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

Alex Kedas worked for the Illinois Department of Transportation (IDOT) for over thirty years, primarily as a senior resident engineer. In 2016, Kedas complained to management and legal counsel that a female colleague was receiving better job assignments due to gender favoritism. After his complaint, Kedas received a counseling memorandum, a negative performance evaluation, and was denied a merit-based bonus. In subsequent years, he was assigned less significant projects and faced additional disciplinary actions. Kedas believed these actions were retaliatory and ultimately resigned in 2021, claiming constructive discharge due to an intolerable work environment.Kedas filed a lawsuit in the United States District Court for the Central District of Illinois, alleging retaliation under Title VII of the Civil Rights Act of 1964. The district court granted partial summary judgment for IDOT, finding that only certain actions—specifically, the counseling memorandum, the negative performance review, the denial of a bonus, and the 2018 job assignments—could be considered materially adverse employment actions. However, the court then found no sufficient evidence of a causal link between Kedas’s protected activity and his 2018 job assignments or constructive discharge. The remaining claims proceeded to trial, where the jury found IDOT had retaliated by issuing the counseling memorandum but awarded no damages.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s summary judgment rulings de novo. The appellate court held that Kedas failed to present sufficient evidence to support claims of constructive discharge or a causal connection between his protected activity and the 2018 job assignments. The Seventh Circuit affirmed the district court’s judgment, concluding that no reasonable jury could find in Kedas’s favor on these issues. View "Kedas v Illinois Department of Transportation" on Justia Law

Two children, E.R. and G.S., have severe, complex medical conditions that require constant, skilled care. Their mothers, who are their primary caregivers and sole financial supporters, have been trained by medical professionals to provide the necessary care at home. For years, Indiana’s Medicaid program reimbursed these mothers for providing “attendant care services” under a waiver program designed to keep individuals out of institutions. In July 2024, the Indiana Family and Social Services Administration (FSSA) implemented a policy change that would make parents ineligible to be paid providers of attendant care for their children, threatening to force E.R. and G.S. into institutional care due to the lack of available in-home nurses.The Indiana Protection and Advocacy Services Commission, along with E.R. and G.S., sued to block the policy change and require FSSA to secure in-home nursing. The United States District Court for the Southern District of Indiana initially granted a preliminary injunction requiring FSSA to take steps to obtain in-home nurses and to pay the mothers for a different, lower-paid service. After further proceedings, the court modified its order, ultimately requiring FSSA to pay the mothers for attendant care at the previous rate until in-home nursing could be secured.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s October 1 injunction. The court held that the plaintiffs are likely to succeed on their claims under the Americans with Disabilities Act’s integration mandate, which requires states to provide services in the most integrated setting appropriate. The court found that prohibiting the mothers from providing paid attendant care placed the children at serious risk of institutionalization and that FSSA had not shown that allowing such care would fundamentally alter the Medicaid program or violate federal law. The case was remanded for further proceedings. View "Indiana Protection and Advocacy Services Comm'n v Indiana Family and Social Services Administration" on Justia Law

A group of individuals in the custody of the Illinois Department of Corrections (IDOC) filed a lawsuit in 2007, alleging inadequate mental healthcare. The case developed into a class action, and in 2016, the parties reached a settlement agreement that required IDOC to meet specific mental-health treatment benchmarks. The agreement included a provision for $1.9 million in attorney’s fees to be paid to plaintiffs’ counsel if the court granted relief for violations of the agreement. In 2018, the district court found IDOC in breach and issued an injunction, triggering the fee provision. While the defendants appealed, the parties entered into further agreements, resulting in the $1.9 million being paid to plaintiffs’ counsel.The United States District Court for the Central District of Illinois later extended its enforcement jurisdiction over the settlement agreement, but after the expiration of that jurisdiction, the court returned the case to its active docket. The parties continued to litigate, with plaintiffs filing amended complaints and defendants moving to dismiss. More than a year after resuming active litigation, the district court raised concerns about its subject-matter jurisdiction, ultimately concluding that its jurisdiction over the underlying claims ended when its enforcement jurisdiction over the settlement agreement expired. The court dismissed all claims and denied the defendants’ motion to recover the $1.9 million in attorney’s fees.The United States Court of Appeals for the Seventh Circuit reviewed the case. It held that, under the parties’ agreements, the payment of $1.9 million in attorney’s fees to plaintiffs’ counsel was proper and did not need to be returned, even after the district court’s injunction was vacated. The court also vacated the district court’s dismissal of the underlying claims, remanding for the district court to determine whether the settlement agreement moots those claims. The Seventh Circuit affirmed the denial of the defendants’ motion to recover the attorney’s fees. View "Daniels v. Jones" on Justia Law

Jose Farias orchestrated a large-scale drug trafficking operation that brought significant quantities of heroin and cocaine into the Chicago area during 2015 and 2016. He worked with a network of co-conspirators, using tractor-trailers with hidden compartments to transport drugs from Texas to Illinois. Law enforcement, tipped off early by a Texas truck dispatcher, conducted surveillance and seized substantial amounts of drugs at multiple locations. Several co-conspirators were arrested and cooperated with authorities, providing testimony and participating in recorded calls with Farias that further implicated him.The United States District Court for the Northern District of Illinois, Eastern Division, presided over Farias’s trial. The government presented testimony from cooperating witnesses and law enforcement agents, as well as recordings and translated transcripts of Farias’s conversations. The jury convicted Farias of conspiracy to distribute heroin and cocaine and possession of cocaine with intent to distribute. The district court denied Farias’s post-trial motions challenging the sufficiency of the evidence, the admission of voice identification testimony, and the jury instructions regarding translated transcripts. At sentencing, the court attributed 130 kilograms of heroin and 45 kilograms of cocaine to Farias, applied a leadership enhancement, and sentenced him to 300 months in prison.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed Farias’s challenges to the admission of voice identification testimony, the jury instructions on translated transcripts, the sufficiency of the evidence, and the sentencing calculations. The court held that the admission of the agent’s voice identification did not violate Farias’s constitutional rights, that Farias had waived any objection to the jury instructions on translated transcripts, that sufficient evidence supported the convictions, and that the district court did not clearly err in its drug quantity findings or in applying the leadership enhancement. The Seventh Circuit affirmed the judgment of the district court. View "USA v Farias" on Justia Law

Edward Flynn was killed when a fleeing suspect, James Shirley, crashed into his car during a high-speed police pursuit. The incident began when Indianapolis police officers attempted to investigate a potentially stolen truck. Shirley, the suspect, backed into a patrol car and nearly struck two officers before fleeing. Multiple officers engaged in a pursuit that lasted about five and a half minutes, during which Shirley drove recklessly, including turning off his lights, running stop signs and red lights, and reaching high speeds. The chase ended when Shirley ran a red light and collided with Edward Flynn’s vehicle, resulting in Flynn’s death.Gayl Flynn, representing Edward’s estate, filed suit in the United States District Court for the Southern District of Indiana against the City and five officers. She alleged violations of Edward’s Fourteenth Amendment substantive due process rights and claimed the City failed to properly train its officers, invoking Monell v. Department of Social Service of New York. The district court granted summary judgment for the defendants, applying the “intent to harm” standard for Fourteenth Amendment liability in emergency situations and finding no such intent by the officers.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court agreed that the facts presented an emergency situation, making the “intent to harm” standard appropriate. The court found that the officers did not act with intent to harm and that the circumstances did not support a claim under a deliberate indifference standard. Because there was no underlying constitutional violation, the Monell claim against the City also failed. The Seventh Circuit affirmed the district court’s grant of summary judgment to all defendants. View "Flynn v Consolidated City of Indianapolis and Marion County" on Justia Law

David Fiddler, a Jamaican national who entered the United States as a child, was convicted in Illinois of first-degree murder and attempted first-degree murder, resulting in a lengthy prison sentence. He suffers from severe schizophrenia, which has led to repeated hospitalizations. After the Department of Homeland Security initiated removal proceedings against him in 2021, Fiddler sought deferral of removal under the Convention Against Torture (CAT), arguing that, if returned to Jamaica, he would likely become homeless, lack access to mental health care, and face violence from police or private individuals, with the acquiescence of authorities, due to his mental illness.An Immigration Judge (IJ) initially denied Fiddler’s CAT claim, finding insufficient evidence that he would face a substantial risk of torture. The Board of Immigration Appeals (BIA) remanded for further analysis, but the IJ again denied relief, concluding that while Fiddler was likely to become homeless and vulnerable, the evidence did not show a substantial risk of torture or that Jamaican officials would act with the specific intent required under the CAT. The BIA affirmed, holding that Fiddler had not demonstrated that harm he feared would be inflicted with the specific intent to torture, nor that Jamaican officials would acquiesce in torture by private actors. After a further remand and another BIA affirmation (with one dissent), Fiddler petitioned for review.The United States Court of Appeals for the Seventh Circuit reviewed the case and denied the petition. The court held that Fiddler failed to establish it was more likely than not he would be tortured with the specific intent required by the CAT, either by government officials or with their acquiescence. The court found the BIA’s analysis consistent with CAT standards and concluded that the evidence did not compel a contrary result. View "Fiddler v Bondi" on Justia Law

Police began investigating a man after a confidential informant, who had been caught with illegal drugs and firearms, provided detailed information about the man’s drug trafficking activities. The informant described prior drug purchases from the man, his connections to a cartel, and provided specific details about the man’s address, vehicle, and communications. Police corroborated much of this information through surveillance and controlled drug buys, and obtained state and federal search warrants. When executing the warrants, officers found large quantities of methamphetamine, fentanyl, firearms, and evidence of drug sales. The man was charged with multiple drug and firearm offenses.In the United States District Court for the Northern District of Indiana, the defendant moved for a Franks hearing, arguing that the affidavits supporting the initial search warrants omitted important information about the informant’s credibility and cooperation agreement. He also sought to suppress evidence obtained from the warrants and challenged the scope of the firearm charge and several sentencing enhancements. The district court denied the motions, finding the omissions immaterial to probable cause and insufficient to warrant a Franks hearing, and concluded that the evidence and enhancements were properly applied. The jury convicted the defendant on all counts, and the court imposed a life sentence.The United States Court of Appeals for the Seventh Circuit reviewed the case. It held that the district court did not err in denying a Franks hearing, as the omitted information about the informant was not material given the corroboration and detail provided. The appellate court also found no constructive amendment of the indictment regarding the firearm charge and upheld the application of the sentencing enhancements. The Seventh Circuit affirmed the district court’s judgment in all respects. View "USA v Hecke" on Justia Law

A large group of current and former Illinois prisoners diagnosed with hepatitis C brought lawsuits against various medical officials of the Illinois Department of Corrections. The plaintiffs alleged that, over the past two decades, these officials were deliberately indifferent to their medical needs by adopting and enforcing hepatitis C treatment policies that denied them effective care. The complaints sought only monetary damages and did not specify whether the defendants were being sued in their individual or official capacities.In the United States District Court for the Central District of Illinois, the Orr plaintiffs’ efforts to obtain class certification and injunctive relief were denied, and subsequent attempts to amend their complaint were dismissed for lack of specificity. The Ternaprovich plaintiffs, represented by the same counsel and making similar claims, also had their complaints dismissed for failing to provide sufficient notice to the defendants. Ultimately, in January 2024, the district court dismissed both cases with prejudice, holding that the claims were barred by the Eleventh Amendment as official-capacity suits for damages, and, alternatively, that the complaints failed to state plausible claims for relief under Federal Rule of Civil Procedure 12(b)(6).On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the dismissals de novo. The appellate court concluded that, despite some ambiguity, the complaints should be interpreted as asserting individual-capacity claims under 42 U.S.C. § 1983, given the explicit request for damages. However, the court affirmed the dismissals on the alternative ground that the complaints failed to state plausible claims for relief. The court held that the plaintiffs did not provide sufficient factual allegations to connect specific defendants to the alleged constitutional violations, and thus failed to give fair notice as required by Rule 8. The judgments of dismissal with prejudice were affirmed. View "Ternaprovich v Shicker" on Justia Law

Israel Isbell pleaded guilty in 2010 to receipt of child pornography and was sentenced to 180 months in prison followed by a lifetime of supervised release. As his prison term ended, Isbell violated several conditions of his supervised release, including unauthorized internet use and unsuccessful participation in sex offender and substance abuse treatment programs. These violations led to the revocation of his supervised release, an additional prison term, and a new term of supervised release with specific conditions.After a prior appeal resulted in a remand for resentencing on an unrelated issue, the United States District Court for the Central District of Illinois resentenced Isbell to 16 months’ imprisonment and 8 years of supervised release. Isbell objected to three conditions: a requirement to participate in a computer and internet monitoring program, a provision regarding medical marijuana use during treatment, and a mandate for substance abuse treatment. The district court overruled his objections and imposed the conditions as proposed.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed Isbell’s challenges de novo. The court held that the computer monitoring condition was neither unconstitutionally vague nor overbroad, as its language and purpose provided sufficient notice and guidance. The court also found that the medical marijuana provision did not improperly delegate judicial authority to treatment providers, as it required Isbell to follow generally applicable program rules rather than allowing providers to determine the existence of the condition. Finally, the court determined that the written judgment requiring substance abuse treatment was consistent with the oral pronouncement and did not violate the non-delegation rule. The Seventh Circuit affirmed the judgment of the district court. View "USA v Isbell" on Justia Law

A customer service analyst at a large corporation alleged that her supervisors created a hostile work environment characterized by inappropriate behavior and a culture of “machismo.” She reported these concerns to human resources, including claims of increased workload without overtime approval and specific instances of inappropriate conduct. The company investigated, found low morale but no evidence of discrimination or harassment, and paid her owed overtime. After her complaints, the analyst received escalating warnings about her work performance, culminating in the lowest possible rating on her annual review. She was then given the choice between a performance improvement plan or resignation. Following an emotional reaction to this meeting, the company withdrew the improvement plan option and terminated her employment.She filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, alleging gender discrimination and retaliation under Title VII, and age discrimination and retaliation under the Age Discrimination in Employment Act. The district court granted summary judgment in favor of the employer, finding insufficient evidence to support her claims.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the case de novo, considering whether a reasonable factfinder could conclude that her gender, age, or protected activity caused her termination. The court held that the plaintiff failed to identify similarly situated comparators who were treated more favorably, did not present evidence that her age was the “but for” cause of her termination, and could not establish a causal link between her complaints and adverse employment actions. The court found no evidence of pretext or retaliation and concluded that the record did not support her allegations. The Seventh Circuit affirmed the district court’s grant of summary judgment to the employer. View "Ontiveros v. Exxon Mobil Corporation" on Justia Law