to assess whether the requirements of the stream-of-commerce theory, which may establish a defendant's minimum contacts with a forum state, were met in this case. The court also found that the district court's reliance on the Supreme Court case of Ford Motor Co. v. Montana Eight Judicial District Court was distinguishable as Samsung SDI did not advertise, sell, or service the specific batteries in question in Indiana. The court noted that the extent of Samsung SDI's knowledge and expectations about the 18650 batteries entering Indiana was unclear.The court also found that the record did not clearly show whether Samsung SDI's contacts with Indiana were related to the alleged injury. Lastly, the court determined that more facts were needed to assess whether the exercise of personal jurisdiction would be fair.Given these uncertainties, the Seventh Circuit Court of Appeals remanded the case for further jurisdictional discovery to gather more information about Samsung SDI's contacts with Indiana concerning B.D.'s claimed injuries. The court clarified that this remand was limited to the question of personal jurisdiction and did not obligate the district court to consider or reconsider any non-jurisdictional issues. View "B. D. v. Samsung SDI Co., Ltd." on Justia Law

In 2015, DeShawn Harold Jewell was convicted of robbery by use of force and bail jumping, following a robbery outside a Milwaukee tavern. A DNA match from a hat left at the scene and a photo identification by the victim led to his arrest, but Jewell argued that the photo array procedure did not adhere to best practices. During deliberations, the jury asked the trial court if the numbering system of the photo array matched that of a photo "six-pack" shown at trial. The trial court, without consulting the parties, answered "No." The jury subsequently returned a guilty verdict. Jewell challenged this ex parte communication, arguing that it violated his Sixth Amendment rights. The Wisconsin Court of Appeals affirmed the conviction, concluding that the trial court's error was harmless. Jewell sought habeas relief under the Antiterrorism and Effective Death Penalty Act, but the U.S. Court of Appeals for the Seventh Circuit affirmed the lower court's decision. The court reasoned that the Wisconsin Court of Appeals had not unreasonably applied Supreme Court precedent in its harmlessness analysis, and that the ex parte communication did not have a substantial and injurious effect on the jury’s verdict. View "Jewell v. Boughton" on Justia Law