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

Joel Cielak and Barron Hodges were sexually abused by David Johnson, a teacher at Nicolet High School (NHS), in the late 1970s and early 1980s. Hodges reported the abuse in 1983, leading the school board to confront Johnson but keep him employed under supervision. Johnson ceased abusing Hodges but continued to abuse Cielak, who had graduated in 1982. Both plaintiffs sued NHS, the school district, and board members under 42 U.S.C. §§ 1983 and 1985, alleging violations of their Fourteenth Amendment rights and a conspiracy to violate their equal protection rights. The district court dismissed the claims with prejudice and denied leave to amend the complaint.The United States District Court for the Eastern District of Wisconsin granted the defendants' motion to dismiss, concluding that the plaintiffs failed to state claims based on Johnson's abuse predating Hodges's 1983 allegation. The court also found that Hodges's claims were time-barred and that Cielak's allegations of post-allegation harms did not amount to violations of his substantive due process or equal protection rights. The court denied the plaintiffs leave to amend their complaint, deeming it futile.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court held that Hodges's claims were time-barred as he knew of his injuries and their cause in the fall of 1983. In contrast, the court found that it was unclear when Cielak knew or had reason to know that his post-allegation injuries were connected to actions by the defendants, making it improper to dismiss his claims on statute of limitations grounds at this stage. However, the court concluded that Cielak failed to plausibly plead a violation of his substantive due process or equal protection rights because Johnson's post-allegation abuse was not under color of state law. The court also upheld the denial of leave to amend, noting that the plaintiffs failed to explain how they would cure the complaint's defects. View "Cielak v. Nicolet Union High School District" on Justia Law

Three plaintiffs, planning to participate in protests during the Democratic National Convention in Chicago, challenged the constitutionality of a city ordinance listing prohibited items within security perimeters. The list includes items such as laptops, large bags, drones, bicycles, and pointed objects, among others. Plaintiffs argued that the ordinance is unconstitutionally vague, particularly concerning the prohibition of "pointed object(s)," which they feared could include everyday items like ballpoint pens and buttons.The United States District Court for the Northern District of Illinois denied the plaintiffs' request for a preliminary injunction, finding that the ordinance was not unconstitutionally vague. The plaintiffs then appealed this decision.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 ordinance has a core of ascertainable meaning, covering items that pose clear safety risks, such as weapons and explosives. The court noted that while the plaintiffs raised concerns about potential overreach, they had not demonstrated that a substantial number of the ordinance's applications were unconstitutional. The court concluded that the plaintiffs' facial challenge to the ordinance lacked merit, as the potentially problematic applications were not substantial in relation to the valid ones. The court also found that the plaintiffs had standing to challenge the ordinance but ultimately ruled against them on the merits. View "Thayer v. City of Chicago" on Justia Law

Don Bevly, a repeat bank robber, pleaded guilty to two counts of bank robbery and one count of attempted bank robbery. He also admitted to six additional bank robberies as relevant conduct. During sentencing, the government established that Bevly made death threats during two of the robberies, leading the district judge to increase his offense level by two levels under the Sentencing Guidelines. The judge also sentenced Bevly as a career offender due to his six prior bank robbery convictions.The United States District Court for the Northern District of Illinois, Eastern Division, handled Bevly's case. Bevly argued that the government had promised not to pursue the threat enhancement, but the judge rejected this claim based on the plea agreement and Bevly's statements during the guilty-plea colloquy. The judge also found that Bevly's prior convictions qualified him as a career offender, resulting in an advisory imprisonment range of 151 to 188 months. Ultimately, the judge imposed a below-guidelines sentence of 144 months.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district judge's decision, finding no error in the application of the threat enhancement or the career-offender designation. The court noted that the plea agreement clearly stated the government's right to seek the threat enhancement and that Bevly had confirmed under oath that no other promises were made. Additionally, the court held that bank robbery under 18 U.S.C. § 2113(a) qualifies as a crime of violence under the career-offender guideline, consistent with circuit precedent. The court also rejected Bevly's Sixth Amendment claim regarding judicial fact-finding at sentencing, citing established Supreme Court precedent. View "United States v. Bevly" on Justia Law

In 2020, Tamara Frazier applied for a mortgage with Mutual Federal Bank, which reviewed a credit report from CreditLink aggregating data from Equifax, Experian, and TransUnion. The bank denied her application. Frazier claimed that Equifax reported inaccurate late payments on her credit history, violating the Fair Credit Reporting Act (FCRA). She argued that her mortgage account, settled through a short sale in January 2016, was inaccurately reported as delinquent.The United States District Court for the Northern District of Illinois granted summary judgment to Equifax, finding that the information reported by Equifax was accurate. The court ruled that there was no inaccuracy in Equifax’s report, as the data furnished and reported by Equifax was true. Frazier appealed this decision.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court affirmed the district court’s decision, holding that Equifax’s report did not contain inaccuracies. The court noted that the information indicating Frazier’s account was 90 days delinquent was not misleading when viewed in full context, as it was accompanied by information that the account was closed and paid for less than the full balance. The court also found that Equifax could not be held liable for the CreditLink report, which was missing certain pertinent information and was not prepared by Equifax. Additionally, the court determined that the denial of Frazier’s loan application was due to her high debt-to-income ratio, not the alleged inaccuracies in the credit report. Therefore, the court concluded that Equifax’s report did not cause the denial of Frazier’s loan application. View "Frazier v. Equifax Information Services, LLC" on Justia Law

3M Company operates a manufacturing facility in Cordova, Illinois, producing chemical products containing PFAS. The State of Illinois sued 3M, alleging that PFAS from the Cordova Facility contaminated the Mississippi River, violating state environmental laws. The State's complaint specifically excluded PFAS contamination from any other source, including AFFF used by the U.S. military at the nearby Rock Island Arsenal.The case was initially filed in Illinois state court. 3M removed it to the United States District Court for the Central District of Illinois, citing the federal officer removal statute, arguing that some contamination might have come from AFFF provided to the military, thus invoking a federal government contractor defense. The State moved to remand the case back to state court. The district court granted the motion, finding that the State's complaint excluded AFFF-related contamination, focusing solely on PFAS from the Cordova Facility.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court held that 3M could not satisfy the fourth element required for removal under the federal officer removal statute, which necessitates a colorable federal defense. The court noted that the State had unequivocally conceded that it would not seek relief for mixed PFAS contamination and that any recovery would be barred if contamination was not solely from the Cordova Facility. Consequently, 3M's government contractor defense was deemed irrelevant under the State's theory of recovery. The Seventh Circuit affirmed the district court's decision to remand the case to state court. View "Raoul v. 3M Company" on Justia Law

Five former participants in the Salvation Army's residential rehabilitation program filed a lawsuit alleging that the organization subjected them to forced labor. The plaintiffs, who participated in the program to address issues such as homelessness and substance abuse, were required to work approximately forty hours per week in exchange for food, clothing, and housing. They claimed that the work was not therapeutic but rather a coercive labor arrangement benefiting the Salvation Army financially. The plaintiffs included both individuals who voluntarily enrolled in the program and those referred by courts or parole/probation departments.The United States District Court for the Northern District of Illinois dismissed the plaintiffs' claims. The court found that the justice-referred plaintiffs' claims were barred by the Rooker-Feldman doctrine, as they were allegedly compelled to participate by state court orders. For the walk-in plaintiffs, the court concluded that the threats of losing food, clothing, and shelter were not sufficiently serious to constitute forced labor under federal law. The court also found that the plaintiffs failed to allege that the Salvation Army acted with the requisite intent to compel labor through threats of serious harm. The district court denied the plaintiffs' request to amend their complaint, leading to an immediate entry of judgment for the Salvation Army.The United States Court of Appeals for the Seventh Circuit affirmed the district court's judgment. The appellate court held that the Rooker-Feldman doctrine did not bar the justice-referred plaintiffs' claims, as their participation was not compelled by state court orders but by parole or probation officers. However, the court found that the plaintiffs' allegations did not plausibly indicate that the Salvation Army violated the forced labor provisions. The walk-in plaintiffs were free to leave the program at any time, and the justice-referred plaintiffs did not adequately demonstrate how the conditions of their participation constituted forced labor. The court also agreed that the proposed second amended complaint would not cure the deficiencies of the original complaint. View "Taylor v. The Salvation Army National Corporation" on Justia Law

Donald Reynolds began a 60-month term of supervised release in 2020 after serving a lengthy prison sentence. During his supervision, he tested positive for methamphetamine twice. Despite efforts by the United States Probation Office to help him access drug treatment services, Reynolds failed to participate in the recommended programs. Consequently, the Probation Office petitioned to revoke his supervised release. At the revocation hearing, Reynolds admitted to violating his release conditions, and the district court revoked his supervised release, sentencing him to 21 months of custody.The United States District Court for the Northern District of Indiana initially handled the case. After Reynolds tested positive for methamphetamine, the Probation Office referred him to a recovery center. When he tested positive again, an intensive outpatient program was recommended, but Reynolds did not comply. The Probation Office then petitioned for revocation. A magistrate judge ordered Reynolds to participate in an inpatient drug treatment program, but he struggled with obtaining his mental health medications and attempted suicide. After leaving the treatment facility without permission, he was arrested.The United States Court of Appeals for the Seventh Circuit reviewed the case. Reynolds argued that the district court erred by not recognizing its discretion to consider substance abuse treatment as an alternative to revocation and incarceration. The appellate court affirmed the district court's decision, noting that even if the district court had realized its discretion under 18 U.S.C. § 3583(d), it would not have opted for further treatment given Reynolds's history of noncompliance. The court concluded that any error in the district court's understanding of its discretion was harmless, as the outcome would have been the same. View "United States v. Reynolds" on Justia Law

The case involves the crash of Lion Air Flight JT 610, a Boeing 737 MAX, which took off from Jakarta, Indonesia, and crashed into the Java Sea on October 29, 2018, killing all on board. The plaintiffs are family members and representatives of the estates of two passengers, Liu Chandra and Andrea Manfredi. They filed lawsuits against Boeing and other defendants, seeking damages under various legal theories, including the Death on the High Seas Act (DOHSA), state law, and other federal statutes.The Chandra case was initially filed in Illinois state court and then removed to the United States District Court for the Northern District of Illinois. The Manfredi case was filed directly in the same federal court. Both sets of plaintiffs demanded a jury trial and asserted claims under DOHSA, state law, and other federal statutes. Boeing filed motions to limit the plaintiffs' claims to DOHSA and to preclude a jury trial. The district court ruled in favor of Boeing, holding that DOHSA was the exclusive remedy and that the plaintiffs were not entitled to a jury trial. The court dismissed all non-DOHSA claims and certified the jury trial issue for interlocutory appeal.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's rulings, holding that DOHSA preempts all other claims and mandates a bench trial. The court reasoned that DOHSA's language and legislative history indicate that claims under the statute must be brought in admiralty, which does not carry the right to a jury trial. The court also noted that Congress has not amended DOHSA to allow for jury trials in federal court, despite longstanding judicial interpretations to the contrary. Therefore, the plaintiffs' claims must proceed without a jury. The court's decision was to affirm the district court's rulings. View "Buehler v. Boeing Company" on Justia Law

A family of six Mexican citizens entered the United States without authorization and were subsequently placed in removal proceedings. They hired an attorney to help them apply for asylum. Despite having nearly fifteen months to prepare, the attorney requested a continuance only eight days before the hearing, citing the government shutdown as a reason for her lack of preparation. The Immigration Judge (IJ) denied the continuance and, due to the attorney's unpreparedness, deemed the asylum applications abandoned, ordering the family's removal. The Board of Immigration Appeals (BIA) affirmed the IJ's decision.The family appealed to the United States Court of Appeals for the Seventh Circuit. The court dismissed the cases of two family members due to lack of jurisdiction, as their removal proceedings had been terminated after they received special immigrant status. The remaining four family members argued that the IJ erred in denying the continuance and that their attorney was ineffective. The court found that the IJ did not abuse his discretion in denying the continuance, as the attorney had ample time to prepare and failed to do so. The court also noted that the attorney's unpreparedness did not violate the family's due process rights.Regarding the ineffective assistance of counsel claim, the court acknowledged the attorney's failure to prepare but noted that the family did not present this claim to the BIA, thus failing to exhaust administrative remedies. Consequently, the court could not consider the ineffective assistance claim. The court suggested that the family could seek to reopen the proceedings through a motion to reopen or by requesting equitable tolling of the deadline.The United States Court of Appeals for the Seventh Circuit dismissed the petitions of two family members and denied the petitions for review of the remaining four family members. View "Bustos-Millan v. Garland" on Justia Law

AXIS Insurance Company sought indemnification from American Specialty Insurance & Risk Services for claims AXIS settled, based on a contract between the two parties. The contract did not require AXIS to offer American Specialty the choice to approve the settlement or assume the defense. However, American Specialty argued that Indiana law imposed such an obligation. The district court agreed with American Specialty and granted summary judgment in its favor.The United States District Court for the Northern District of Indiana found that AXIS's settlement payment was voluntary because AXIS did not give American Specialty the opportunity to approve the settlement or assume the defense. The court concluded that AXIS had to show actual liability on the underlying claim to seek indemnification, which AXIS could not do. Therefore, the district court ruled that American Specialty had no duty to indemnify AXIS for the settlement payment.The United States Court of Appeals for the Seventh Circuit reviewed the case and reversed the district court's decision. The appellate court held that the contract did not require AXIS to tender the defense to American Specialty before settling claims. The court also found that Indiana law does not imply such a requirement in indemnification agreements. The Seventh Circuit concluded that AXIS was not obliged to offer American Specialty the opportunity to approve the settlement or assume the defense as a condition precedent to indemnification. The case was remanded for further proceedings consistent with this opinion. View "Axis Insurance Company v. American Specialty Insurance & Risk Services" on Justia Law