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

Shawn Riley, a former prisoner at the Wisconsin Secure Program Facility (WSPF), filed a lawsuit under 42 U.S.C. § 1983 against WSPF’s Health Services Manager, Jolinda Waterman, and Nurse Practitioner Sandra McArdle. Riley alleged that they were deliberately indifferent to his serious medical needs, violating the Eighth Amendment. Riley experienced chronic pain and sought specific medical treatments, including high-top shoes recommended by specialists. Despite receiving various treatments, including medications, physical therapy, and custom orthotics, Riley claimed that his pain persisted and that the defendants ignored specialist recommendations.The United States District Court for the Eastern District of Wisconsin granted summary judgment in favor of the defendants and denied Riley’s motions to appoint counsel. The court found that the defendants were not deliberately indifferent to Riley’s medical needs, noting that they provided extensive medical care and followed many of the specialists' recommendations. The court also concluded that Riley’s requests for special shoes were reviewed and denied by the Special Needs Committee (SNC) and that the defendants' actions did not amount to deliberate indifference.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s decision, holding that the defendants did not ignore the specialists' recommendations and provided adequate medical care. The court also found that the defendants' refusal to allow Riley to purchase shoes from outside the approved catalog did not constitute deliberate indifference. Additionally, the court upheld the denial of Riley’s motion to appoint counsel, determining that Riley was competent to litigate his case and that the case did not present complexities that necessitated appointed counsel. The judgment of the district court was affirmed. View "Riley v. Waterman" on Justia Law

In February 2018, two men invaded a home in Rockford, Illinois, resulting in the death of Julian Young, Jr. and the escape of Jasmine Meneweather. Meneweather initially provided general descriptions of the assailants but no specific identities. Later, she sent a photo of one perpetrator to Detective Eric Harris, but the person was not identified. Over a year later, Harris received another photo from Young’s aunt, identifying the assailants as brothers Cortez and Shawnqiz Lee. Meneweather later identified Shawnqiz Lee in a photo array. Despite Lee’s alibi of being at work during the crime, he was arrested in November 2019 based on a criminal complaint and a judge-issued arrest warrant. A grand jury indicted Lee, but subsequent DNA evidence did not match him. Lee was released in December 2020 after the charges were dismissed.The United States District Court for the Northern District of Illinois granted summary judgment to the police officers, reasoning that probable cause existed based on Meneweather’s identification, which is an absolute defense to Lee’s claims. Lee appealed, arguing that the officers lacked probable cause and that they recklessly withheld material facts.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 probable cause existed based on Meneweather’s identification, which was sufficient to support the arrest warrant. The court also found that the officers did not recklessly withhold material facts that would have negated probable cause. Additionally, the grand jury indictment provided prima facie evidence of probable cause, which Lee failed to rebut. Consequently, the court affirmed the summary judgment in favor of the police officers, concluding that probable cause was an absolute defense to Lee’s Fourth Amendment and state-law claims. View "Lee v Harris" on Justia Law

Caroline Retzios was terminated by Epic Systems Corporation after she refused to be vaccinated against COVID-19, citing religious objections. She filed a lawsuit under Title VII of the Civil Rights Act of 1964, claiming that Epic was required to accommodate her religious beliefs. Epic requested the district court to compel arbitration based on an agreement Retzios had signed, which the court granted, subsequently dismissing the suit.The United States District Court for the Northern District of Illinois dismissed the case after referring it to arbitration, despite Epic's request for a stay. According to the Federal Arbitration Act, a stay should have been issued instead of a dismissal when arbitration is requested. This dismissal allowed Retzios to appeal the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case and determined that the district court erred in dismissing the suit instead of staying it. However, the appellate court proceeded with the case due to the district court's actions. The appellate court found that Retzios's claims fell within the scope of the arbitration agreement she had signed with Epic. The court rejected Retzios's arguments against the enforceability of the arbitration agreement, including her claims of promissory estoppel and waiver. The court also found her objections to arbitration to be frivolous and granted Epic's motion for sanctions, directing Retzios to reimburse Epic for its legal expenses incurred on appeal. The decision of the district court was affirmed, with sanctions imposed on Retzios. View "Retzios v Epic Systems Corp." on Justia Law

Blake Stewardson was arrested for driving under the influence on January 1, 2018, and taken to Cass County Jail. While intoxicated, he directed profanities at police and resisted during intake, leading Officer Titus to slam his head against a wall twice, causing a cut. Titus then performed a leg sweep, causing Stewardson to fall and hit his head. Later, Titus opened a cell door into Stewardson and performed a hip toss. Stewardson sued Titus and Biggs, alleging excessive force and failure to intervene.The United States District Court for the Northern District of Indiana granted summary judgment to the defendants on many claims but allowed two to proceed to trial: one against Titus for excessive force and one against Biggs for failing to intervene. The jury found Titus liable and awarded $400,000 in compensatory damages and $850,000 in punitive damages. Biggs was found not liable for failing to intervene. Titus appealed the punitive damages award, and Stewardson cross-appealed the summary judgment decisions.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court upheld the jury's punitive damages award against Titus, finding it not unconstitutionally excessive given the reprehensibility of his conduct, the ratio of punitive to compensatory damages, and comparable cases. The court also affirmed the district court's summary judgment in favor of Biggs, concluding that he did not violate clearly established law regarding excessive force or failure to intervene. Additionally, the court upheld the summary judgment on Stewardson's Monell claim against Cass County, finding insufficient evidence of an unconstitutional custom. View "Stewardson v. Titus" on Justia Law

Tara Osborn, a technical support specialist, was terminated by JAB Management Services, Inc., which provides prison healthcare. Osborn sued her former employer, alleging violations of state and federal employment law, including a claim that JAB Management failed to compensate her for overtime work as required by the Fair Labor Standards Act (FLSA). JAB Management moved for summary judgment on the overtime claim.The United States District Court for the Central District of Illinois granted summary judgment in favor of JAB Management. The court found that Osborn failed to comply with local rules in her response to the summary judgment motion, leading to her amended response being struck. Consequently, the court deemed JAB Management's facts as admitted and found that Osborn did not provide sufficient evidence to show she worked overtime.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's decision, holding that Osborn did not meet her initial burden of proving she worked uncompensated overtime. The court noted that Osborn's evidence was vague, conclusory, and lacked specificity regarding her work hours. Additionally, her claims were inconsistent with other evidence in the record. The court also found that even under the relaxed just and reasonable inference standard for proving damages, Osborn's evidence was insufficient to establish the amount and extent of her overtime work. Therefore, the Seventh Circuit affirmed the district court's grant of summary judgment in favor of JAB Management. View "Osborn v JAB Management Services, Inc." on Justia Law

An inmate at Green Bay Correctional Institution, who is a practicing Muslim, filed a lawsuit under the Religious Land Use and Institutionalized Persons Act (RLUIPA) against the Wisconsin Department of Corrections (WDOC). He challenged WDOC's policy prohibiting inmates from leading religious programs when no outside religious leader or volunteer is available, claiming it resulted in unnecessary cancellations of religious programs. He also alleged that the cancellation of these programs breached a prior settlement agreement with WDOC.The United States District Court for the Western District of Wisconsin granted summary judgment in favor of WDOC on the RLUIPA claim, finding that the policy was the least restrictive means of furthering the compelling interest of maintaining prison safety and security. The court also granted summary judgment in favor of the inmate on the state law breach-of-contract claim as to liability but relinquished supplemental jurisdiction over the request for injunctive relief.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's summary judgment in favor of WDOC on the RLUIPA claim, agreeing that the policy was the least restrictive means to ensure prison safety and security. However, the appellate court vacated the district court's partial judgment on the state law breach-of-contract claim. The court held that the district court abused its discretion by relinquishing jurisdiction over the remedy portion of the claim while retaining jurisdiction over liability. The case was remanded to the district court to determine whether to retain or relinquish jurisdiction over the entire state law claim. View "West v Hoy" on Justia Law

Kevin Johnson, an inmate in Indiana, filed a pro se lawsuit under 42 U.S.C. § 1983, alleging that he received inadequate dental and mental health care while incarcerated. The case was complicated by the COVID-19 pandemic and Johnson's frequent transfers between prisons in Indiana, Ohio, and Virginia, which disrupted his mail service. Johnson claimed he never received the defendants' summary judgment motions due to these mail issues.The United States District Court for the Southern District of Indiana initially denied the defendants' summary judgment motions without prejudice, recognizing potential mail delivery problems. The court allowed the defendants to refile their motions and instructed them to notify the court if Johnson did not receive the filings. Despite these measures, Johnson did not respond to the refiled motions within the given 28-day period. Consequently, the district court granted summary judgment in favor of the defendants and dismissed the case. Johnson later filed a motion to vacate the judgment, asserting he never received the refiled motions, but the district court denied this motion.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court acknowledged the procedural complexities but focused on whether Johnson had constructive notice of the summary judgment motions. The court concluded that Johnson had constructive notice because he received the district court's order resetting the briefing schedule and instructing him on how to proceed. The court found no substantive or procedural error in the district court's decision and affirmed the summary judgment in favor of the defendants. View "Johnson v Purdue" on Justia Law

Technical Security Integration, Inc. ("Technical Security") and EPI Technologies, Inc. ("EPI") entered into a Sales Representative Agreement in which EPI agreed to sell Technical Security's products in exchange for commissions. The agreement included a clause requiring disputes to be submitted to mediation, and if mediation failed within 180 days, the prevailing party in any subsequent litigation would be entitled to attorneys' fees. A dispute arose, and EPI demanded mediation, but Technical Security did not respond promptly. EPI then sued Technical Security in state court, where it mostly lost. Technical Security sought attorneys' fees in federal court, which the district court denied, ordering each party to pay its own fees.The Circuit Court of Cook County, Illinois, granted partial summary judgment for Technical Security on the commissions dispute. EPI's remaining claims were dismissed, and the state court denied Technical Security's motion for attorneys' fees, citing a factual dispute. Technical Security then demanded mediation to resolve the fee dispute, but EPI did not respond. Technical Security subsequently sued EPI in the Northern District of Illinois, seeking fees and costs from the state court litigation. The district court granted summary judgment for EPI, concluding that Technical Security had delayed the mediation process.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that the agreement did not specify a timeline for mediation demands or responses, creating ambiguity. The court held that the district court erred in faulting Technical Security for preventing mediation without considering whether EPI's actions were reasonable. The Seventh Circuit vacated the district court's summary judgment for EPI and remanded the case for further proceedings to determine the reasonableness of each party's conduct regarding the mediation timeline. View "Technical Security Integration, Inc. v EPI Technologies, Inc." on Justia Law

Lorenzo Johnson ran an online child-pornography scheme, inducing financially desperate women to send him sexually explicit photos of their young children by promising them money. Law enforcement identified Johnson's IP address, social media accounts, and cellphone, leading to a search of his home where they found his phone containing evidence of the crimes and a handgun. Johnson confessed to key details of his scheme in two recorded interviews with FBI agents. A jury found him guilty of conspiracy to produce child pornography, distribution of child pornography, and unlawful possession of a firearm as a felon.The United States District Court for the Northern District of Indiana, Hammond Division, handled the initial trial. Johnson's requests for new counsel were denied by both the magistrate judge and the district judge. The district judge also denied Johnson's motion for a new trial based on a late disclosure of potential Brady/Giglio evidence, which involved a romantic relationship between two FBI agents. Additionally, Johnson argued that the judge made an improper factual finding at sentencing regarding his causal role in the suicide of one of the women involved in his scheme.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the lower court's decisions, holding that the magistrate and district judges appropriately exercised their discretion in denying Johnson’s requests for new counsel. The district judge properly denied Johnson’s motion for a new trial because it was undeveloped and the new information was deemed immaterial. Lastly, the court found that the judge’s comments at sentencing about the co-conspirator’s suicide were part of a holistic assessment of the seriousness of the crimes and did not amount to a factual finding that Johnson was causally responsible. The Seventh Circuit affirmed the district court's rulings and Johnson's conviction and sentence. View "U.S. v. Johnson" on Justia Law

Bellin Memorial Hospital hired Kinsey & Kinsey, Inc. to upgrade its computer software. Kinsey failed to implement the agreed-upon software, leading Bellin to sue Kinsey in Wisconsin state court for breach of contract and other claims. Bellin also sued Kinsey’s president and a senior product consultant. Kinsey’s insurer, Philadelphia Indemnity Insurance Company, provided a defense under a professional liability insurance policy. During the trial, Bellin and Philadelphia Indemnity entered into a partial settlement, resolving some claims and specifying the conditions under which Bellin could collect damages from Kinsey. Bellin prevailed at trial and was awarded damages.The Wisconsin circuit court ruled that the limited liability provision in the Agreement did not apply due to Kinsey’s material breach. The court granted a directed verdict on the breach of contract claim against Kinsey, leaving the question of damages to the jury. The jury awarded Bellin $1.39 million, later reduced to $750,000 plus costs. The jury found Kinsey and its president not liable for intentional misrepresentation and misleading representation.Philadelphia Indemnity filed a declaratory judgment action in the United States District Court for the Northern District of Illinois, seeking a declaration that the state court’s judgment was covered by the insurance policy and that the $1 million settlement offset the $750,000 judgment. The district court ruled for Bellin, concluding that the state court judgment was not covered by the insurance policy.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The court held that the insurance policy covered only negligent acts, errors, or omissions, and the state court’s judgment was based on a breach of contract, not negligence. Therefore, the $1 million set-off provision did not apply, and Bellin could recover the full amount of the judgment. View "Philadelphia Indemnity Insurance Co. v Kinsey & Kinsey, Inc." on Justia Law