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

This case involves a dispute over insurance coverage following a family business conflict. Brian Flood and his sons, Chris and Shawn, were involved in a waste collection business, Flood Brothers Waste Disposal Company. After being pushed out of the family business, they started a new company, S.B.C. Flood Waste Solutions, Inc. They obtained insurance from Grinnell Mutual Reinsurance Co. without disclosing the ongoing dispute with Flood Brothers over the use of the "Flood" name. When Flood Brothers sued them for improper use of the name, they sought coverage from Grinnell, which refused and sought to rescind the policies due to material misrepresentations.The United States District Court for the Northern District of Illinois granted summary judgment in favor of Grinnell, finding that S.B.C. Flood Waste Solutions, Inc. had made material misrepresentations in their insurance applications. The court identified three categories of false statements: failure to disclose potential claims or occurrences, failure to disclose the existence of another business venture (Flood, Inc.), and misrepresenting the start date of business activities. The court found these misrepresentations material based on the testimony of Grinnell’s underwriter, who stated that the insurance would not have been issued if the true facts were known.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The appellate court agreed that the misrepresentations were material under Illinois law, which allows for rescission of an insurance policy if a false statement materially affects the acceptance of risk. The court emphasized that the undisclosed dispute and the existence of Flood, Inc. were significant factors that would have influenced Grinnell’s decision to issue the policies. The court did not need to address the alter ego argument, as the material misrepresentations alone were sufficient to justify rescission. View "Grinnell Mutual Reinsurance Company v. S.B.C. Flood Waste Solutions, Inc." on Justia Law

Daroush Ebrahimi, a prisoner serving a life sentence in Illinois, filed a lawsuit in the United States District Court for the Southern District of Illinois against Wexford Health Sources, Inc. and Dr. Mohammed Siddiqui, alleging medical mistreatment. Ebrahimi was granted in forma pauperis status, indicating his inability to pay court fees. The district court eventually granted summary judgment in favor of the defendants. Following this, Wexford and Dr. Siddiqui submitted a bill of costs totaling $5,243.45 for deposition transcripts, which Ebrahimi opposed, citing his indigency.The district court awarded the full amount of costs to the defendants. The court noted that Ebrahimi's prison trust fund account had a balance of $1,663.70 in July 2022, which had decreased to $936.84 by September 2022. The court concluded that Ebrahimi had not demonstrated an inability to pay the costs, either currently or in the future, despite his in forma pauperis status at the beginning of the lawsuit.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the district court did not abuse its discretion in awarding costs to the defendants. The court emphasized that Ebrahimi failed to provide sufficient documentation to prove his inability to pay the costs. The appellate court also found that the district court provided an adequate explanation for its decision, noting that Ebrahimi had substantial funds in his account and had received ample funds since the litigation began. Thus, the assessment of costs against Ebrahimi was affirmed. View "Ebrahimi v. Siddiqui" on Justia Law

In Illinois, voters can cast their ballots by mail, and election officials can receive and count these ballots for up to two weeks after Election Day, provided they are postmarked or certified by Election Day. Plaintiffs, including Illinois voters and political candidates, challenged this procedure, arguing it unlawfully extends the voting period and dilutes their votes. They also claimed it forced them to spend additional resources on their campaigns beyond Election Day. The district court dismissed their claims, ruling that Plaintiffs lacked standing to sue and also rejected the claims on the merits.The United States District Court for the Northern District of Illinois dismissed the case, concluding that Plaintiffs lacked standing to challenge the Illinois ballot receipt procedure. The court found that Plaintiffs did not allege a sufficient injury in fact, as their claims of vote dilution and additional campaign expenditures were deemed too speculative and generalized. Plaintiffs appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's dismissal. The appellate court held that Plaintiffs lacked standing because they did not allege a concrete and particularized injury. The court found that any potential vote dilution would affect all Illinois voters equally, making it a generalized grievance. Additionally, the court determined that the claimed campaign expenditures were speculative and not directly traceable to the Illinois ballot receipt procedure. Therefore, the court concluded that Plaintiffs did not meet the requirements for Article III standing and affirmed the dismissal of the case for lack of jurisdiction. View "Bost v. Illinois State Board of Elections" on Justia Law

In 2004, Graham Stowe was charged with violent offenses against his former girlfriend and her family. He pleaded no contest, claiming insanity, which a state judge accepted, leading to his commitment for 39.5 years unless he recovered earlier. Released in 2007, Stowe was soon re-incarcerated for violating release conditions and later escaped in 2013, using drugs while free. After serving a sentence for escape, Stowe sought release in 2016 under Wisconsin law, which requires clear and convincing evidence of significant risk to deny release. Expert testimony indicated Stowe had a personality disorder and posed a risk of violence, leading the state circuit court to deny his release, a decision affirmed by the state court of appeals.Stowe then sought federal habeas corpus relief, arguing that the Wisconsin statute violated the Due Process Clause as interpreted in Foucha v. Louisiana, by allowing detention without a finding of mental illness. The district court found that Stowe had not preserved an as-applied challenge in state courts and limited the certificate of appealability to whether the statute was facially invalid. The district court upheld the statute, noting it allows consideration of mental history and condition, and thus often includes findings on mental illness.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court held that Stowe failed to show the Wisconsin statute was facially invalid under clearly established federal law, as the statute permits consideration of mental condition and does not inherently violate due process. The court also noted that Stowe's as-applied challenge was not preserved for federal review. Therefore, the court concluded that the Due Process Clause does not entitle Stowe to immediate release. View "Stowe v. Rybroek" on Justia Law

Paul Carnes, an employee of Consolidated Grain and Barge Co., was diagnosed with degenerative disc disease in 2019 and received medical treatment for it. HMO Louisiana, Inc., the administrator of Consolidated Grain’s employer-sponsored health plan governed by ERISA, paid for some of Carnes’s treatments but not all. Carnes filed a workers’ compensation claim against his employer, which was settled without the employer accepting responsibility for his medical claims. With an outstanding medical balance of around $190,000, Carnes sued HMO Louisiana, alleging it violated Illinois state insurance law by not paying his medical bills and sought penalties for its alleged "vexatious and unreasonable" conduct.The United States District Court for the Central District of Illinois dismissed Carnes’s complaint on the grounds that his state law insurance claim was preempted by ERISA. The court allowed Carnes to amend his complaint to plead an ERISA claim, but instead, Carnes moved to reconsider the dismissal. The district court denied his motion and ordered the case closed. Carnes then appealed the final order.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court affirmed the district court’s decision, agreeing that Carnes’s state law claim was preempted by ERISA. The court noted that ERISA’s broad preemption clause supersedes any state laws relating to employee benefit plans, and Carnes’s claim fell within this scope. The court also found that ERISA’s saving clause did not apply because the health plan in question was self-funded, making it exempt from state regulation. The court concluded that Carnes’s attempt to frame his suit as a "coordination of benefits dispute" was an impermissible effort to avoid ERISA preemption. Consequently, the court affirmed the dismissal of Carnes’s case. View "Carnes v. HMO Louisiana, Inc." on Justia Law

John Smith, an employee of Sysco Indianapolis, LLC, did not receive a monthly benefit check he expected. His labor union, Teamsters Local 135, filed a grievance on his behalf, alleging that Sysco violated their 2018 collective bargaining agreement (CBA) by not providing a $500 Supplemental Early Retirement Benefit (SERB) to certain retirees and employees. Sysco participated in the initial grievance process but refused to proceed to arbitration, arguing that the grievance was not arbitrable under the CBA. Sysco then sought a declaratory judgment from the district court, while the Union counterclaimed for a declaration that the grievance was arbitrable.The United States District Court for the Southern District of Indiana sided with Sysco, finding that the monthly benefit was governed by terms outside the CBA and that the parties' bargaining history indicated they did not intend for the benefit to be arbitrable. The court granted Sysco's motion for summary judgment and denied the Union's counterclaims.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and reached a different conclusion. The appellate court found that Sysco failed to present the "most forceful evidence" required to exclude the monthly benefit from the arbitration provision in the CBA. The court noted that the grievance fell within the scope of the arbitration clause on its face and that the CBA did not explicitly exclude the SERB from arbitration. The court also found that the parties' bargaining history did not clearly demonstrate an intent to exclude the benefit from arbitration. Consequently, the Seventh Circuit reversed the district court's judgment, holding that the grievance must be sent to arbitration. View "Sysco Indianapolis LLC v. Teamsters Local 135" on Justia Law

Cameron Johnson, a convicted felon, was found in possession of a firearm on September 15, 2019. He pleaded guilty to this charge. The Government sought an enhanced sentence under the Armed Career Criminal Act (ACCA) based on Johnson's three prior robbery convictions under Indiana law. Johnson argued that two of these robberies, committed on January 22, 2009, occurred on the same occasion and thus should not count as separate offenses under ACCA. He also contended that a jury should determine whether the robberies were committed on different occasions.The United States District Court for the Southern District of Indiana rejected Johnson's argument, relying on Seventh Circuit precedent that did not require a jury to decide the different-occasions question. The court concluded that the robberies were committed on different occasions and sentenced Johnson to fifteen years in prison, the minimum under ACCA.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court noted that the Supreme Court's recent decision in Erlinger v. United States established that the Fifth and Sixth Amendments entitle defendants to have a jury decide whether prior offenses were committed on the same or different occasions. Given this precedent, the Seventh Circuit determined that the district court erred in not submitting the different-occasions question to a jury. The court also found that this error was not harmless, as it was not clear beyond a reasonable doubt that a jury would have found the robberies to be committed on different occasions.The Seventh Circuit vacated Johnson's sentence and remanded the case for further proceedings consistent with its opinion. View "USA v. Johnson" on Justia Law

Harold Grimes, a coal miner for 34 years, developed black lung disease and later died of lung cancer in 2018. His widow, Susan Grimes, is eligible for survivor’s benefits under the Black Lung Benefits Act. The dispute centers on whether Apogee Coal Company, Grimes’s last employer, or the Black Lung Disability Trust Fund should pay these benefits. The Department of Labor’s administrative law judge (ALJ) and the Benefits Review Board assigned financial responsibility to Apogee, with Arch Resources Inc., Apogee’s former parent corporation, bearing the liability. Arch contested this, arguing that the Trust Fund should pay.The district director initially identified Apogee as a potentially liable operator and notified Arch as Apogee’s “Insurance Carrier.” Despite Apogee’s bankruptcy in 2015, the district director and ALJ concluded that Arch, as Apogee’s self-insuring parent, was responsible for the benefits. The ALJ’s decision was based on the premise that Arch’s self-insurance umbrella covered Apogee’s liabilities. The Benefits Review Board affirmed this decision, referencing its prior cases, including Howard v. Apogee Coal Co., which supported the Department’s theory of liability for self-insuring parents.The United States Court of Appeals for the Seventh Circuit reviewed the case and found no statutory or regulatory basis for holding Arch liable for Apogee’s obligations. The court emphasized that neither the ALJ nor the Board identified a specific provision in the Act or its regulations that justified this liability. The court vacated the Board’s decision and remanded the case with instructions to assign Mrs. Grimes’s benefits to the Black Lung Disability Trust Fund. The court noted that future cases might provide additional arguments for such liability, but in this instance, the Trust Fund must pay. View "Apogee Coal Co. v. Office of Workers' Compensation Programs" on Justia Law

The case involves a challenge to Indiana's ballot access laws by the Indiana Green Party, the Libertarian Party of Indiana, and associated individuals. They argue that the requirements for candidates to collect signatures amounting to 2% of the votes cast in the last Secretary of State election, the process for submitting petitions, and the early deadline for submission are unconstitutional under the First and Fourteenth Amendments. They also challenge the law's indexing of party-level access to the results of the most recent Secretary of State election.The United States District Court for the Southern District of Indiana granted summary judgment in favor of the defendant, Indiana’s Secretary of State. The district court concluded that the 2% signature requirement and the June 30 deadline for submitting petitions were constitutionally permissible, relying on precedent from the Supreme Court and the Seventh Circuit. The court did not address the burdens created by the county-level submission requirement or the challenge to the indexing of the full slate access option.The United States Court of Appeals for the Seventh Circuit affirmed the district court's judgment. The court held that Indiana's ballot access requirements do not impose severe burdens on the plaintiffs' rights. The 2% signature requirement, the June 30 deadline, and the county-level submission process were deemed reasonable and justified by the state's interests in preventing voter confusion and ensuring orderly elections. The court also found that the requirement for parties to garner 2% of the vote in the Secretary of State election to maintain full slate access was reasonable, given the alternative petitioning route available to candidates. The court concluded that the state's regulatory interests were sufficient to justify the challenged restrictions. View "Indiana Green Party v. Morales" on Justia Law

Xengxai Yang robbed a credit union in Appleton, Wisconsin, wearing a black mask and armed with a sawed-off rifle. After his arrest, Yang admitted to the robbery, claiming he wanted to "try something new." He was indicted on multiple counts, including armed bank robbery. Yang initially raised an insanity defense but later withdrew it and entered a plea agreement. However, he subsequently sought to withdraw his guilty plea, citing ineffective assistance of counsel. A second psychological evaluation suggested Yang's mental conditions impaired his judgment during the crime. The court allowed Yang to withdraw his plea and reassert the insanity defense, but ultimately found him guilty and sentenced him to 168 months in prison.Yang did not appeal his conviction directly but filed a motion to vacate his sentence under 28 U.S.C. § 2255, claiming ineffective assistance of counsel. After an evidentiary hearing, Yang withdrew this claim and instead argued that the court's failure to hold a competency hearing violated his due process rights. The district court denied his motion, finding that Yang had procedurally defaulted his competency claim by not raising it earlier and that he was competent during the proceedings.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The court held that procedural default bars Yang's competency claim because he failed to raise it on direct appeal and did not demonstrate cause and prejudice or actual innocence to overcome the default. The court concluded that Yang's competency claim was procedurally defaulted and dismissed his petition for collateral relief under § 2255. View "Xengxai Yang v. United States" on Justia Law