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

Jacqueline Sterling failed to pay $500 in gym membership fees to Southlake Nautilus Health and Racquet Club, leading to a default judgment against her in the Superior Court of Lake County, Indiana. Despite a bankruptcy court discharging her debt, Southlake continued to enforce the judgment. Sterling did not notify the Lake County court of her bankruptcy or appear at a hearing, resulting in a bench warrant for her arrest. A year later, she was arrested during a traffic stop and spent a weekend in jail, missing work and suffering emotional distress.The bankruptcy court found Southlake in civil contempt for violating the discharge order and contributing to Sterling's arrest and resulting damages. The court also found Sterling partially at fault for not notifying the Lake County court of her bankruptcy. Applying comparative fault principles, the court allocated half the liability for Sterling's lost wages, emotional distress, and attorney’s fees to each party. Sterling was awarded $9,724.50 in compensatory damages and $99,355 in attorney’s fees.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that while compensatory damages in civil contempt proceedings must be awarded if the complainant proves the defendant's actions caused the injury, the court has broad discretion in awarding attorney’s fees. The bankruptcy court erred by not recognizing this distinction and improperly applied comparative fault principles to reduce the attorney’s fees award. The Seventh Circuit vacated the judgment in part and remanded the case to the bankruptcy court to reassess the attorney’s fees in light of its broad discretion. The court also clarified that costs should be allowed and directed the bankruptcy court to set a deadline for Sterling to file a bill of costs. View "Sterling v Southlake Nautilus Health & Racquett Club, Inc." on Justia Law

The defendant, Rolando Joel De Leon De Paz, pleaded guilty to illegally reentering the United States in violation of 8 U.S.C. § 1326. De Leon had been removed from the U.S. five times previously, with his first removal in 2002 following a conviction for the sale and delivery of methamphetamine. Subsequent removals occurred in 2008, 2013, 2016, and 2022, each following separate convictions for illegal reentry. Despite escalating sentences for each conviction, De Leon reentered the U.S. again and was arrested in January 2023. He was indicted for illegal reentry and pleaded guilty after the district court denied his motion to dismiss the indictment on equal protection grounds.The United States District Court for the Western District of Wisconsin calculated a sentencing Guidelines range of 21 to 27 months but imposed an above-Guidelines sentence of 48 months. The court justified the sentence by emphasizing De Leon's repeated illegal reentries and the failure of previous escalating punishments to deter him. The court also noted De Leon's struggle with alcohol, which contributed to his criminal behavior, although this was not the main reason for the above-Guidelines sentence.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 acted within its discretion in imposing the 48-month sentence, finding that the justifications provided were consistent with the 18 U.S.C. § 3553(a) factors. The court noted that De Leon's repeated offenses and the ineffectiveness of prior sentences warranted the above-Guidelines sentence. Additionally, the appellate court rejected De Leon's argument that the district court improperly relied on his alcohol dependence and found no abuse of discretion in the sentencing decision. The court also affirmed the district court's denial of De Leon's motion to dismiss the indictment, citing recent precedent. View "United States v De Leon De Paz" on Justia Law

Brian J. Murphy, a former employee of Caterpillar Inc., alleged that he was constructively discharged due to age discrimination and retaliation for previous legal actions against the company. Murphy, who began working for Caterpillar in 1979, had a long history of positive performance reviews and promotions. In 2000, he was placed on a performance action plan and subsequently fired after complaining about age discrimination. He sued Caterpillar, won a retaliation claim, and was reinstated in 2005. In 2018, after successfully leading a significant project, Murphy was placed on another performance action plan that he argued was designed for him to fail.The United States District Court for the Central District of Illinois granted summary judgment in favor of Caterpillar on all claims. The court found that Murphy did not provide sufficient evidence to support his claims of age discrimination and retaliation. Murphy appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that Murphy presented enough evidence to support a reasonable inference of pretext and unlawful intent regarding his age discrimination claim. The court noted that the performance action plan was flawed, as it included a deadline that had already passed and was signed off as failed before Murphy had a chance to comply. This, along with Murphy's consistent positive performance reviews, suggested that the plan was a pretext for discrimination. However, the court affirmed the summary judgment on Murphy's retaliation claim, citing the long gap between his previous lawsuit and the adverse action, and the lack of evidence of retaliatory animus.The Seventh Circuit reversed the district court's decision on the age discrimination claim, allowing it to proceed to trial, but affirmed the decision on the retaliation claim. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Murphy v Caterpillar Inc." on Justia Law

Gary Matthews and Monte Brannan collaborated on a project to redevelop a landmark hotel in Peoria, Illinois. Instead of fulfilling their financial obligations to lenders, they diverted project revenue for personal gain. This led to federal charges of mail fraud and money laundering, resulting in guilty verdicts by a jury.The United States District Court for the Central District of Illinois oversaw the initial trial. Matthews and Brannan were convicted of mail fraud, money laundering, and, in Brannan’s case, conspiracy to commit money laundering. They appealed their convictions, raising multiple issues.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found the evidence against Matthews and Brannan overwhelming, affirming their convictions. The court noted that Matthews and Brannan failed to comply with Circuit Rule 30(b)(1) by not including necessary district court rulings in their appendices, which hindered the appellate review process. Despite this, the court ensured a fair review by independently locating the relevant rulings. The court ordered Matthews’s and Brannan’s counsel to show cause why they should not be sanctioned for their violations of Circuit Rule 30. The court affirmed the district court’s judgment, ensuring that Matthews and Brannan received fair consideration of their appeals. View "USA v Brannan" on Justia Law

Curtis Walker, who was 17 years old when he committed murder, was sentenced to life in prison with a parole eligibility date set for 2071, effectively making it a life-without-parole sentence. After serving nearly 30 years, Walker sought postconviction relief, arguing that his sentence violated the Eighth Amendment based on a series of Supreme Court decisions regarding juvenile offenders sentenced to life without parole. Walker's request for a "meaningful opportunity" to demonstrate his rehabilitation was denied by the Wisconsin state courts, prompting him to file a federal habeas corpus petition.The Wisconsin Court of Appeals denied Walker's postconviction motion, holding that his sentence did not violate the Eighth Amendment because the sentencing judge had considered his youth and its attendant circumstances. The Wisconsin Supreme Court denied review. Walker then filed a federal habeas petition, which the district court dismissed as untimely and without merit, concluding that the Wisconsin Court of Appeals did not unreasonably apply federal law.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's denial of habeas relief. The court held that the Wisconsin Court of Appeals did not unreasonably apply Supreme Court precedent, particularly in light of the decisions in Miller v. Alabama, Montgomery v. Louisiana, and Jones v. Mississippi. The Seventh Circuit concluded that the state court's decision was not contrary to or an unreasonable application of clearly established federal law, as the Supreme Court's precedents did not clearly establish a categorical prohibition against sentencing corrigible juvenile offenders to life without parole. View "Walker v Cromwell" on Justia Law

Michael Williams was convicted by a Wisconsin jury of reckless homicide and possession of a firearm as a convicted felon. He appealed his convictions to the Wisconsin Court of Appeals, arguing that a jury instruction unconstitutionally lowered the government's burden of proof and that the prosecutor's closing arguments improperly shifted the burden of proof to him. The Wisconsin Court of Appeals affirmed the convictions, and the Wisconsin Supreme Court denied his petition for review.Williams then filed a petition for habeas corpus in the United States District Court for the Eastern District of Wisconsin. The district court held that the state appellate court reasonably applied Supreme Court precedent in concluding that it was not reasonably likely the jury applied the instruction in an unconstitutional manner. The court also held that Williams had not demonstrated that the prosecutor's remarks violated clearly established Supreme Court precedent.On appeal to the United States Court of Appeals for the Seventh Circuit, Williams raised the same two arguments. The Seventh Circuit affirmed the district court's decision. The court held that the Wisconsin Court of Appeals did not unreasonably apply Supreme Court precedent regarding the jury instruction on reasonable doubt. The court also found that the prosecutor's comments during closing arguments did not shift the burden of proof to the defense in a manner that violated due process, especially considering the trial court's curative instructions. The Seventh Circuit concluded that Williams had not shown that the state court's rulings were so lacking in justification as to constitute an unreasonable application of clearly established federal law. View "Williams v Meisner" on Justia Law

Verizon Wireless sought permits from the City of Milwaukee to install small cells and matching utility poles in a downtown plaza next to a major arena. The City denied most of the permits, initially citing aesthetic concerns and proximity to existing poles. Later, it claimed it lacked authority to grant the permits because the plaza was leased to Deer District LLC. Verizon sued the City, arguing the denials violated the Telecommunications Act (TCA) and Wisconsin state law. The district court ruled in favor of Verizon, finding the City's justifications insufficient and ordered the City to issue the permits. Verizon installed the poles, and the City accepted the ruling.The district court found that the City's initial reasons for denial were not supported by substantial evidence and violated the TCA. It also found the City's later rationale, based on the lease with Deer District, untimely and unconvincing. The court held that the City violated Wisconsin state law as well, and ordered the City to issue the permits. The City complied and did not appeal the decision. Deer District, an intervening defendant, appealed, challenging the district court's interpretation of the lease and state law, but not the TCA holding.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court dismissed Deer District's appeal for lack of Article III standing, as Deer District could not demonstrate that its injury would be redressed by a favorable decision. The court noted that the City did not join the appeal and that the injunction ran exclusively against the City. Therefore, even if the court ruled in Deer District's favor, it would not change the City's obligations under the district court's order. The appeal was dismissed for want of jurisdiction. View "Cellco Partnership v Deer District LLC" on Justia Law

In 1997, William Brokaw Price’s parents entered into a contract with Carri Scharf Trucking, Inc. (CST) for surface-level mining on their property. The contract allowed CST to extract sand, gravel, and topsoil in exchange for royalty payments. As the contract neared its end in 2010, Bill Price, Brokaw’s father, communicated with CST about future plans for the property but passed away shortly after. Years later, Brokaw discovered that the property had not been reclaimed as required by the contract, leading to a dispute over CST’s reclamation obligations and alleged trespassing.The Prices sued CST for breach of contract, and CST counterclaimed for breach based on the Prices’ trespass accusations. The first trial ended in a mistrial, and the second trial resulted in a verdict for CST. The district court denied the Prices’ motion for judgment as a matter of law and rejected CST’s request for attorney’s fees under the contract’s fee-shifting provision.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s decision, holding that the contract did not set a firm deadline for reclamation and allowed for a jury to resolve factual disputes about the instructions given by Bill Price. The jury had a sufficient basis for its verdict in favor of CST. Additionally, the court held that CST was not entitled to attorney’s fees because the contract’s fee-shifting provision only applied to parties enforcing the contract’s terms, and CST’s successful defense did not trigger that provision. The court affirmed the judgment of the district court in all respects. View "Price v Carri Scharf Trucking, Inc." on Justia Law

Fourteen plaintiffs, including pilots, a physician, a nurse, and an attorney, were required to undergo alcohol testing to maintain their employment and professional licenses. The tests, developed by United States Drug Testing Laboratories, Inc. (USDTL), indicated positive results for alcohol consumption, leading to significant professional harm. The plaintiffs alleged that the tests were unreliable and sued USDTL and its officers under the Racketeer Influenced and Corrupt Organizations Act (RICO) and state law. They also sued Choice Labs Services (CLS) and its owners, who provided the tests to the administrators.The plaintiffs initially filed suit in the Southern District of Florida, asserting claims for fraud and negligence. The district court dismissed the case without prejudice, finding the complaint insufficient. The plaintiffs then filed a second amended complaint, adding CLS as defendants. The case was transferred to the Northern District of Illinois, where the district court dismissed the RICO claims under Rule 12(b)(6) and denied supplemental jurisdiction over the state law claims. The plaintiffs' motion to alter or amend the judgment was also denied.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court's decision. The court held that the plaintiffs failed to establish proximate causation for their RICO claims, as they did not adequately allege a direct link between USDTL's alleged misrepresentations and their professional injuries. The court also found that the plaintiffs did not meet the heightened pleading requirements for fraud under Rule 9(b). Consequently, the RICO claims were dismissed with prejudice, and the state law claims were dismissed without prejudice. View "Ratfield v United States Drug Testing Laboratories, Inc." on Justia Law

TWD, LLC filed a complaint against Grunt Style LLC in 2018, alleging trademark infringement. Both companies sell goods with military-related trademarks. Grunt Style counterclaimed, asserting TWD was infringing on its prior trademark. The district court granted Grunt Style's motion for partial summary judgment in April 2022, dismissing all of TWD's claims. The case was reassigned to Judge Hunt, who held a bench trial in 2024 and ordered TWD to pay Grunt Style $739,500. Grunt Style moved to amend the judgment to include interest and permanent injunctive relief, which the district court granted in January 2025.TWD filed a notice of appeal from the amended judgment, which was docketed as appeal No. 25-1305. During a preliminary review, the Seventh Circuit identified a potential jurisdictional issue because the district court's judgment did not explicitly address TWD's counterclaims. The court directed the parties to address whether the judgment was deficient. TWD filed an amended notice of appeal, which was docketed as a new appeal, No. 25-1341. The district court later issued an indicative ruling, signaling its intent to correct the judgment if the case was remanded.The United States Court of Appeals for the Seventh Circuit agreed with the district court's solution and decided to remand the case for correction of the clerical mistake in the judgment. The court retained jurisdiction over the appeal and dismissed the second appeal (No. 25-1341) as unnecessary, without collecting an additional fee. The court emphasized the importance of clear and complete judgments to avoid jurisdictional issues and ensure appellate jurisdiction is clear. View "Grunt Style LLC v TWD, LLC" on Justia Law