Satkar Hospitality, Inc.v. Fox Television Stations, Inc., No. 11-3572 (7th Cir. 2014)Annotate this Case
Satkar owns Schaumburg, Illinois hotel and was mentioned in blog posts and a television news report as having made a large donation to a local politician and later won a property-tax appeal. In response, the Cook County Board of Review revoked Satkar’s property-tax reduction and opened an inquiry. Satkar sued the Board, its members and staff, the blog, the television station, and reporters, under 42 U.S.C. 1983, and for defamation and false light. The district court dismissed the 1983 claims against the Board and the officials. The Seventh Circuit affirmed. The court separately dismissed the state-law claims against the media defendants, applying the Illinois Anti-SLAPP statute. Because the section 1983 claims were still pending, the judge entered final judgment under FRCP 54(b) to permit appeal of the SLAPP issue. Later, the judge orally invited Satkar to ask for a Rule 54(b) judgment on the SLAPP dismissal, forgetting that he had already entered final judgment. Satkar did not correct the judge, did not seek clarification, and did not file a notice of appeal. After the deadline to appeal expired, Satkar sought an extension, claiming that the judge’s comment created confusion. The judge granted the extension, relying on the defunct “unique circumstances” doctrine. The Seventh Circuit dismissed an appeal, noting that the Supreme Court has disavowed the unique circumstances doctrine and Satkar has not otherwise demonstrated excusable neglect.