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

In this putative class action filed shortly after two fatal crashes of new Boeing 737 MAX airliners led to a worldwide grounding of those planes and a halt to production, resulting to a significant drop in the value of Boeing stock, the Seventh Circuit affirmed the judgment of the district court granting Defendants' motion to dismiss under Fed. R. Civ. P. 12(b)(6), holding that there was no error.At issue was The Boeing Company's employee stock ownership plan (ESOP) and whether Boeing plan fiduciaries' delegation to an independent outside fiduciary the selection and management of investment options for the ESOP protected the company and company insiders from liability for the plan's continued offering of Boeing stock as an independent option for employees before and during the time when the Boeing stock dropped. Plaintiffs argued that Boeing's continuous concealment of material facts relating to the 737 MAX jets caused the price of the stock to be artificially inflated and that Defendants should disclosed the safety issues to the public immediately. The district court dismissed the action. The Seventh District affirmed, holding that the delegation of investment decisions to an independent fiduciary meant that Boeing did not act in an ERISA fiduciary capacity in connection with the continued investments in Boeing stock. View "Burke v. Boeing Co." on Justia Law

The Seventh Circuit reversed the judgment of the district court in this (Cooper II) lawsuit brought by Jack Cooper against Retrieval-Masters Creditors Bureau (RMCB) asserting an additional violation of the Fair Debt Collection Practices Act (FDCPA) arising out of the same debt that was the subject of an appeal in a separate civil action between the same parties (Cooper I), holding that the sanctions award was improper.Plaintiff sued RMCB alleging that a letter from RMCB he received seeking to collect a consumer debt violated the FDCPA. Plaintiff then filed this separate action against RMCB claiming additional violations of the FDCPA arising from the same debt. RMCB filed a motion to dismiss the Cooper II complaint, arguing that it was improper claim splitting. The trial court dismissed the action with prejudice. Thereafter, RMCB moved for sanctions. The court granted the motion in part and imposed sanctions on two lawyers and their firm. The Seventh Circuit reversed, holding that the district court's stated grounds for imposing monetary sanctions against counsel did not support the sanctions. View "Cooper v. Retrieval Masters Creditors" on Justia Law

The Seventh Circuit vacated the fee award entered by the district court in this dispute over attorney fee awards to prevailing plaintiffs under consumer-protection statutes where damages are modest and the plaintiff has rejected a substantial early settlement offer, holding that the fee award was an abuse of discretion.Plaintiff sued Defendant for violating the Fair Debt Collection Practices Act, 15 U.S. 1692 et seq., in attempting to collect a debt. The district court granted summary judgment to Plaintiff on liability and awarded Plaintiff $500. Plaintiff and his attorneys then sought an award of attorney fees and costs of more than $66,000. The district court awarded fees and costs of less than $8,000. The Seventh Circuit vacated the award, holding that the district court's refusal to grant any post-offer fees was an abuse of discretion. View "Cooper v. Retrieval-Masters Creditors Bureau, Inc." on Justia Law

Officers found nine firearms in Prado’s home: five were stolen and one had an obliterated serial number. Prado pled guilty to unlawful possession of a firearm as a felon, 18 U.S.C. 922(g)(1).The district court calculated the initial base offense level as 20, which was lower than the base offense level of 22 recommended in the PSR because Prado’s prior conviction for mob action by force was not a crime of violence. The court applied a four-level enhancement (U.S.S.G. 2K2.1(b)(1)(B)) because the offense involved 8-24 firearms; a two-level enhancement (U.S.S.G. 2K2.1(b)(4)(A)) because Prado possessed a stolen firearm; and a four-level enhancement under subsection (B) because Prado possessed a firearm with an obliterated serial number. The PSR indicated that section 2K2.1(b)(4) allowed the application of only one of the enhancements in its subsections, not both. A “hanging paragraph” in 2K2.1(b) provided that the cumulative offense level from the application of 2K2.1(b)(1)–(4) may not exceed 29. Following the imposition of those enhancements, the court applied a four-level enhancement (2K2.1(b)(6)(B)) because Prado used or possessed the firearms in connection with another felony, and deducted three levels for Prado’s acceptance of responsibility. Despite a guideline range of 135-168 months, the statutory maximum was 120 months.The Seventh Circuit affirmed Prado's 108-month sentence, rejecting an argument concerning Prado’s guideline range. Under any calculation, the applicable guideline range is the 120-month statutory maximum. View "United States v. Prado" on Justia Law

Marin entered the U.S. illegally as a child in 1988 and was removed within months. He illegally reentered, was ordered removed in 1997, and was removed to Mexico. He illegally reentered, returned to Mexico, and reentered again—most recently in 2004, then remained in the U.S., accumulating convictions for residential burglary, domestic battery, illegal firearm possession, and four DUIs. DHS located Marin in an Illinois prison and reinstated the 1997 removal order. Because Marin has been convicted of residential burglary, an aggravated felony, he is inadmissible for 20 years, 8 U.S.C. 1182(a)(9)(A)(i), and is barred from seeking withholding of removal under the Immigration and Nationality Act or the Convention Against Torture.He sought deferral of removal under the Convention. An asylum officer determined that he had a reasonable fear of torture; he was placed in “withholding only” proceedings. The judge granted deferral of removal. The BIA reversed and ordered him removed. Marin petitioned for review but did not seek a stay of removal from the court. His request for a DHA administrative stay was denied. He was removed while his case was pending. The Seventh Circuit dismissed a petition for review. Because he seeks only deferral of removal in a withholding-only proceeding, his removal moots his claim for relief. View "Garcia-Marin v. Garland" on Justia Law

The Seventh Circuit affirmed the judgment of the district court granting summary judgment to Defendants on all claims asserted against them, including misappropriation of trade secrets and breach of an implied contractual obligation to assign patent rights but vacated the judgment awarding attorneys' fees, holding that a reduction in fees was warranted.REXA, Inc. sued Mark Chester and MEA, Inc. for misappropriation of trade secrets and breach of an implied contractual obligation to assign patent rights, alleging that Chester and MEA incorporated and disclosed confidential designs. The district court granted summary judgment to Defendants. The Seventh Circuit affirmed in part and vacated in part, holding that the district court (1) properly granted summary judgment in favor of Defendants; but (2) abused its discretion in awarding Chester and MEA approximately $2.357 million in attorneys' fees, which they requested as a sanction for REXA's litigation conduct, where the court did not make specific findings about each of REXA's objections to the fee petition. View "REXA, Inc. v. Chester" on Justia Law

The Seventh Circuit affirmed the decision of the district judge entering summary judgment for Rush University Medical Center on all claims brought by Dr. Peter Jokich under Title VII of the Civil Rights Act of 1964 and Illinois law, holding that there was no error or abuse of discretion in the proceedings below.Jokish, a radiologist who had worked at Rush for nearly two decades before being fired, brought this action arguing that his termination was unlawful retaliation for his participation in a colleague's Title VII lawsuit and that Rush both violated the employment contract and failed to adhere to an agreement guaranteeing his employment for an additional time period. The district court granted summary judgment against Jokish on all claims. The Seventh Circuit affirmed, holding that the record did not support Jokich's Title VII claims or his breach of contract claims. View "Jokich v. Rush University Medical Center" on Justia Law

The Seventh Circuit affirmed the judgment of the district court, holding that Plaintiff, a guidance counselor at a Catholic high school, was a minister and that the ministerial exception barred of all her claims against Roncalli High School and the Archdiocese of Indianapolis, both federal and state, holding that there was no error.After Plaintiff informed Roncalli's leadership that she was in a same-sex union she was given notice that her employment would not be renewed for the next school year because her conduct violated the terms of her contract. Plaintiff brought this complaint, alleging several claims. The trial court granted summary judgment based on the ministerial exception, grounded in the First Amendment's Religion Clauses, which bars interference with the selection and control of a religious organization's ministers. The Seventh Circuit affirmed, holding that the Archdiocese was entitled to fire Plaintiff without regard to the substantive rules in Title VII of the Civil Rights Act. View "Starkey v. Roman Catholic Archdiocese of Indianapolis, Inc." on Justia Law

The Seventh Circuit reversed the judgment of the district court granting summary judgment in favor of the Federal Aviation Administration (FAA) and dismissing Plaintiff's claims that the FAA violated Title VII by retaliating against her for filing a formal complaint of religious discrimination, holding that a reasonable juror could conclude that retaliatory animus influenced Defendant's decision-making and proximately caused Plaintiff's termination.Plaintiff violated the FAA's alcohol and drug policy when she was arrested for an alcohol-related offense. By self-reporting her infraction, Plaintiff avoided disciplinary action if she completed a rehabilitation plan supervised by the FAA. Plaintiff objected on religious reasons to the plan's requirement that she attend Alcoholics Anonymous meetings and complained of religious discrimination, even after the FAA approved her participation in an alternate recovery program. The district court concluded that Plaintiff failed to establish a causal link between the formal complaint and her termination and granted summary judgment to the FAA. The Seventh Circuit reversed, holding that, under the causation standard for federal-sector retaliation claims, a reasonable juror could conclude that retaliatory animus influenced the FAA's decision-making and proximately caused Plaintiff's termination. View "Huff v. Buttigieg" on Justia Law

The Seventh Circuit affirmed the order of the district court denying Defendants' requests for reduced sentences following their convictions stemming from their participation in a drug conspiracy involving the distribution of crack cocaine and heroin, holding that the district court properly denied Defendants' requests for reduced sentences.In 2009 and 2010, Defendants pleaded guilty to one count each of conspiracy to possess with intent to distribute and to distribute controlled substances. In 2020, Defendants each filed motions under 404(b) of the First Step Act seeking reductions in their sentences based on changes congress made to penalties resulting from certain drug crimes. The district court judge denied the motions. The Seventh Circuit affirmed, holding that the district court did not abuse its discretion in ruling that Defendants were not entitled to relief under the First Step Act. View "United States v. Clay" on Justia Law