U.S. Court of Appeals for the Seventh Circuit - Justia Case Law Summaries

USA v Pennington

2026-09-04T13:00:09-08:00

After being stopped by Illinois State Police for speeding, a driver was questioned about his criminal history and denied a request to search his vehicle. The officer issued only a warning and allowed the driver to leave. However, the officer notified a nearby canine unit about his suspicions. Less than two hours later, the canine officer observed the driver commit another traffic infraction, pulled him over, and conducted a dog sniff that led to the discovery of drugs in the vehicle. The driver was subsequently indicted for possession with intent to distribute cocaine base. Reviewing the case, the United States District Court for the Central District of Illinois denied the driver’s motion to suppress the drug evidence, finding the second traffic stop was independently justified by a new traffic violation and that the dog sniff did not unreasonably prolong the stop. The district court also denied the driver’s motion to dismiss the indictment for vindictive prosecution and selective enforcement, concluding that there was no evidence of impermissible motives or that similarly situated individuals were treated differently. The driver entered a conditional guilty plea, reserving the right to appeal these rulings. On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s decisions. The appellate court held that the initial traffic stop was unreasonably prolonged but that the evidence from the second stop was attenuated from this violation, as the second stop was based on an independent traffic infraction. The court also found the second stop was not unlawfully prolonged and that the dog sniff occurred during the normal course of the traffic warning process. Regarding the motion to dismiss, the court held the driver failed to raise a reasonable doubt that enforcement was selectively or vindictively motivated and upheld the denial of an evidentiary hearing. View "USA v Pennington" on Justia Law

Caraba v Paul Revere Life Insurance Co.

2026-09-03T12:30:07-08:00

A dentist applied for benefits under his individual disability insurance policy after suffering impairments to his hip and back. While his claim was under review, he received payments from his insurer for over a year. During that period, he earned income through part-time teaching and performing duties for two professional dental associations. After discovering this income, the insurer terminated his benefits, determining that his continued work qualified as a “gainful occupation” and thus he did not satisfy the policy’s requirement for “total disability.” The dentist subsequently filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, alleging breach of contract and seeking statutory penalties for bad faith under the Illinois Insurance Code. Both parties moved for summary judgment. The district court granted summary judgment in favor of the insurer, finding that the policy’s language was unambiguous and that the dentist was, as a matter of law, engaged in a gainful occupation based on the undisputed facts. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s ruling de novo. The appellate court held that the policy unambiguously required the claimant to show not only inability to perform his prior occupation but also that he was not engaged in any other gainful occupation. The court concluded that “gainful occupation” was not ambiguous and that the dentist’s nonclinical work, which generated substantial income, disqualified him from benefits. The court also rejected the contention that “gainful occupation” should be defined as earning at least 60% of pre-disability income, finding no support for that standard in the policy language. The Seventh Circuit affirmed the district court’s judgment for the insurer. View "Caraba v Paul Revere Life Insurance Co." on Justia Law

USA v Frazier

2026-09-02T13:00:09-08:00

Matthew Frazier was convicted in federal court for possession of child pornography under 18 U.S.C. § 2252A and sentenced to 120 months' imprisonment and seven years of supervised release. Frazier had a prior history involving a state court conviction for similar offenses, during which he was initially found incompetent to stand trial but later restored to competency following mental health treatment. After his release on probation, authorities discovered that he was again accessing prohibited materials, leading to a federal search that uncovered additional incriminating evidence. Prior to his federal trial, Frazier underwent a psychological evaluation, revealing ongoing hallucinations but ultimately concluding he was competent to stand trial. Following Frazier's waiver of a jury trial in the United States District Court for the Northern District of Indiana, he made statements about experiencing hallucinations. However, neither his attorney nor the prosecutor questioned his competency at that time, and the district judge conducted a thorough inquiry into his understanding of the proceedings. Defense counsel confirmed that Frazier’s decision-making abilities were consistent with the earlier finding of competency. On appeal to the United States Court of Appeals for the Seventh Circuit, Frazier challenged the district court’s failure to order a second competency hearing and contested the supervised release condition requiring full-time employment. The Seventh Circuit held that the district court did not abuse its discretion by not ordering a second competency hearing, given the evidence and the deferential standard of review. Regarding supervised release, the court concluded that the employment condition was not plain error because it included alternatives like community service or job training, and Frazier had not shown he was incapable of meeting those requirements. The Seventh Circuit affirmed the judgment of the district court. View "USA v Frazier" on Justia Law

Reynoso-Salgado v Blanche

2026-09-01T10:00:08-08:00

Maria Reynoso-Salgado, a Mexican citizen, has lived in the United States since 1997. In 2012, she pleaded guilty to a misdemeanor charge of child neglect under Wisconsin law. The following year, the Department of Homeland Security initiated removal proceedings against her, alleging she was present in the country without proper authorization. Reynoso-Salgado admitted the factual allegations and sought cancellation of removal, which is only available to noncitizens without certain disqualifying convictions. An immigration judge denied her request for cancellation, finding that her conviction for child neglect constituted a “crime of child abuse, child neglect, or child abandonment” under 8 U.S.C. § 1227(a)(2)(E)(i), making her ineligible for relief. The Board of Immigration Appeals affirmed this decision, concluding that the Wisconsin statute was a categorical match to the federal standard for such crimes. Reynoso-Salgado then petitioned the United States Court of Appeals for the Seventh Circuit for review, arguing that her state conviction should not disqualify her from cancellation of removal. The United States Court of Appeals for the Seventh Circuit considered whether the Wisconsin child neglect statute matched the federal definition of a “crime of child abuse, child neglect, or child abandonment” for immigration purposes. Employing the categorical approach, the court concluded that the elements of the Wisconsin statute—requiring intentional conduct resulting in a child’s neglect—met or exceeded the minimum mental state and conduct required by the federal statute. The court also held that the federal provision should be read as a single category encompassing various forms of child maltreatment, with a minimum mens rea of criminal negligence. The Seventh Circuit denied Reynoso-Salgado’s petition, holding that her conviction rendered her ineligible for cancellation of removal. View "Reynoso-Salgado v Blanche" on Justia Law

Sima v Benesch, Friedlander, Coplan & Aronoff LLP

2026-08-28T13:00:08-08:00

The plaintiff, an individual designer, developed a spill-proof cup lid and sought to have it manufactured and sold. She contacted a company for manufacturing and, during this process, shared confidential materials with a sales representative who was also representing the manufacturer in the same product category. Later, she discovered that the manufacturer had released a product almost identical to her design and had obtained both a design and a utility patent for it. The plaintiff then engaged a law firm and attorney to pursue potential legal claims and settlement discussions with the manufacturer’s parent company. During the representation, the attorney was negotiating employment with the law firm representing the opposing party, a fact not initially disclosed to the plaintiff. Eventually, the law firm terminated its representation of the plaintiff, citing unpaid fees. After the termination, the plaintiff, acting without legal counsel, filed suit in the United States District Court for the Northern District of Illinois against the law firm and the attorney, asserting multiple claims including legal malpractice, fraud, breach of contract, and intentional infliction of emotional distress. The district court dismissed the complaint with prejudice for failure to state a claim, emphasizing the plaintiff’s failure to adequately allege harm causally connected to the defendants’ conduct, particularly any lost viable legal claim or damages resulting from the alleged conflict of interest. The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s dismissal. The appellate court held that, under Ohio law (as specified in the retainer agreement), the plaintiff did not sufficiently plead that the attorney’s conduct caused her to lose any viable underlying legal claim due to the expiration of a statute of limitations. The court also found the plaintiff’s alternative theories of harm, including loss of the retainer fee and emotional distress, insufficient to sustain a malpractice claim. Accordingly, the judgment was affirmed. View "Sima v Benesch, Friedlander, Coplan & Aronoff LLP" on Justia Law

Metroplex Communications, Inc. v Meta Platforms, Inc.

2026-08-27T13:00:07-08:00

Metroplex Communications, Inc., which operates several local news outlets in Illinois, earns revenue by selling advertising space. Meta Platforms, Inc., the owner of Facebook, also sells ads and competes for the same local advertisers. Metroplex, representing a putative class of small businesses that compete with Meta for advertisers, alleged that Meta engaged in unlawful, anticompetitive practices by misrepresenting the reach and effectiveness of its Facebook advertisements, thereby drawing advertisers away from other platforms. The suit is based on claims under the Lanham Act and the Illinois Uniform Deceptive Trade Practices Act, seeking disgorgement of profits Meta allegedly earned through misleading conduct. Although Metroplex had purchased Facebook ads in the past, its lawsuit was brought in its capacity as a competitor, not as an ad purchaser. Meta moved to compel arbitration in the United States District Court for the Southern District of Illinois, arguing that Metroplex’s prior ad purchases subjected it to an arbitration clause in Meta’s Commercial Terms. The district court denied the motion, reasoning that Metroplex’s claims arose from its status as a competitor and not from its own ad purchases or contractual relationship as an ad buyer. The court found the claims to be outside the scope of the arbitration clause. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the scope of the arbitration clause de novo, applying Illinois law. The court held that Metroplex’s unfair competition claims were not sufficiently connected to Metroplex’s ad purchases or Meta’s Commercial Terms to fall within the arbitration agreement. The claims centered on alleged anticompetitive conduct and public misrepresentations, unrelated to Metroplex’s own limited use of Meta’s ad services. The court affirmed the district court’s denial of Meta’s motion to compel arbitration, holding that the arbitration clause did not apply to Metroplex’s claims as a competitor. View "Metroplex Communications, Inc. v Meta Platforms, Inc." on Justia Law

USA v. Musselman

2026-08-27T07:30:08-08:00

Carrie Musselman, a chiropractor in Illinois, expanded her practice to include non-chiropractic medical services and subsequently engaged in fraudulent billing practices targeting Medicare. She directed staff to bill services performed by nurse practitioners and physician assistants under physicians’ names, circumventing Medicare’s “Incident To” requirements, which resulted in higher reimbursements. Additionally, she billed a non-surgically implanted pain-relief device using a code for surgically implanted devices and billed sublingual allergy drops under a code intended for injectable allergy treatments. Despite repeated internal and external warnings about these improper practices, Musselman persisted, primarily seeking advice from sources with vested financial interests. A federal grand jury indicted Musselman on charges of healthcare fraud, wire fraud, and obstruction of a federal audit. Following a 13-day trial in the United States District Court for the Central District of Illinois, a jury found her guilty of healthcare fraud and five counts of wire fraud, acquitting her on other charges. Post-verdict, the district court discovered that the jury foreperson had created a deliberation guide based on online articles, which included references to non-unanimous verdicts. Musselman moved for a new trial on this basis and challenged the court’s use of an “ostrich” instruction regarding deliberate ignorance. The district court denied both motions, reasoning that the outside research was harmless and the ostrich instruction was justified by the evidence. On appeal, the United States Court of Appeals for the Seventh Circuit affirmed. The court held that the district court properly found no reasonable possibility that the jury’s verdict was affected by the foreperson’s outside research and that Musselman had waived a further evidentiary hearing. The appellate court also concluded that the evidence supported the ostrich instruction, given Musselman’s repeated disregard of obvious red flags and her heightened duty to inquire about her practice’s billing practices. View "USA v. Musselman" on Justia Law

Central States SE & SW Areas Health & Welfare Fund v. McClain

2026-08-26T10:00:07-08:00

A self-funded, multiemployer health and welfare fund that provides benefits nationwide challenged an Arkansas regulation, Rule 128, which applies to health plans operating in that state. The regulation has two main features: it authorizes the Arkansas Insurance Commissioner to require health plans to pay additional dispensing fees to pharmacies if existing payments are deemed not “fair and reasonable,” and it requires health plans to report certain compensation-related information. The fund, which covers participants in Arkansas, argued that the Employee Retirement Income Security Act of 1974 (ERISA) preempts both aspects of Rule 128 because they interfere with uniform plan administration and reporting requirements set by federal law. The United States District Court for the Northern District of Illinois, Eastern Division, heard the fund’s claims and granted the Insurance Commissioner’s motion to dismiss. The court held that the Dispensing Fee Requirement regulated only the cost of benefits and did not dictate substantive plan choices, relying on the Supreme Court’s decision in Rutledge v. Pharmaceutical Care Management Association. The court also found that the Reporting Requirement was merely incidental to enforcing cost regulation and did not constitute an impermissible intrusion into plan administration under ERISA, as discussed in Gobeille v. Liberty Mutual Insurance Company. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s dismissal de novo. The Seventh Circuit affirmed the dismissal, holding that ERISA does not preempt Rule 128’s Dispensing Fee Requirement because it is a permissible cost regulation and does not force plans to adopt a specific benefit structure. The court also concluded that the Reporting Requirement is incidental and necessary to enforce the cost regulation, and thus does not impermissibly intrude upon ERISA’s uniform reporting scheme. View "Central States SE & SW Areas Health & Welfare Fund v. McClain" on Justia Law

USA v Anderegg

2026-08-25T12:00:11-08:00

The defendant was charged with producing, distributing, and possessing AI-generated images that depicted minors engaged in sexually explicit conduct, as well as transferring such material to a minor. The images were alleged to be created using Stable Diffusion, a text-to-image generative AI program, and did not involve real children. Law enforcement linked the defendant to these images after a report by Meta Platforms, which found the material sent to a minor on Instagram. A search of the defendant’s devices revealed hundreds of similar AI-generated images. In the United States District Court for the Western District of Wisconsin, the defendant moved to dismiss the count charging him with knowing possession of obscene virtual child sexual abuse material (CSAM) in violation of 18 U.S.C. § 1466A(b)(1). The district court granted the motion as to the possession charge, concluding that the statute was unconstitutional as applied in this context. The court reasoned that, under Stanley v. Georgia, individuals have a First Amendment right to possess obscenity in their homes, and that this right extends to virtual CSAM, especially in light of the Supreme Court’s decision in Ashcroft v. Free Speech Coalition, which distinguished virtual CSAM from material involving actual children. The court left the production and distribution charges intact. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s dismissal de novo. The Seventh Circuit held that Supreme Court precedent—specifically Stanley v. Georgia and Ashcroft v. Free Speech Coalition—controls the as-applied challenge. The court found that, because the images did not depict real children, the government’s justifications for banning their possession in the home had been expressly rejected by the Supreme Court. Accordingly, the Seventh Circuit affirmed the district court’s judgment, holding that 18 U.S.C. § 1466A(b)(1) is unconstitutional as applied to the defendant’s in-home possession of obscene virtual CSAM. View "USA v Anderegg" on Justia Law

Highbaugh v Exelead, Inc.

2026-08-24T06:31:15-08:00

Richard Highbaugh, a Black man aged 60, worked for Exelead, Inc., a pharmaceutical manufacturer, for nearly three decades in various warehouse roles. In 2022, after a vacancy arose for a Materials Manager position, Highbaugh, who had experience as a supervisor and as a Sampling Specialist, expressed interest in the promotion. However, he did not apply during the internal posting period, instead submitting his materials to his supervisor, Aaron Mendez, about two months after the internal posting closed. Mendez ultimately hired an external candidate, a white man in his thirties, citing the external candidate’s experience with larger scale management and skills relevant to the position. Highbaugh believed he was passed over due to his race and age and filed charges with the EEOC before bringing suit. The United States District Court for the Southern District of Indiana granted summary judgment to Exelead. The district court concluded that Highbaugh failed to raise a genuine issue of material fact that Exelead’s stated reason for not promoting him—concerns about his qualifications and suitability for the manager role—was a pretext for discrimination. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the grant of summary judgment de novo and affirmed the lower court’s decision. The Seventh Circuit held that, even assuming Highbaugh established a prima facie case of discrimination under Title VII, § 1981, and the ADEA, Exelead provided a legitimate, non-discriminatory reason for its decision, and Highbaugh did not produce evidence sufficient for a reasonable jury to find this reason was pretextual. The court found no evidence of shifting or inconsistent explanations, nor that Highbaugh was so much better qualified that discrimination could be inferred. Accordingly, the judgment for Exelead was affirmed. View "Highbaugh v Exelead, Inc." on Justia Law

USA v. Braun

2026-08-20T11:01:16-08:00

In September 2020, Microsoft and Google each reported to the National Center for Missing and Exploited Children (NCMEC) that images suspected to be child sexual abuse material (CSAM) were uploaded from the same IP address to their platforms. The images were not viewed by the companies or by NCMEC; instead, they were flagged by automated systems after matching hash values of known CSAM. NCMEC forwarded these reports to the Wisconsin Department of Justice, which traced the IP address to Peter Braun's residence. Special Agent Aaron Koehler viewed the images without a warrant, conducted surveillance, and obtained a prior report from 2015 indicating Braun had been observed chatting online with very young girls. Based on this information, Koehler applied for and obtained a state search warrant for Braun’s home, leading to charges of producing CSAM. The United States District Court for the Eastern District of Wisconsin, after referral to a magistrate judge, granted Braun’s motion to suppress the evidence from the search. The district court found that Agent Koehler’s warrantless viewing of the images was unlawful, and that, excluding his descriptions of the images, the warrant affidavit did not establish probable cause. The court also determined that the good-faith exception to the exclusionary rule did not apply. The government appealed this decision. The United States Court of Appeals for the Seventh Circuit reviewed the case, applying de novo review to legal conclusions and clear error review to factual findings. The Seventh Circuit held that, even without the descriptions of the images obtained from the unlawful search, Agent Koehler’s affidavit contained sufficient information—such as the reliability of the reporting sources, the incriminating file name, and corroborating evidence regarding Braun’s prior behavior—to establish probable cause for the search. The court concluded that the decision to seek the warrant was not prompted by the unlawfully obtained information. Accordingly, the Seventh Circuit reversed the district court’s order suppressing the evidence. View "USA v. Braun" on Justia Law

Merchants Bank of Indiana v. Craik

2026-08-19T12:30:57-08:00

Merchants Bank of Indiana lent substantial amounts to two entities for the purchase of assisted living facilities in Arkansas and Tennessee. The loans were secured by mortgages on the properties as well as personal guaranties executed by three individuals. When the borrowers defaulted on the loans, Merchants initiated federal lawsuits against the guarantors to collect the outstanding debts and, after dismissing the borrowers from those suits, later began foreclosure actions on the mortgaged properties in state courts. Receivers were appointed for the properties, but Merchants had not recovered the loan amounts. After Merchants moved for summary judgment in the United States District Court for the Southern District of Indiana, the guarantors argued that Indiana’s “One Action” statute (Indiana Code § 32-30-10-10) barred simultaneous suits on the guaranties and foreclosures. The district court, acting on its own, granted summary judgment to the guarantors, finding that the statute applied to guaranties and rendered the waivers in the guaranty contracts unenforceable as contrary to Indiana public policy. On appeal, the United States Court of Appeals for the Seventh Circuit found that the scope of Indiana’s One Action statute and the enforceability of waivers in this context were unsettled under Indiana law. Recognizing the ambiguity and the lack of controlling precedent, the Seventh Circuit certified two questions to the Indiana Supreme Court: whether the statute prohibits a lender from foreclosing while simultaneously suing on guaranties in separate proceedings, and, if so, whether such protections may be waived by guarantors. The Seventh Circuit stayed further proceedings in the case pending the Indiana Supreme Court’s response. View "Merchants Bank of Indiana v. Craik" on Justia Law

Smith v. Price

2026-08-19T12:00:55-08:00

An inmate incarcerated at an Indiana prison was twice transported by correctional officers between the facility and a hospital in June 2019. During the first transport, after a medical appointment, the inmate was placed in a van in restraining gear that prevented him from buckling his seatbelt, and the officers refused to buckle it for him. One of the officers then drove the van in a manner the inmate described as reckless, resulting in a sudden stop that threw the inmate to the floor and caused a broken collarbone. The inmate alleged the officers made threatening remarks referencing his prior grievances against staff and later colluded to create consistent incident reports. On the second transport, after surgery, the inmate was buckled in but not placed in the more secure area he requested. Officers drove in a way that jostled his recent injuries, deliberately drove over rough terrain and railroad tracks, and laughed in response to his pain. The United States District Court for the Southern District of Indiana allowed the inmate’s Eighth Amendment claims against three officers to proceed, along with First Amendment retaliation claims. At summary judgment, the district court granted qualified immunity to all three officers on the Eighth Amendment claims, finding that the law was not clearly established for the conduct alleged, and entered judgment for the officers. The court analyzed the claims under both deliberate indifference and excessive force standards, depending on the officer’s role and the facts alleged. On appeal, the United States Court of Appeals for the Seventh Circuit affirmed in part and vacated in part. The court held that the officer who failed to buckle the inmate’s seatbelt and did not intervene during reckless driving on the first transport was not entitled to qualified immunity, as it was clearly established that subjecting a restrained inmate to reckless driving without a seatbelt posed a substantial risk of serious harm. However, the court affirmed summary judgment for the officers involved in the second transport, finding the law was not clearly established that their conduct—though troubling—violated the Eighth Amendment under the specific facts presented. The case against the first officer was remanded for further proceedings. View "Smith v. Price" on Justia Law

Public Interest Legal Foundation, Inc. v. Wolfe

2026-08-19T11:00:56-08:00

A nonprofit organization dedicated to election integrity requested a copy of Wisconsin’s voter registration list, seeking access under the National Voter Registration Act (NVRA). Wisconsin, however, is exempt from the NVRA because it has permitted same-day polling-place registration since before August 1, 1994. The state processed the request under its public-records law, which required redaction of birth dates and imposed a fee of $12,500 due to the size of the list. The organization objected to both the fee and the redactions, arguing that Wisconsin’s exemption from the NVRA was unconstitutional. The United States District Court for the Western District of Wisconsin dismissed the case. The district judge held that the plaintiff’s claims—asserting violations of the “equal state sovereignty” principle from Shelby County v. Holder and the “congruence and proportionality” requirement from City of Boerne v. Flores—were not supported by law. While the judge found that the plaintiff had Article III standing due to the alleged financial injury, he expressed doubt about prudential standing but decided the case on the merits, concluding that neither cited Supreme Court decision undermined the validity of Wisconsin’s exemption. The United States Court of Appeals for the Seventh Circuit reviewed the dismissal de novo. The court agreed that the plaintiff had Article III standing but questioned prudential standing, as the legal theories invoked state, rather than individual, rights. Nonetheless, the court bypassed this issue, holding that the NVRA’s exemption for states like Wisconsin does not violate equal state sovereignty or the congruence and proportionality standard. The court emphasized that the exemption relieves, rather than imposes, federal regulatory burdens and that Congress acted under its Elections Clause authority, making City of Boerne inapplicable. The Seventh Circuit affirmed the district court’s dismissal. View "Public Interest Legal Foundation, Inc. v. Wolfe" on Justia Law

Village of Schaumburg v Permasteelisa North America

2026-08-18T12:30:47-08:00

The Village of Schaumburg owns a hotel and convention center that it alleges has defective exterior walls. In February 2022, it initiated a lawsuit in the United States District Court for the Northern District of Illinois, Eastern Division, against several parties for fraud, breach of warranty, and products liability. In November 2022, the Village added Permasteelisa North America, a subcontractor, as a defendant. About eight months later, the Village sought to compel arbitration of its dispute with Permasteelisa, even though it had not previously requested arbitration in its complaint or before filing suit, and the arbitration clause was contained in a contract between Permasteelisa and the general contractor, not the Village directly. The District Court concluded that by filing a lawsuit and then delaying its request for arbitration, the Village presumptively waived any right to arbitrate it might have had. The Village argued that the lawsuit was filed to avoid the statute of limitations expiring, but the District Court responded that the Village should have requested arbitration at the outset or, at the latest, soon after Permasteelisa’s motion to dismiss was filed. The court found that the combination of filing suit and substantial delay amounted to waiver of any right to arbitrate and denied the Village’s motion to compel arbitration. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the District Court’s decision for abuse of discretion. The appellate court held that the District Court did not err in concluding that the Village waived any right to arbitrate by acting inconsistently with that right through both initiating litigation and delaying the arbitration request. The Seventh Circuit also rejected the argument that a contractual anti-waiver clause could override federal procedural rules governing litigation conduct. The judgment of the District Court was affirmed. View "Village of Schaumburg v Permasteelisa North America" on Justia Law

Moore v Club Exploria, LLC

2026-08-18T12:30:47-08:00

The plaintiff received two pre-recorded telemarketing calls from a vacation property company, which he alleged were made without his consent in violation of the Telephone Consumer Protection Act. The company had used third-party vendors to conduct a large-scale telemarketing campaign, targeting individuals whose phone numbers had been obtained from opt-in websites. The plaintiff, on behalf of himself and a proposed class, filed suit against the company in April 2019, asserting that these calls violated federal law. In the United States District Court for the Northern District of Illinois, the defendant engaged in extensive litigation over the course of four years. It filed answers with affirmative defenses, participated in class-related discovery, and litigated several motions, including opposing class certification and filing for summary judgment. Notably, the defendant did not assert arbitration as a defense until after the class was certified and significant litigation had occurred. When it finally raised arbitration—claiming that many class members had agreed to arbitrate through opt-in websites—the district court refused to allow the late amendment to add this defense, finding that it was too late and that the right to arbitrate had been waived. The district court later denied the defendant’s motion to compel arbitration, granted summary judgment to the plaintiff and the class, and ordered further settlement negotiations. Upon appeal, the United States Court of Appeals for the Seventh Circuit clarified the appropriate standard of review for orders denying motions to compel arbitration, holding that legal rulings with precedential effect are reviewed de novo, while the ultimate waiver determination is reviewed for clear error. The court further held that a defendant’s conduct prior to class certification is relevant in assessing waiver of the right to arbitrate. Finding no clear error in the district court’s conclusion that the defendant waived its arbitration rights by failing to timely assert them, the Seventh Circuit affirmed the judgment. View "Moore v Club Exploria, LLC" on Justia Law

Burns v Polk

2026-08-18T10:00:55-08:00

A pretrial detainee housed in the Milwaukee County Jail alleged that, during a medical emergency involving COVID-19 symptoms, two correctional officers failed to provide adequate medical attention. He claimed that despite using his in-cell intercom to request help for chest pain and shortness of breath, the officers did not respond. Later, a nurse administered a COVID-19 test, but the detainee was never informed of the results, and his condition worsened until he eventually passed out and was hospitalized. After recovering, the detainee followed the jail’s grievance procedure by submitting a grievance through the electronic kiosk, updating it as his symptoms persisted, and eventually receiving a response from jail staff that closed the grievance. He did not appeal the grievance. The detainee later filed a lawsuit under 42 U.S.C. § 1983 in the United States District Court for the Eastern District of Wisconsin, alleging violations of his Fourteenth Amendment rights. Before discovery, the defendants moved for summary judgment, arguing that the detainee failed to exhaust his administrative remedies as required by the Prison Litigation Reform Act (PLRA). The district court granted summary judgment for the defendants, concluding that the detainee did not appeal his grievance and that the remedies were available to him, dismissing his assertion that the process was unavailable. Reviewing the appeal, the United States Court of Appeals for the Seventh Circuit held that a genuine dispute of material fact existed as to whether the jail’s grievance appeals process was actually available to the plaintiff. The Seventh Circuit vacated the district court’s summary judgment, finding that the detainee’s sworn declaration provided sufficient evidence to require further fact-finding, either through an evidentiary hearing or a jury trial if the exhaustion issue is intertwined with the merits. The case was remanded for further proceedings. View "Burns v Polk" on Justia Law

Planned Parenthood Great Northwest, Hawai'i v Commissioner of the Indiana State Department

2026-08-18T09:01:24-08:00

In 2017, Indiana enacted a statute known as the “aid-or-assist” law, which prohibits any person from knowingly or intentionally assisting an unemancipated pregnant minor in obtaining an abortion without fulfilling the state’s parental consent and notice requirements. Planned Parenthood, a nonprofit operating health centers in Indiana, regularly provides minors with factually accurate information and referrals about lawful abortion services in neighboring states, particularly after Indiana enacted more restrictive abortion laws following Dobbs v. Jackson Women’s Health Organization. Both parties agreed that, without adherence to Indiana’s parental consent law, providing such information would violate the aid-or-assist statute, exposing Planned Parenthood and its physicians to civil liability and professional discipline. After the law’s passage, Planned Parenthood filed suit in the United States District Court for the Southern District of Indiana, challenging the statute under the First Amendment as applied to its provision of information and referrals to minors about lawful out-of-state abortion services. The district court initially granted a preliminary injunction, and after changes in federal and state abortion law, ultimately issued a permanent injunction preventing enforcement of the aid-or-assist law as applied to Planned Parenthood’s speech and referrals about legal abortion practices in other states. The district court reasoned that the statute was a content-based restriction on protected speech and failed strict scrutiny. The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the permanent injunction, with one modification: it removed the Commissioner of Health as a defendant because the Commissioner no longer had authority to provide relief. The Seventh Circuit held that Planned Parenthood’s provision of information and referrals about legal out-of-state abortion services was protected speech under the First Amendment. The court found that Indiana’s law, as applied, was a content- and viewpoint-based restriction that failed strict scrutiny, as it was not narrowly tailored to serve compelling state interests. The injunction was affirmed as modified. View "Planned Parenthood Great Northwest, Hawai'i v Commissioner of the Indiana State Department" on Justia Law

Soloway v ALM Global, LLC

2026-08-18T08:00:54-08:00

After serving as general counsel for a prominent commercial real estate firm, an attorney oversaw the company’s legal response to subpoenas in highly publicized litigation involving the Trump Organization. The company was held in contempt of court by a judge for delayed compliance with the subpoenas, but a subsequent judge extended the deadline and purged the contempt without imposing fines. The attorney resigned from the company on friendly terms, and shortly thereafter, a media outlet published an article suggesting the company had replaced its general counsel “in the wake of” the court’s rebuke in the Trump probe. Most of the article was behind a paywall, but the publicly available sections included the headline, byline, bullet points, and two paragraphs noting the sequence of events but not explicitly linking the attorney’s departure to the contempt proceedings. The attorney filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, alleging defamation per se and defamation per quod under Illinois law. The district court dismissed the defamation per se claim with prejudice, holding the article was subject to a reasonable innocent construction and thus not actionable. The defamation per quod claim was dismissed without prejudice because the complaint did not sufficiently plead special damages. The attorney did not amend his complaint and appealed. The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The court held that, under Illinois’s innocent construction rule, the article was reasonably susceptible to an innocent interpretation and therefore not actionable as defamation per se. The court further held that the defamation per quod claim failed because special damages were not pleaded with the specificity required under federal rules. The judgment of the district court was affirmed. View "Soloway v ALM Global, LLC" on Justia Law

USA v. Krejza

2026-08-18T06:30:46-08:00

A federally insured bank in Chicago, Washington Federal Bank for Savings, was involved in a multi-year scheme orchestrated by its president and senior officials to benefit a select group of borrowers, including the defendant. These borrowers received millions in commercial real estate loans that were poorly secured, improperly documented, and concealed from regulators. Over time, the true poor condition of these loans was hidden through manipulated records and false documentation. When regulators from the Office of the Comptroller of the Currency eventually discovered the scheme, the bank collapsed, resulting in significant losses for the Federal Deposit Insurance Corporation. The defendant, who was among the favored borrowers, submitted false information to the FDIC after the bank’s failure. A grand jury indicted the defendant on conspiracy and aiding and abetting embezzlement, alleging his involvement in the scheme from 2004 to 2018. The United States District Court for the Northern District of Illinois, Eastern Division, presided over a ten-day trial, during which the defendant raised several evidentiary challenges and argued that the evidence only showed imprudent lending, not criminal conduct. The jury convicted him on both counts. The district court subsequently denied his post-trial motions for acquittal and a new trial, finding the evidence sufficient and its evidentiary rulings proper. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the defendant’s claims regarding variance or constructive amendment, sufficiency of the evidence, and evidentiary rulings. The court found no fatal variance or constructive amendment, concluded that sufficient evidence supported the convictions for conspiracy and aiding and abetting embezzlement, and held that the district court did not abuse its discretion in its evidentiary decisions. The appellate court affirmed the judgment of the district court. View "USA v. Krejza" on Justia Law

Enloe v Heritage Operations Group, LLC

2026-08-17T13:00:48-08:00

Heritage Operations Group operates long-term care facilities in Illinois, with Green Tree Pharmacy providing pharmacy services to these facilities. Both companies are family-owned and operated. A. Samuel Enloe, who has extensive experience in the long-term care pharmacy industry, alleged that Heritage and Green Tree dispensed Schedule II controlled substances to residents without valid prescriptions, particularly during emergencies when the pharmacy was closed. Enloe claimed that this practice violated the Controlled Substances Act (CSA) and that subsequent claims for Medicare reimbursement were fraudulent under the False Claims Act (FCA). The United States District Court for the Northern District of Illinois, Eastern Division, dismissed Enloe’s second amended complaint. The court concluded that Enloe failed to plead his FCA claims with the particularity required by Federal Rule of Civil Procedure 9(b), specifically not identifying the “who, what, when, where, and how” of the alleged fraud. It also found that the CSA does not provide a private cause of action and, as a result, dismissed the related unjust enrichment claim. Enloe appealed, challenging only the dismissal of his FCA claims. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s dismissal de novo. The appellate court held that Enloe’s allegations were speculative and lacked the concrete factual detail required under Rule 9(b). The court found that Enloe did not sufficiently allege either a clear violation of the CSA or that any misrepresentation was material to the government’s payment decision. Thus, the Seventh Circuit concluded that Enloe failed to state a claim under the FCA and affirmed the district court’s judgment dismissing his complaint. View "Enloe v Heritage Operations Group, LLC" on Justia Law

Fields v. USA

2026-08-17T08:30:55-08:00

Derek Fields was involved in a violent kidnapping in September 2015, during which he and his co-defendants abducted Adrian Harris, inflicted physical harm, and demanded ransom. Fields was arrested within days alongside his co-defendants and indicted on several charges, including kidnapping, making a ransom demand, and firearm offenses. The government extended multiple plea offers, each carrying substantial prison time, but Fields consistently rejected them, viewing sentences over twenty years as tantamount to a life sentence. After his motion to suppress evidence was denied, Fields proceeded to trial, was convicted on all counts, and originally sentenced to 53 years. On appeal, his conviction under one firearm statute was vacated pursuant to United States v. Davis, 588 U.S. 445 (2019), and he was resentenced to 43 years. After his conviction became final, Fields filed a motion under 28 U.S.C. § 2255 in the United States District Court for the Northern District of Indiana, arguing that his last counsel was constitutionally ineffective for failing to adequately advise him about an alleged 37-year plea offer presented during jury selection. The district court denied the motion without an evidentiary hearing, focusing primarily on a different plea agreement attached to Fields’s reply brief, and concluded that Fields failed to show prejudice because he did not establish a reasonable probability he would have accepted the offer and received a lower sentence. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s denial de novo for legal questions and for abuse of discretion regarding the lack of an evidentiary hearing. The Seventh Circuit assumed, for argument’s sake, that the alleged 37-year plea offer existed and that counsel’s advice was inadequate, but found that Fields did not demonstrate a reasonable probability he would have accepted the plea or received a lower sentence. The court therefore affirmed the district court’s denial of Fields’s § 2255 motion without an evidentiary hearing. View "Fields v. USA" on Justia Law

Savory v Andrews

2026-08-14T14:30:48-08:00

In 1977, a 14-year-old was questioned by police in Peoria, Illinois, about the murder of two teenagers. Over roughly two days, police and a polygraph examiner interrogated him, at times using harsh tactics. He eventually confessed and was convicted of first-degree murder. The state appellate court later overturned the conviction, finding the confession involuntary. He was retried, convicted again, and served decades in prison before being released on parole in 2006. In 2014, he was pardoned by the governor. Years later, he filed a civil suit under 42 U.S.C. § 1983 against 16 former police officers, the City of Peoria, and the polygrapher, alleging unlawful detention, coercion of his confession, and destruction and fabrication of evidence. The United States District Court for the Central District of Illinois denied summary judgment to the defendants, concluding that material factual disputes precluded resolution of the unlawful detention claim, that clearly established law would have put the officers and the polygrapher on notice their interrogation tactics were unconstitutional, and that a reasonable jury could find evidence destruction and fabrication in violation of established law. On appeal, the United States Court of Appeals for the Seventh Circuit reversed. The court held the officers were entitled to qualified immunity for the unlawful detention claim, finding they had arguable probable cause based on the totality of the circumstances. The court also found no evidence the officers destroyed evidence in bad faith or at a time when its exculpatory value was apparent, and held there was no clearly established law making their actions unconstitutional at the relevant times. Additionally, the court concluded that the coercion claim failed because no then-existing precedent put the unconstitutionality of the officers’ interrogation methods “beyond debate.” Finally, the court held the officers were entitled to absolute immunity for testimony at trial, even if it was consistent with allegedly fabricated evidence not introduced at trial. Accordingly, the district court’s denial of immunity was reversed. View "Savory v Andrews" on Justia Law

Kaiser v Alcoa USA Corp.

2026-08-14T13:00:55-08:00

An aluminum company had, through various collective bargaining agreements (CBAs), promised certain healthcare benefits to retirees, their spouses, and dependents. The agreements did not specify the duration of these benefits, but the company had been providing lifetime healthcare coverage to individuals who retired before June 1, 1993. In August 2020, the company announced it would transition these pre-1993 retirees to a new health reimbursement arrangement starting January 1, 2021, under which the company reserved the right to terminate benefits at any time. Over 3,000 affected individuals, including the widow of a former employee, challenged this change, alleging that it breached the CBAs and violated federal labor and benefits laws. The United States District Court for the Southern District of Indiana certified a class of affected retirees and their eligible spouses and dependents. After discovery, the court granted summary judgment as to liability in favor of the plaintiffs, relying on judicial estoppel. The court found that the company was barred from arguing that benefits were not vested for life because it had previously taken the opposite position in earlier litigation. As a result, the district court declared that class members were entitled to lifetime healthcare benefits and issued a permanent injunction requiring reinstatement of the prior plan and allowing claims for expenses incurred since January 1, 2021. The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s certification of the class under Rule 23(b)(2), finding no abuse of discretion. However, it reversed the grant of summary judgment as to liability. The appellate court concluded that judicial estoppel did not apply because the company’s prior statements in earlier litigation were not clearly inconsistent with its current position. The case was remanded for further proceedings on the merits. View "Kaiser v Alcoa USA Corp." on Justia Law

Herrera v USA

2026-08-14T12:00:48-08:00

Irma Herrera alleged that her obstetricians committed medical malpractice during her childbirth at a federally funded community health clinic in Chicago, resulting in serious injuries. Because the clinic receives federal funding, her legal remedy was limited to an action against the United States under the Federal Tort Claims Act. After initially filing suit in state court, the Attorney General certified that the doctors were acting within the scope of their federal employment, leading to removal of the case to federal court. The United States District Court for the Northern District of Illinois dismissed Herrera’s case because she had failed to exhaust her administrative remedies as required under 28 U.S.C. § 2401(b). In an attempt to preserve her claim, Herrera complied with the saving provision in the Westfall Act and refiled her case in federal court. However, the district court again dismissed her suit, relying on the Seventh Circuit’s precedent in Evans v. United States, which had held that the Westfall Act’s saving provision does not apply to medical malpractice cases removed under 42 U.S.C. § 233(c). On appeal, the United States Court of Appeals for the Seventh Circuit considered whether to overturn its holding in Evans in light of Herrera’s arguments that Evans was wrongly decided. The court declined to do so, emphasizing the importance of stare decisis and finding no compelling reason to depart from its recent precedent. The Seventh Circuit affirmed the district court’s dismissal, holding that the Westfall Act’s saving provision does not apply to medical malpractice cases removed under 42 U.S.C. § 233(c), thereby precluding Herrera’s claim. View "Herrera v USA" on Justia Law

Hunter v Elanco Animal Health Incorporated

2026-08-14T06:30:47-08:00

The plaintiffs, who purchased securities issued by an animal health company, brought a proposed class action against the company and certain officers and directors. They alleged that the company misled investors by publicly attributing its sales growth to strong end-user demand, when in reality, the growth was artificially created through “channel stuffing”—the practice of pushing excessive inventory onto distributors, thus inflating reported revenues. The company’s alleged conduct took place around the time of major acquisitions and included public statements and SEC filings that, according to the plaintiffs, failed to disclose the channel stuffing and misrepresented the true basis for revenue increases. The United States District Court for the Southern District of Indiana reviewed the plaintiffs’ first amended complaint and dismissed it without prejudice for failure to state a claim, allowing an opportunity to amend. The plaintiffs sought to file a second amended complaint, asserting claims under the Securities Exchange Act of 1934 and the Securities Act of 1933, as well as related “control person” liability provisions. The district court denied leave to amend, deeming further amendment futile, and dismissed the case with prejudice. The court concluded the plaintiffs had not adequately alleged actionable misstatements, scienter (intent to defraud), or loss causation under the heightened pleading standards required by the Private Securities Litigation Reform Act and Federal Rule of Civil Procedure 9(b). On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The appellate court held that, even assuming the statements at issue could be considered materially misleading, the plaintiffs failed to allege facts giving rise to a strong inference of scienter. The court also agreed that the claims under the Securities Act sounded in fraud and therefore required particularized pleading, which the plaintiffs had not met. Consequently, all claims were properly dismissed with prejudice. View "Hunter v Elanco Animal Health Incorporated" on Justia Law

Kelley-Lomax v City of Chicago

2026-08-13T13:00:57-08:00

A 911 caller reported that several African American men were pointing guns at his vehicle at a gas station. Responding officers arrived to find a blue SUV with four African American males at an adjacent pump. The plaintiff was seated in the front passenger seat. After detaining and handcuffing all occupants, officers searched the SUV and found a loaded handgun under the seat the plaintiff had occupied. The plaintiff admitted he did not have a license to carry a firearm. The officers arrested him for aggravated unlawful use of a weapon under Illinois law. Later, during the investigation, it was learned that the plaintiff’s brother, who was not present in the SUV but had rented it, had authorization to carry a gun. The Cook County State Attorney’s Office charged the plaintiff, and a grand jury indicted him after hearing testimony from one of the arresting officers. At trial in Illinois state court, the only witness was the arresting officer, and after the state rested its case, the judge granted a directed verdict in favor of the plaintiff, finding insufficient evidence that the plaintiff knew the gun was present. The plaintiff then sued the officers in the United States District Court for the Northern District of Illinois, alleging false arrest and malicious prosecution under 42 U.S.C. § 1983. The district court granted summary judgment to the officers, holding that probable cause existed for both the arrest and prosecution. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s grant of summary judgment de novo. The court held that the officers had probable cause to arrest the plaintiff based on his proximity to the gun and lack of a license, and that the same facts supported probable cause to prosecute. The court also found that, even when excluding allegedly fabricated information, probable cause remained. The judgment of the district court was affirmed. View "Kelley-Lomax v City of Chicago" on Justia Law

USA v Oke

2026-08-13T12:30:49-08:00

Three women orchestrated a scheme in 2014 to bring two girls, aged 11 and 14, from Benin to the United States under false pretenses. The girls’ families were promised that the children would attend school and have the opportunity to earn money. The women obtained fraudulent identification and travel documents, creating a fabricated story for immigration authorities. Once in Illinois, the girls were subjected to forced labor in the women’s homes, denied education and medical care, and suffered physical and psychological abuse. Over the course of several years, both girls managed to escape and later cooperated with authorities. A federal grand jury in the Northern District of Illinois indicted the women on charges of conspiracy to harbor and shield unauthorized aliens, actual harboring and shielding, and forced labor. After an initial mistrial, a retrial was held where the government presented extensive testimony from the victims and corroborating witnesses. The defense challenged the credibility of the victims, arguing inconsistencies in their accounts and motives related to immigration benefits. The jury nevertheless convicted all three defendants on all counts, and found that two had committed their offenses for financial gain, warranting enhanced sentences. The district court denied post-trial motions for acquittal or a new trial, emphasizing that credibility determinations were for the jury. The United States Court of Appeals for the Seventh Circuit reviewed the sufficiency of the evidence and the reasonableness of the sentences imposed. It held that the evidence, including the victims’ testimonies and corroborating documentation, was sufficient for a rational jury to convict on the harboring and forced labor charges. The court also found that the sentences, which were within or below the applicable guideline range, were reasonable. The Seventh Circuit affirmed the district court’s judgment in its entirety. View "USA v Oke" on Justia Law

USA v Hinz

2026-08-13T12:30:47-08:00

After being convicted of distributing methamphetamine, Jerid Hinz was sentenced to 18 months in prison and five years of supervised release. Following his release, Hinz repeatedly violated conditions of his supervision, including using methamphetamine, failing to report for drug testing, and not maintaining lawful employment. He was twice found to have violated his supervised release. The second revocation stemmed from new violations in late 2024 and early 2025, including multiple positive drug tests and an attempt to use fake urine. Hinz was also arrested in February 2025 after an incident involving a shooting, but those charges were ultimately dismissed and read in at sentencing for an earlier state case. The United States District Court for the Western District of Wisconsin revoked Hinz’s supervised release and imposed a 24-month prison sentence, the statutory maximum, with no additional supervised release to follow. At the revocation hearing, the court clarified that it was not considering unproven allegations about gun possession or the shooting incident, and instead based its decision on the violations Hinz admitted. However, in its written order, the court also imposed a condition requiring Hinz to register with local law enforcement and the state attorney general before release. The United States Court of Appeals for the Seventh Circuit reviewed Hinz’s appeal. The court held that the district court did not rely on inaccurate or unproven allegations in sentencing Hinz. However, it found that the district court exceeded its authority by imposing a registration requirement effective after Hinz’s prison term, since there was no supervised release to follow. The appellate court struck the registration requirement from the judgment and, as modified, affirmed the judgment. View "USA v Hinz" on Justia Law

McDonald v Trustees of Indiana University

2026-08-13T11:30:50-08:00

Four professors employed by Indiana’s public universities brought a facial constitutional challenge against a new state law, which mandates that university boards adopt and enforce policies promoting “free inquiry, free expression, and intellectual diversity.” The law conditions tenure and promotion decisions, as well as periodic reviews of tenured faculty, on compliance with these principles. The professors argued that these requirements, and related university policies, compelled them to alter their teaching and course materials, thereby chilling their First Amendment rights. They described changes they made to their syllabi and teaching practices out of concern for violating the law or university policies, but none had faced discipline or explicit threats as a result. Previously, the United States District Court for the Southern District of Indiana dismissed the professors’ initial suit for lack of standing, finding no credible threat of enforcement since the law regulated university boards rather than faculty directly. After the universities adopted “interim” policies to implement the law, the professors sued again, targeting both the statute and these new policies. The district court again dismissed the case, reasoning that the professors’ fears of enforcement were speculative because the policies were not final and no actions had been taken against them under the new regime. On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal for lack of subject-matter jurisdiction. The Seventh Circuit held that the professors failed to establish Article III standing, as they did not demonstrate a credible threat that the law or university policies would actually be enforced against them, nor an objectively reasonable chilling effect on their speech. The court emphasized that neither the indirect application of the law nor the interim status of the policies categorically precluded standing, but found that the record did not support a sufficient injury-in-fact to proceed. View "McDonald v Trustees of Indiana University" on Justia Law

Kim v Jump Trading, LLC

2026-08-13T11:01:10-08:00

The case centers on a group of plaintiffs who brought a lawsuit claiming that their employer's timekeeping system, which rounded employees’ clock-in and clock-out times to the nearest quarter-hour, resulted in underpayment of wages. The plaintiffs argued that this rounding practice systematically favored the employer and thus violated the Fair Labor Standards Act (FLSA). The employer maintained that its rounding policy was neutral and consistent with federal regulations, and that over time, the rounding did not systematically disadvantage employees. In the United States District Court for the Northern District of Illinois, the employer moved for summary judgment, contending that the evidence showed the rounding practice was neutral both on its face and in practice. The district court agreed, finding that the employer’s rounding system complied with the FLSA’s regulations, which permit rounding as long as it does not consistently favor the employer. The court concluded there was no genuine dispute of material fact and granted summary judgment in favor of the employer. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the case. The appellate court affirmed the district court’s decision, holding that the employer’s rounding policy was permissible under the FLSA, provided it was facially neutral and did not systematically undercompensate employees over time. The Seventh Circuit clarified that, although individual pay periods might see some employees gain or lose time, the system as a whole did not violate federal law when considered in the aggregate. The court’s holding confirms that time-rounding practices consistent with federal guidance, and that do not result in systematic underpayment, are lawful under the FLSA. View "Kim v Jump Trading, LLC" on Justia Law

Sunco International Inc. v Jiangsu Sunco Boiler Co., Ltd.

2026-08-13T11:01:09-08:00

The case involves a criminal defendant who was convicted on federal charges after law enforcement conducted a search of his home. The search was carried out pursuant to a warrant, and evidence seized during the search was used to support the prosecution’s case. The defendant challenged the lawfulness of the search, arguing that the affidavit supporting the warrant application contained misrepresentations or omissions that were material to the finding of probable cause. At trial in the United States District Court for the Northern District of Illinois, the defendant sought to suppress the evidence obtained during the search, contending that the warrant was not supported by probable cause due to false or misleading statements in the supporting affidavit. The district court denied the motion to suppress, finding that the affidavit provided a sufficient basis for probable cause and that any alleged inaccuracies were not material. The defendant was subsequently convicted, and he appealed, renewing his arguments regarding the validity of the search warrant. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s denial of the suppression motion. The appellate court held that in order to invalidate a search warrant under Franks v. Delaware, 438 U.S. 154 (1978), a defendant must show that the affidavit included deliberately or recklessly false statements, and that those statements were necessary to a finding of probable cause. The Seventh Circuit found that the defendant failed to make this showing. The court concluded that, even excising the challenged statements, the remaining contents of the affidavit were sufficient to establish probable cause. Therefore, the court affirmed the judgment of the district court, upholding the defendant’s conviction. View "Sunco International Inc. v Jiangsu Sunco Boiler Co., Ltd." on Justia Law

Putnam v Caramelcrisp, LLC

2026-08-13T10:30:58-08:00

Aisha Putnam was employed by CaramelCrisp, LLC, working in research and development and also managing quality assurance for the company’s food products. During her time there, she observed several food safety and quality control violations, which she repeatedly reported to company management. In early 2019, Putnam sent anonymous emails to the FDA regarding these concerns. Two weeks after her communication with the FDA, CaramelCrisp terminated her employment. Subsequent to her termination, CaramelCrisp discovered that Putnam had taken company documents and initiated a trade secrets lawsuit against her. While the trade secrets case was pending, Putnam filed suit in the United States District Court for the Northern District of Illinois, alleging she was discharged in retaliation for her food safety complaints, bringing claims under the Food Safety Modernization Act (FSMA) and Illinois common law. The district court dismissed her common law claim, holding that the existence of a statutory remedy under the FSMA precluded a separate common law action. The court granted summary judgment to CaramelCrisp on Putnam’s FSMA claim to the extent it was based on her FDA emails because there was no evidence CaramelCrisp knew about them. Her claim based on complaints to management proceeded to trial, where a jury found that her complaints were not a contributing factor in her termination. On appeal, the United States Court of Appeals for the Seventh Circuit dismissed Putnam’s trial-related challenges due to her failure to provide trial transcripts. The court affirmed the district court’s dismissal of the common law claim and its summary judgment ruling, holding that Putnam failed to show CaramelCrisp knew of her FDA emails and that the jury’s finding precluded success on any theory requiring proof that her complaints contributed to her termination. View "Putnam v Caramelcrisp, LLC" on Justia Law

Ferguson v Aon Risk Services Companies, Inc.

2026-08-13T09:31:38-08:00

A group of former shareholders of a reinsurance provider’s parent company acquired the provider’s rights to seek recourse against third parties for losses stemming from a failed reinsurance program. The losses occurred after the provider’s agent advised participation in a structurally unsound London Market program, resulting in significant financial harm. The shareholders, now plaintiffs, alleged that an insurance brokerage firm failed to properly notify the agent’s professional liability insurers of claims arising from these events, as required under agreements between the broker, the agent, and the insurers. After unsuccessful attempts to recover from the provider’s agent and its bankrupt parent company, the plaintiffs notified the agent’s insurers, who denied coverage due to untimely notice. The plaintiffs then filed suit against the brokerage firm in the Circuit Court of Cook County, Illinois, asserting claims for professional negligence and breach of contract. The suit was removed to the United States District Court for the Northern District of Illinois. The district court dismissed the negligence claim and granted summary judgment to the brokerage firm on the contract claim, finding the provider was not a third-party beneficiary to the relevant agreements and the broker owed no duty to the provider. The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s judgment. The court held that the provider was not a third-party beneficiary of the agreements between the broker and the agent, as the contracts did not expressly manifest an intent to benefit the provider. The court also held that the broker owed no professional duty to the provider to notify the agent’s insurers of claims. Finally, it concluded that the claims were time-barred under Illinois law. View "Ferguson v Aon Risk Services Companies, Inc." on Justia Law

Chapman v Burke

2026-08-13T07:00:47-08:00

Reginald Chapman was convicted by an Illinois state court jury of murdering Angela Butler and her son, C.B., in 1998. After his conviction, Chapman sought post-conviction DNA testing on evidence collected during the investigation that had not been tested or could be tested with new technology. He filed a motion under 725 Ill. Comp. Stat. 5/116-3, the Illinois statute governing post-conviction DNA testing. Although the county prosecutor’s office initially agreed to DNA testing, the state court rejected the agreement and dismissed Chapman’s motion, finding the evidence at trial was overwhelming and that further testing would not have altered the verdict. Chapman appealed, but the Illinois Appellate Court affirmed the dismissal, and the Illinois Supreme Court denied his request for review. Following the denial in state court, Chapman filed a suit in the United States District Court for the Northern District of Illinois against the Cook County State’s Attorney, Eileen O’Neill Burke. He challenged the constitutionality of the Illinois post-conviction DNA testing statute on its face under the Fourteenth Amendment’s Due Process Clause and the Sixth Amendment’s right to a jury trial. The district court dismissed the case for lack of subject matter jurisdiction, citing the Rooker-Feldman doctrine, which bars lower federal courts from reviewing state court judgments. On appeal, the United States Court of Appeals for the Seventh Circuit found that Chapman had standing to sue, as his injury was fairly traceable to Burke’s refusal to allow DNA testing. The court also held that the Rooker-Feldman doctrine did not bar Chapman’s federal claim because he was challenging the constitutionality of the statute itself, not seeking to overturn the state court judgment. Therefore, the Seventh Circuit reversed the district court’s dismissal and remanded the case for further proceedings. View "Chapman v Burke" on Justia Law

USA v. Betty

2026-08-12T13:00:48-08:00

A 27-year-old man used a dating app designed for teenagers to contact a 14-year-old girl. He misrepresented his age, communicated with her in sexually explicit ways, and persuaded her to send sexually explicit photos, including requests for specific acts. He later arranged to meet her in person, again misrepresenting his age, and engaged in sexual intercourse with her. Law enforcement intervened after the victim’s mother discovered the events. The man admitted to the conduct during investigation, and a federal grand jury indicted him on charges of sexual exploitation of a child, enticement of a minor, and receipt of child pornography. After his indictment in the United States District Court for the Central District of Illinois, the defendant pleaded guilty to all four counts. A presentence investigation report was prepared, which calculated a total offense level that resulted in a guidelines range of life imprisonment, despite the defendant having no prior criminal history. At sentencing, his counsel argued that the guidelines calculations resulted in impermissible “double counting” and an unfairly high range, but acknowledged that existing Seventh Circuit law supported the calculations. The district court accepted the plea, adopted the presentence report’s calculations, and imposed a sentence of 264 months’ imprisonment, well below the advisory range, citing the overall circumstances and mitigation arguments. The United States Court of Appeals for the Seventh Circuit reviewed the sentence. The court rejected all four of the defendant’s challenges: it held that the grouping rules and enhancements were properly applied under circuit precedent; the two-level enhancement for “sexual contact” was correct; the district court did not rely on inaccurate victim impact information; and the sentencing explanation was adequate with reference to the relevant statutory factors. The judgment of the district court was affirmed. View "USA v. Betty" on Justia Law

USA v. Lloyd

2026-08-12T12:00:47-08:00

In this case, the defendant was found asleep with a firearm in his possession at a restaurant in Indiana. He was charged with and pleaded guilty to being a felon in possession of a firearm. At sentencing, the calculation of his advisory sentencing range under the United States Sentencing Guidelines turned on whether his prior Indiana conviction for conspiracy to commit armed robbery qualified as a “crime of violence.” The parties agreed that Indiana law allows for conviction of conspiracy even if the only other participant is an undercover officer, a so-called “unilateral” conspiracy. The United States District Court for the Southern District of Indiana determined that the relevant definition of “conspiracy” under the Guidelines, as amended in 2023, included both bilateral (where more than one genuine participant agrees to commit a crime) and unilateral conspiracies. As a result, it found that the Indiana conviction was a “crime of violence,” applied a higher offense level, and sentenced the defendant to 96 months in prison. The United States Court of Appeals for the Seventh Circuit reviewed the case. It applied the categorical approach, which looks to the elements of the generic offense as understood when the relevant Guideline provision was enacted. The court held that in 1989, when the Guideline first included conspiracies as “crimes of violence,” the prevailing view required bilateral conspiracies; most states and federal law at that time defined conspiracy as requiring two or more genuine participants. Because Indiana’s statute is broader, the prior conviction could not categorically qualify as a “crime of violence” under the Guidelines. Accordingly, the Seventh Circuit vacated the sentence and remanded for resentencing. View "USA v. Lloyd" on Justia Law

Pfalzgraf v. Rusk County, Wisconsin

2026-08-12T09:31:12-08:00

A Rusk County, Wisconsin sheriff’s deputy, Ben Reisner, stopped Brian Pfalzgraf for having a license plate obscured by snow. During the stop, Deputy Reisner questioned Pfalzgraf about his travel plans and observed what he considered suspicious behaviors, including dilated pupils, dry mouth, and agitation. Based on these observations and Pfalzgraf’s explanation for his movements, Reisner suspected drug use or possession. Reisner frisked Pfalzgraf, searched his car, and, after a K-9 sniff, searched Pfalzgraf’s person, finding methamphetamine. State charges against Pfalzgraf were dismissed after the court suppressed evidence, finding the traffic stop was improperly extended. Pfalzgraf then filed a federal civil rights lawsuit under 42 U.S.C. § 1983 in the United States District Court for the Western District of Wisconsin, alleging three Fourth Amendment violations: an unlawful frisk, an unlawfully extended stop, and an unlawful search of his person. The district court granted partial summary judgment for Pfalzgraf on his unlawful frisk and extended-stop claims, finding no reasonable jury could conclude that Reisner had adequate suspicion to justify either. The court denied summary judgment on the personal search claim, leaving that issue for trial. After Pfalzgraf voluntarily dismissed the latter claim, the case proceeded to a jury trial on damages, resulting in an award for Pfalzgraf. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s grant of partial summary judgment. The appellate court affirmed the finding that the frisk was unlawful, concluding there was no individualized suspicion that Pfalzgraf was armed or dangerous. However, the appellate court reversed the grant of summary judgment on the unlawfully extended stop, finding genuine disputes of material fact regarding whether Reisner had reasonable suspicion to prolong the stop. The court vacated the damages award and remanded for further proceedings. View "Pfalzgraf v. Rusk County, Wisconsin" on Justia Law

Bonan v. FDIC

2026-08-12T09:01:29-08:00

Frank William Bonan II served as chairman of the board and loan committee member at Grand Rivers Community Bank in Illinois while simultaneously holding positions at another local bank. In 2015, Bonan orchestrated a complex loan transaction involving the purchase and leaseback of a warehouse by 618 Holdings, LLC, whose principals were financially unstable and closely connected to Bonan. The transaction was structured so that Grand Rivers’s loan funded both the purchase of the warehouse and initial lease payments, with the bank ultimately suffering significant losses when the loan defaulted. Additionally, Bonan was involved in an incident where the bank mistakenly released its security interest in valuable collateral, resulting in further losses. Following these events, the Federal Deposit Insurance Corporation (FDIC) initiated an administrative enforcement action against Bonan in 2021, alleging unsafe or unsound banking practices and breaches of fiduciary duty. After a hearing before an FDIC administrative law judge, the judge found misconduct and recommended sanctions. The FDIC Board of Directors subsequently issued an order barring Bonan from working at any FDIC-insured institution under 12 U.S.C. § 1818(e) and imposed a $105,000 civil money penalty under 12 U.S.C. § 1818(i)(2)(B). Bonan petitioned the United States Court of Appeals for the Seventh Circuit for review, presenting constitutional and evidentiary challenges, including an argument that the FDIC’s administrative adjudication deprived him of his Seventh Amendment right to a jury trial. The Seventh Circuit found that, under current Supreme Court precedent, the FDIC’s enforcement action implicated “public rights” and was not subject to the jury trial requirement. The court rejected Bonan’s additional constitutional and evidentiary arguments, found substantial evidence supporting the FDIC’s findings, and denied the petition for review, thereby upholding the FDIC’s orders. View "Bonan v. FDIC" on Justia Law

USA v Matlock

2026-08-11T07:30:39-08:00

Johntavis Matlock and Lindsey Wiley were friends who both struggled with heroin addiction. On December 11, 2020, Wiley purchased heroin from Matlock in Evansville, Indiana, after coordinating the transaction through text messages. Wiley ingested some of the heroin at Matlock’s home, picked up additional cash, returned to complete the purchase, and then used heroin with Matlock before leaving for her home in Kentucky. Shortly after arriving home, Wiley exhibited signs of an opioid overdose. Emergency responders administered Narcan, and she revived, stating she had used heroin. Medical professionals concluded she had overdosed on an opioid. Later, Wiley texted Matlock that she had overdosed, and he expressed concern. Wiley died from a drug overdose after a separate meeting with Matlock on February 27, 2021. A federal grand jury indicted Matlock on four counts, including distributing a controlled substance resulting in serious bodily injury (Count One) and resulting in death (Count Two). At trial in the United States District Court for the Southern District of Indiana, Matlock moved for judgment of acquittal, arguing the government failed to prove his heroin was the “but-for” cause of Wiley’s December 11 overdose. The district court denied this motion, instructing the jury on the “but-for” causation standard. The jury convicted Matlock on Count One, as well as on firearm and drug possession charges, but acquitted him on Count Two. The United States Court of Appeals for the Seventh Circuit reviewed the denial of the motion for judgment of acquittal de novo, applying the standard for sufficiency of the evidence. The court held the evidence was sufficient for a rational jury to find Matlock’s heroin was a but-for cause of Wiley’s overdose. The court affirmed Matlock’s conviction. View "USA v Matlock" on Justia Law

DiFranco v City of Chicago

2026-08-07T13:30:46-08:00

A Chicago police officer with cystic fibrosis and related diabetes requested a workplace accommodation in March 2020 to minimize his risk of contracting Covid-19. After receiving guidance from the Department, his medical provider submitted documentation, and he followed up with a self-certification form. The officer continued working as usual during this period. Following Illinois’s stay-at-home order, narcotics officers, including the officer in question, were reassigned to monitor public spaces individually from their vehicles, minimizing contact. The officer expressed concerns to his superiors and was assured that an accommodation would be made. He indicated to a Medical Section captain that his sergeant would ensure he was assigned to solo patrol duties and stated he was content with this arrangement. He worked several more days before becoming ill, was hospitalized, and later died from Covid-19. The Estate sued the City of Chicago in the United States District Court for the Northern District of Illinois, asserting claims under the ADA, Illinois Human Rights Act, and Illinois Wrongful Death Act. The court dismissed disparate treatment claims and granted summary judgment for the City on the failure-to-accommodate and wrongful death claims. It found the officer was reasonably accommodated by reassignment to isolated duties, emphasizing that the method of accommodation was less important than its effect. The court also concluded that the officer was exposed to Covid-19 before requesting reassignment, so any alleged delay could not have caused his death, and the Estate presented no evidence of a later exposure. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s summary judgment decision de novo. The Seventh Circuit held that the City promptly accommodated the officer’s request, and the Estate failed to provide evidence disputing the material facts or establishing a causal link between any City omission and the officer’s illness and death. The court affirmed the district court’s judgment. View "DiFranco v City of Chicago" on Justia Law

Johnson v Ridge Tool Manufacturing Co.

2026-08-07T13:00:45-08:00

Paul Johnson sustained severe injuries while using a drain-cleaning machine manufactured by Ridge Tool Manufacturing Company, Inc. The machine, designed to minimize user risks, included a warning label, an instruction manual, and specially designed gloves. Johnson did not read the manual or use the provided gloves, instead choosing an oversized pair from his employer. While operating the machine, his glove became entangled in the rotating cable, resulting in significant injury. Johnson brought suit against Ridge Tool, alleging strict liability, negligence, and failure to warn. He relied on two expert witnesses: Chad Jones, who opined that a safer alternative design was feasible, and Cynthia Rando, who criticized the manual and glove warnings. The United States District Court for the Northern District of Illinois excluded both expert reports under Federal Rule of Evidence 702, finding Jones’s alternative design opinion unreliable due to lack of testing, analysis, and supporting industry data, and Rando’s report deficient for not proposing an alternative warning and for focusing on the manual Johnson never read. The district court then granted summary judgment to Ridge Tool, concluding that Johnson’s claims lacked evidentiary support after the exclusion of his experts. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s decisions for abuse of discretion regarding the exclusion of expert testimony and de novo for summary judgment. The appellate court affirmed both rulings, holding that the district court properly excluded Johnson’s experts for unreliable methodologies and unsupported conclusions, and that, absent those expert opinions, Johnson’s legal theories could not survive summary judgment. The court emphasized the necessity of reliable expert evidence and alternative warnings to establish causation in failure-to-warn claims under Illinois law. The judgment was affirmed. View "Johnson v Ridge Tool Manufacturing Co." on Justia Law

G.T. v Samsung Electronics America, Inc.

2026-08-07T12:00:45-08:00

Several individuals who purchased and used Samsung smartphones and tablets alleged that the preinstalled Samsung Gallery app created and stored face templates by scanning photographs for facial geometry, thereby capturing biometric data. They claimed that Samsung’s proprietary algorithm measured unique facial features, and the resulting face templates were stored locally on their devices. Plaintiffs argued that Samsung controlled the biometric data, since users had no way to disable the facial recognition features, and Samsung’s privacy policy indicated it “may collect” such information. They further contended that Samsung lacked a written policy for retention and destruction of biometric data and failed to provide required disclosures or obtain releases, in violation of the Illinois Biometric Privacy Information Act (“BIPA”). The plaintiffs initially filed their suit in Illinois state court, seeking class certification for all Illinois residents whose biometric data was collected or stored by Samsung. Samsung removed the case to the United States District Court for the Northern District of Illinois under the Class Action Fairness Act. After several amended complaints and motions to dismiss, the district court ultimately granted Samsung’s third motion to dismiss with prejudice, finding that the plaintiffs failed to plausibly allege that Samsung possessed or exerted control over the biometric data stored on users’ devices. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s dismissal de novo. The court held that under both Illinois law and BIPA, “possession,” “collection,” and “capture” require a degree of control by the company over the biometric data. Because the plaintiffs’ allegations did not plausibly show that Samsung itself controlled the facial geometry data generated by the app, the Court affirmed the district court’s judgment dismissing the complaint. View "G.T. v Samsung Electronics America, Inc." on Justia Law

Ferguson v USA

2026-08-07T12:00:44-08:00

Terry Ferguson was charged with conspiracy to distribute cocaine and possession of a firearm by a convicted felon. In January 2023, he pleaded guilty to both counts under a written plea agreement that included a broad waiver of his appellate rights, except for challenges to the validity of the plea or his sentence. During the investigation, federal agents solicited Ferguson's cooperation against his attorney, Beau Brindley, suggesting possible misconduct by Brindley. Ferguson initially expressed interest but ultimately declined to cooperate and retained Brindley as his counsel throughout the proceedings. After pleading guilty, Ferguson filed motions in the United States District Court for the Northern District of Illinois, Eastern Division, to dismiss the indictment on grounds of selective or vindictive prosecution, alleging he was singled out due to personal animus from investigating agents. The district court denied these motions, finding no evidence of improper prosecutorial motive and determining that Ferguson had waived such defenses by pleading guilty. Ferguson also sought to vacate his sentence under 28 U.S.C. § 2255, claiming ineffective assistance of counsel due to an alleged conflict of interest arising from the government's inquiry into Brindley. The district court rejected this claim, concluding there was no actual conflict or adverse effect on Brindley’s representation. On consolidated appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s denial of Ferguson’s § 2255 motion, holding there was no actual conflict of interest or adverse effect on counsel’s performance. The court also dismissed Ferguson’s appeal of the denial of his motions to dismiss, enforcing the appellate waiver in his plea agreement, which barred such claims. Thus, the district court’s judgment was affirmed in part and the remaining appeal was dismissed. View "Ferguson v USA" on Justia Law

March v. Wolff

2026-08-07T08:30:54-08:00

A town administrator in Grand Chute, Wisconsin, was terminated by a newly elected faction on the town’s Board of Supervisors. The administrator, who had served since 2008, claimed his firing was retaliation for cooperating with a state Department of Justice investigation into alleged corruption by a newly elected supervisor. That supervisor had previously been involved in litigation against the town and was later indicted, though ultimately acquitted, on unrelated corruption charges. The administrator’s relationship with the new board members deteriorated, and he was perceived as politically aligned with their rivals and critical of their policies. The administrator sued the Town and individual supervisors in the United States District Court for the Eastern District of Wisconsin under 42 U.S.C. § 1983, asserting First Amendment retaliation. The supervisor also filed a counterclaim alleging the administrator had set him up for prosecution. The district court granted summary judgment for the defendants in both actions, finding the administrator’s termination did not violate the First Amendment and that qualified immunity applied due to unclear precedent regarding the firing of policymaking officials for political speech. The court also rejected the supervisor’s counterclaim, finding no evidence of state action or differential treatment required for an equal protection class-of-one claim. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s rulings de novo. The Seventh Circuit affirmed, holding that the individual defendants were entitled to qualified immunity because existing precedent did not clearly establish that firing a policymaking official under these circumstances violated the First Amendment. The court also affirmed dismissal of the counterclaim, finding neither a viable First Amendment retaliation nor an equal protection claim. View "March v. Wolff" on Justia Law

CSX Transportation, Inc. v Zayo Group, LLC

2026-08-07T06:00:45-08:00

A railroad company operates lines throughout Indiana, holding various property interests in its corridors, such as easements and fee simple ownership. A telecommunications utility installed fiber optic cables above and below some of these railroad tracks without the railroad’s permission, safety review, or payment of licensing fees required by the railroad. The railroad claimed that under Indiana law, its easements gave it exclusive rights to the airspace and subsurface, including the right to exclude third parties and charge for installations. In the United States District Court for the Southern District of Indiana, the railroad asserted claims including trespass, theft, and unjust enrichment. The district court dismissed all claims related to Illinois sites for lack of personal jurisdiction. For the Indiana properties where the railroad held only easements, the district court ruled that the railroad lacked standing to assert trespass and rent claims, finding that its easements did not necessarily include the right to exclude others from the air or subsurface where there was no interference with railroad operations. The court also held that claims based on older installations were time-barred, determining these did not constitute continuing trespasses under Indiana law. Before the United States Court of Appeals for the Seventh Circuit, the railroad argued its easements included exclusion and licensing rights, and that the installations were continuing trespasses. The Seventh Circuit held that, under Indiana law, railroad easements do not necessarily include the right to exclude third parties from the air or ground below the tracks, nor the right to charge licensing fees for such installations unless the railroad’s operations are disturbed. The court also affirmed that these installations are not continuing trespasses and that claims outside the applicable statute of limitations are barred. The Seventh Circuit affirmed the judgment of the district court. View "CSX Transportation, Inc. v Zayo Group, LLC" on Justia Law

USA v Wiley

2026-08-06T11:30:55-08:00

Two Illinois State Police troopers observed Damond K. Wiley, Jr. driving a blue BMW in East St. Louis. After following him for several blocks, they saw the BMW back into a lot in front of a dilapidated, roofless house, with its front wheels slightly on the street and its body blocking the sidewalk. The troopers’ dash camera showed the BMW had dark tinted windows, in violation of Illinois law. When the police cruiser stopped with emergency lights on, Mr. Wiley exited the vehicle and, after being told to get back in, fled on foot. One trooper briefly chased Wiley, while the other returned to the BMW and discovered a pistol in plain view on the driver’s seat. Mr. Wiley was apprehended and, during a subsequent search, police found cannabis and a digital scale in the vehicle. The United States filed a criminal complaint in the United States District Court for the Southern District of Illinois, charging Wiley with possession of a firearm by a felon. Wiley moved to suppress the evidence, arguing the stop and search were unlawful, and requested an evidentiary hearing. The district court denied both the suppression motion and the hearing, finding that the troopers had reasonable suspicion for the stop based on the tinted windows and other traffic violations, and that the search was justified under several exceptions to the warrant requirement, including the protective search doctrine. On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The Seventh Circuit held that the traffic stop was supported by reasonable suspicion based on the visible window tint violation. It further held that the officer’s brief search of the BMW was justified under the protective search exception to the Fourth Amendment, due to safety concerns arising from Wiley’s flight and the inability to see inside the vehicle. The court also found no error in denying an evidentiary hearing. The district court’s judgment was affirmed. View "USA v Wiley" on Justia Law

USA v. Agarwal

2026-08-06T08:30:45-08:00

Rishi Shah and Shradha Agarwal, executives at Outcome Health, were indicted in 2019 for orchestrating a years-long, multi-million-dollar fraud scheme affecting both clients and investors of the company. Outcome Health sold advertising space in doctors’ offices and allegedly inflated its inventory and performance metrics, misleading clients and investors. The fraud resulted in substantial revenue, which was used both for company growth and personal gain. Following public exposure of the scheme, Shah and Agarwal settled civil suits, resigned from Outcome, paid significant sums to investors, and retained funds for legal fees. The United States District Court for the Northern District of Illinois, Eastern Division, entered a pretrial protective order freezing assets deemed traceable to the alleged fraud, including funds Shah and Agarwal intended for legal fees. Shah and Agarwal unsuccessfully challenged the restraint of these funds before trial, resulting in their preferred counsel withdrawing. Both defendants were convicted by a jury on multiple counts of mail, wire, and bank fraud, with Shah also convicted of money laundering. The district court imposed prison terms, fines, and forfeiture orders, and denied post-trial motions challenging the asset restraint, evidentiary rulings, and alleged government misconduct. The United States Court of Appeals for the Seventh Circuit reviewed the case. It held that Shah and Agarwal forfeited their Sixth Amendment right-to-counsel claim by not timely raising it, and, in the alternative, failed to prove that the government’s asset restraint prevented them from affording their counsel of choice. The court further found no Fifth Amendment violation, as the government did not knowingly present or fail to correct false testimony to the grand jury. The court also rejected evidentiary and jury instruction challenges, concluding any errors were harmless and that convictions rested on valid legal theories. The Seventh Circuit affirmed the convictions and all related district court rulings. View "USA v. Agarwal" on Justia Law

USA v. Duncan

2026-08-06T06:31:06-08:00

Thomas Duncan, a supervisor at the Jesse Brown VA Medical Center in Chicago, participated in a fraudulent scheme with his co-defendant, Daniel Dingle. Duncan used his purchasing authority to submit or direct others to submit false orders for blood pressure cuffs from Dingle’s medical supply company. These orders were structured to avoid detection by staying under authorization thresholds and were never actually fulfilled. Dingle received payments from the VA for these phantom orders and paid Duncan kickbacks in return. Altogether, the VA paid nearly $1.9 million to Dingle’s company, with over $1.7 million related to these patterned, fraudulent orders. The United States District Court for the Northern District of Illinois, Eastern Division, oversaw Duncan’s guilty plea to one count of wire fraud. At sentencing, the court considered a Presentence Investigation Report and heard arguments regarding sentencing enhancements for multiple bribes and the loss calculation. Duncan contended he was responsible for only a portion of the loss and that the scheme involved only a single bribe. The district court disagreed, finding Duncan responsible for all patterned orders and concluding the offense involved multiple bribes. The court calculated the Sentencing Guidelines range accordingly and sentenced Duncan to 84 months’ imprisonment. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s legal interpretations de novo and factual findings for clear error. The appellate court held that the district court did not err in applying enhancements for multiple bribes and a loss amount over $1.5 million. The court found the district court’s conclusions were supported by reasonable inferences from the evidence and that any possible error would be harmless, given the district court’s explicit statement that it would impose the same sentence regardless of the enhancements. Accordingly, the judgment was affirmed. View "USA v. Duncan" on Justia Law

Consolidated Chassis Management LLC v Northland Insurance Co.

2026-08-05T14:00:47-08:00

The case centers on a 2016 traffic accident in Will County, Illinois, involving a semi-tractor operated by Midvest Transport Corporation, pulling a chassis managed by two companies. The driver of the car involved sued multiple defendants: Midvest, its driver, and the chassis companies. All defendants were insured by Northland Insurance Company. Northland appointed separate counsel for its insureds, but the chassis companies (Consolidated) preferred their own attorneys and sought reimbursement from Northland for those legal expenses, also seeking statutory penalties under Illinois law. In the United States District Court for the Northern District of Illinois, Consolidated sued Northland for declaratory and compensatory relief, alleging breach of contract and seeking penalties under § 155 of the Illinois Insurance Code. The district court initially ruled for Northland, finding no conflict of interest that would entitle Consolidated to independent counsel at Northland's expense. On reconsideration, however, the court found a conflict existed, granted summary judgment for Consolidated on the breach of contract and declaratory relief claims, and awarded $115,000. The district court rejected Consolidated’s claim for penalties, finding Northland did not act vexatiously or unreasonably. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s rulings de novo. It held that Illinois law only creates a narrow exception to an insurer’s right to control the defense where a serious, actual conflict exists between the insurer and the insured. The court found no such conflict here, as Northland’s interests were not at odds with Consolidated’s, and any adversity between insured codefendants did not trigger the right to independent counsel. Accordingly, the Seventh Circuit reversed the judgment in favor of Consolidated on its breach of contract and declaratory relief claims, and affirmed the judgment in favor of Northland on the § 155 claim. View "Consolidated Chassis Management LLC v Northland Insurance Co." on Justia Law

USA v Morales-Garcia

2026-08-05T13:00:54-08:00

In this case, a defendant was investigated by the U.S. Drug Enforcement Administration for cocaine trafficking in January 2018. An undercover officer negotiated with the defendant for the sale of five kilograms of cocaine. Their conversations included discussions of pricing, logistics, and future transactions, and the defendant provided a sample of cocaine at a recorded meeting. On the day of the planned sale, law enforcement observed the defendant retrieve a bag, which was later found to contain multiple packages of cocaine. After his arrest, the defendant admitted his involvement and knowledge of the cocaine deal. He was charged with conspiracy and possession with intent to distribute cocaine, with the indictment specifying approximately five kilograms or more. The United States District Court for the Northern District of Illinois, Eastern Division, presided over the trial. Prior to trial, the government moved to admit evidence that the defendant had referenced a prior heroin sale in a conversation during the cocaine negotiations, arguing its relevance to the defendant’s knowledge and intent. The court admitted the heroin-related evidence under Federal Rule of Evidence 404(b), finding it relevant to knowledge and intent. At trial, the defense focused on contesting the weight of the cocaine, challenging whether the government had proven the statutory threshold for an enhanced sentence. The jury convicted the defendant on all counts. Post-trial motions challenging the admission of the heroin evidence and the prosecutor’s remarks during closing were denied. On appeal, the United States Court of Appeals for the Seventh Circuit held that the district court erred in admitting the heroin-related evidence under Rule 404(b), as its relevance depended on a prohibited propensity inference. However, the court found the error harmless due to overwhelming evidence of guilt. The court also held that the prosecutor’s rebuttal argument did not violate the defendant’s Fifth Amendment rights. The district court’s judgment was affirmed. View "USA v Morales-Garcia" on Justia Law

Schulte v Leners

2026-08-05T13:00:54-08:00

Elizabeth Schulte, a co-owner of property in Cedar Lake, Wisconsin, challenged actions by Kenneth J. Leners, chairman of the Town’s Board of Supervisors. The Town maintained a website open to public comments, which Schulte used to criticize a post advocating stricter regulation of recreational vehicles. In response, Leners deleted Schulte’s and other critical comments, banned them from further commenting, and ultimately removed all comments from the post. After threats of legal action, the Board decided to eliminate comment sections from the website entirely, later restoring deleted comments in a separate thread unconnected to the original post. Schulte filed suit under 42 U.S.C. §1983 in the United States District Court for the Western District of Wisconsin, alleging violation of her First and Fourteenth Amendment rights due to viewpoint discrimination and vague criteria for regulating the comment section. She also claimed unlawful retaliation when the comment sections were shut down. Leners moved to dismiss, asserting qualified immunity. The district court denied the motion regarding the counts related to selective deletion of comments, finding Schulte had pleaded viewpoint discrimination and rejecting Leners’s qualified-immunity defense. The court dismissed other unrelated counts and allowed Leners and the Town to appeal. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s denial of qualified immunity for Leners’s selective deletion of comments. The appellate court held that it was clearly established in September 2022 that viewpoint discrimination in a public forum, such as a website comment section open to the public without content restrictions, violates the First Amendment. The lack of any policy regulating comment content made the speech private, not government speech. The Seventh Circuit affirmed the district court's denial of qualified immunity to Leners and dismissed the Town’s appeal. View "Schulte v Leners" on Justia Law

Dupont Water Company, Inc. v City of Madison

2026-08-05T13:00:53-08:00

Jefferson County, Indiana, constructed a new jail just outside the city limits of Madison, Indiana, and needed water service for the facility. Dupont Water Company, a rural water association that holds federal debt, claims certain monopoly rights under 7 U.S.C. § 1926(b). The County initially attempted to procure water from Dupont but faced delays: Dupont failed to propose infrastructure solutions or provide a rate quote over several months. Eventually, Jefferson County contracted with the City of Madison, which had the necessary infrastructure and rate schedule, to supply water to the jail. The United States District Court for the Southern District of Indiana, New Albany Division, reviewed the case. Dupont sued Madison, alleging violation of its § 1926(b) monopoly rights. Jefferson County intervened, seeking a declaration that its agreement with Madison was lawful. The district court granted summary judgment in favor of Madison and Jefferson County, finding that Dupont had not "provided or made available" water service to the jail as required to trigger § 1926(b)'s protections. The United States Court of Appeals for the Seventh Circuit reviewed the district court's grant of summary judgment de novo. The appellate court held that, based on the undisputed facts, Jefferson County had requested water service from Dupont, but Dupont did not provide the necessary infrastructure or rate information within a reasonable time. As a result, Dupont did not "provide or make available" water service to the jail under § 1926(b). Therefore, Madison did not violate § 1926(b) by supplying water to the jail. The Seventh Circuit affirmed the district court's judgment. View "Dupont Water Company, Inc. v City of Madison" on Justia Law

USA v Pena

2026-08-05T09:31:19-08:00

Shawn Pena pleaded guilty in 2021 to conspiracy to engage in interstate transportation of stolen goods and was sentenced to 37 months in prison followed by 36 months of supervised release. After beginning supervised release in June 2023, Pena committed several violations, including failing to notify probation of arrests for theft, unauthorized travel, failure to provide his new address, and associating with a known felon. When he missed a court hearing in January 2024, a warrant was issued and he remained a fugitive for over a year until his arrest in April 2025 on new charges. Probation filed multiple violation reports, and at the revocation hearing, Pena and the government agreed to a 14-month sentence for four lower-level violations, with the government recommending one year of supervised release. The United States District Court for the Northern District of Illinois, Eastern Division, reviewed the case. At the revocation hearing, the probation officer recommended a 24-month sentence and one year of supervised release, citing Pena’s criminal history and risk to the community. The district court imposed the maximum 24-month sentence and a year of supervised release, overruling Pena’s objection to a supervised release condition requiring him to notify third parties if his probation officer deemed him a risk. The United States Court of Appeals for the Seventh Circuit reviewed the appeal. It held that Pena had waived procedural objections regarding police reports, found no breach of the plea agreement by the government, determined the district court’s sentence was based on deterrence and public safety rather than retribution, and concluded that the challenged supervised release condition was unconstitutionally vague. The court affirmed the 24-month sentence and 12-month supervised release but vacated the vague condition and remanded for clarification. View "USA v Pena" on Justia Law

USA v Carney

2026-08-04T13:30:45-08:00

Two siblings were tried for the kidnapping of a local businessman in Illinois. The victim responded to a call for a flooring job estimate, where he was attacked, restrained, and transported to a basement. He was forced to request a ransom from his wife, who instead alerted police. The kidnappers subsequently moved the victim to an abandoned minivan and fled. Police arrested the siblings days later after observing them driving a car linked to the crime scene. At trial, the government introduced letters written by one sibling from jail, in which she asked family members to provide a false alibi for both herself and her brother. These letters contained various references to her brother and were admitted with some redactions to minimize prejudice. The case was first tried before the United States District Court for the Central District of Illinois. The jury convicted both siblings of kidnapping. The district court sentenced the sister to thirty years in prison and her brother to twenty-four years. The brother appealed, arguing that admitting the letters violated his Confrontation Clause rights and that his sentence was unreasonable. He had not objected to the letters’ admission or their contents at trial, nor did he raise certain evidentiary objections on appeal. The United States Court of Appeals for the Seventh Circuit reviewed the appeal. The court applied the plain-error standard to the Confrontation Clause argument, because the defendant had not raised it below. The court found that even if there was a plain error, it did not affect the outcome of the trial or the fairness of the proceedings, given the strong evidence against the defendant. Regarding sentencing, the court found that the district court had considered the defendant’s mitigation arguments and imposed a below-Guidelines sentence. The Seventh Circuit affirmed both the conviction and sentence. View "USA v Carney" on Justia Law

USA v Clemon

2026-08-04T13:00:46-08:00

Several individuals were prosecuted for their involvement in a criminal gang known as the Gangster Disciples. The prosecution alleged that these defendants participated in violent acts, including murder, to further the gang’s interests and consolidate power following internal leadership disputes. Key events included a deadly shootout at Matthews Park in Missouri in April 2018, and the murder of Ernest Wilson in Chicago in May 2018. The evidence against the defendants included testimony from gang members, law enforcement, and experts, as well as letters and recorded phone calls among coconspirators. The United States District Court for the Southern District of Illinois presided over the trial. Before trial, the defendants moved for a "Santiago proffer," requesting the government to identify coconspirator statements and provide explanations for their admissibility under Federal Rule of Evidence 801(d)(2)(E). The district court denied the request, conditionally admitting coconspirator testimony and leaving objections to be raised during trial. The jury convicted all defendants on multiple counts, including racketeering conspiracy, murder in aid of racketeering, and firearm offenses. The district court sentenced each to life imprisonment. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed challenges regarding the admission of coconspirator statements, sufficiency of evidence, suppression motions, jury impartiality, expert testimony, and evidentiary rulings. The Seventh Circuit found no reversible error, holding that the district court’s failure to require a pretrial Santiago proffer did not constitute structural error and that the admitted statements met the requirements of Rule 801(d)(2)(E). The court also determined that the evidence was sufficient to support the convictions, and any evidentiary errors were harmless. The Seventh Circuit affirmed the convictions and sentences. View "USA v Clemon" on Justia Law

Insurance Company of the West v High Performance Alloys, Inc.

2026-08-04T12:30:58-08:00

An employee of High Performance Alloys, Inc. died while working at the company’s facility. The deceased employee’s estate sued the company for wrongful death, alleging gross negligence, willful and wanton conduct, disregard of safety regulations, and actual intent to cause injury. The complaint referenced prior safety violations, knowledge of hazardous conditions, failure to implement available safety measures, and a claim that the employer acted with actual intent to cause injury. The estate’s lawsuit was pending in Indiana state court. High Performance Alloys sought coverage under its Worker’s Compensation and Employers’ Liability Insurance Policy issued by Insurance Company of the West. ICW denied coverage, asserting the claims were excluded by the policy. ICW then filed a federal declaratory judgment action in the United States District Court for the Southern District of Indiana, seeking a determination that it had no duty to defend or indemnify High Performance Alloys. High Performance Alloys counterclaimed for coverage. The district court granted judgment in favor of ICW, holding that the claims were either barred by Indiana’s Workers’ Compensation Act or excluded by the Policy’s intentional acts exclusion. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s ruling de novo. The Seventh Circuit held that the estate’s allegations, even if true, either described an accidental injury governed exclusively by Indiana’s Workers’ Compensation Act or an intentional injury excluded from coverage by the policy. The court found the complaint did not allege facts sufficient to plead an intentional tort under Indiana law and denied a request to certify questions to the Indiana Supreme Court. The court affirmed the district court’s judgment, holding that Insurance Company of the West has no duty to defend High Performance Alloys in the underlying lawsuit. View "Insurance Company of the West v High Performance Alloys, Inc." on Justia Law

Golat v Swierawski

2026-08-04T12:30:58-08:00

The plaintiff worked as a court reporter in Rusk County, Wisconsin, initially for Judge Henderson and later for Judge Anderson. She alleged that over several years, she experienced a hostile work environment based on her sex, including inappropriate comments and conduct mainly from Judge Anderson and his judicial assistant. She also claimed her employer failed to accommodate her disability after a work-related injury limited her typing, and that she was retaliated against for reporting the hostile environment and requesting accommodations. Her claims described a series of disciplinary investigations, negative personnel actions, and ultimately not being rehired after Judge Anderson’s retirement, allegedly due to animus from court officials. The United States District Court for the Western District of Wisconsin granted summary judgment for all defendants. The court found that the evidence did not support a hostile work environment claim under Title VII or an Equal Protection claim, as most of the alleged conduct was either not causally connected to her sex or not severe or pervasive enough. It also determined that the employer’s accommodations for her disability, such as use of the DAR system and requirements for sick leave, were reasonable and that negative comments were not relevant to an accommodation claim. On the retaliation claims, the court concluded that only two actions—her suspension and not being rehired—could be considered materially adverse, but found no evidence they were pretextual or causally linked to her protected activity. The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court’s judgment. The Seventh Circuit held that the alleged conduct did not rise to the level of actionable severity or pervasiveness for a hostile work environment, that reasonable accommodations were provided, and that no reasonable jury could find the adverse actions were retaliatory. The decision of the district court was affirmed. View "Golat v Swierawski" on Justia Law

Demir v Mullin

2026-08-04T12:01:02-08:00

Halil Demir, a naturalized U.S. citizen and Executive Director of an international aid organization, frequently travels for work and has received security clearances for certain events. Since 2016, Demir experienced extended airport screening, leading him to suspect wrongful inclusion on the FBI’s Terrorist Watchlist and its Selectee List. After submitting five inquiries through the Department of Homeland Security’s Traveler Redress Inquiry Program (DHS TRIP), he received generic responses that neither confirmed nor denied his watchlist status. Demir then filed suit, alleging violations of his substantive and procedural due process rights and challenging the adequacy of DHS TRIP procedures under the Administrative Procedure Act. The United States District Court for the Northern District of Illinois dismissed Demir’s complaint for lack of subject matter jurisdiction. The court concluded that, under 49 U.S.C. § 46110, challenges to TSA orders—including those relating to DHS TRIP—must be brought directly in a federal court of appeals. It reasoned that Demir’s claims were essentially contesting a TSA decision, as reflected in the DHS TRIP determination letter, and thus should have originated in the Court of Appeals. The United States Court of Appeals for the Seventh Circuit reviewed the case. It held that § 46110 does not apply to Demir’s challenges to his inclusion on the Terrorist Watchlist and Selectee List, as the TSA does not control these lists—the FBI’s Threat Screening Center does. Thus, the district court has jurisdiction over those claims, and the appellate court reversed and remanded them for consideration on the merits. However, the appellate court affirmed the district court’s dismissal of Demir’s challenge to the DHS TRIP program itself, holding that the program constitutes an “order” under § 46110 and must be initially reviewed in a court of appeals. View "Demir v Mullin" on Justia Law

Cortez Gomez v Kohl's Corporation

2026-08-03T13:00:55-08:00

The plaintiff purchased a portable speaker from a Wisconsin-based retailer, believing she was receiving a $30 discount off a regular price of $129.99. However, she later discovered that the retailer almost always sold the speaker at the “sale” price of $99.99 and rarely at the higher “regular” price. She claimed she would not have bought the speaker if she had known this, and brought suit on behalf of a proposed nationwide class, alleging the retailer had violated Wisconsin’s Unfair Trade Practices Act by using misleading price comparison advertising. The suit was filed in federal court, invoking the Class Action Fairness Act as the basis for subject matter jurisdiction. The United States District Court for the Western District of Wisconsin dismissed the complaint for lack of subject matter jurisdiction, finding that the plaintiff had not adequately alleged pecuniary loss under Wisconsin law. The court reasoned that, for damages under Wisconsin’s Unfair Trade Practices Act, the plaintiff must plead that the product was defective or worth less than the price paid, or otherwise did not receive the benefit of the bargain. Because the plaintiff did not make such allegations, the court concluded it was legally impossible for her to meet the required amount-in-controversy for class action jurisdiction. The United States Court of Appeals for the Seventh Circuit reviewed the dismissal de novo. It found Wisconsin law unclear on whether a consumer who was misled by false price comparison advertising, but received a product worth the purchase price, suffers a pecuniary loss. Noting a split in authority and uncertainty in Wisconsin precedent, the appellate court certified this question to the Wisconsin Supreme Court and stayed further proceedings pending an answer. View "Cortez Gomez v Kohl's Corporation" on Justia Law

Bedford v Dewitt

2026-07-31T13:00:52-08:00

On the evening of June 24, 2018, following Chicago’s Pride Parade, Breah Bedford and her friends were on the sidewalk outside a bar owned by Joseph Plewa. After Plewa and his staff ordered the group to move and a confrontation ensued, Plewa dragged one of Bedford’s friends into the bar’s vestibule. Bedford attempted to intervene using objects she had on hand. Chicago police officers arrived, and Officer Brandon DeWitt approached Bedford from behind and shoved her to the ground, after which she suffered seizure-like symptoms. Bedford was taken to a hospital, where she was diagnosed with psychogenic non-epileptiform seizures. During her admission, a nurse reported that Bedford was combative and made a threatening racial comment. Bedford and her friend later sued Plewa, his business, Officer DeWitt, and others, alleging excessive force and state-law claims. The United States District Court for the Northern District of Illinois, Eastern Division, dismissed some claims at summary judgment and narrowed the issues for trial. At trial, the jury found in favor of Bedford’s friend against Plewa and his business, awarding damages, but rejected all of Bedford’s claims. Bedford appealed, arguing that five evidentiary rulings by the district court undermined the verdict. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s evidentiary decisions for abuse of discretion and found none. The court held that admitting expert testimony regarding malingering, nurse testimony about Bedford’s hospital behavior, evidence of the police use-of-force model, and the exclusion of certain video audio and prior use-of-force incidents were all within the district court’s discretion and did not affect the trial’s outcome. Accordingly, the Seventh Circuit affirmed the district court’s judgment. View "Bedford v Dewitt" on Justia Law

Fox v DuPage Township

2026-07-31T12:00:46-08:00

Two long-term employees of a township senior center lost their jobs when a newly elected board, led by a candidate from the opposing political party, reorganized the center's leadership structure. The plaintiffs, both Republicans, had campaigned for the losing Republican candidate in the local election. After the incoming Democratic supervisor and board took office, they voted to eliminate the plaintiffs' positions as part of a broader reorganization, creating new roles and appointing others, including one individual who had also supported the Republican candidate. After their terminations, the plaintiffs filed suit in Illinois state court, naming the township and certain officials as defendants. They alleged, among other claims, that their First Amendment rights had been violated because their political activity was a motivating factor in their dismissals. The defendants removed the case to the United States District Court for the Northern District of Illinois. Following partial dismissal of claims, only the First Amendment retaliation and breach of implied contract claims against the township remained. After discovery, the district court granted summary judgment for the township, finding plaintiffs had not shown that their political activity was a motivating factor in the terminations, nor had they rebutted the township's evidence of legitimate reasons for the reorganization. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision de novo. The Seventh Circuit held that the plaintiffs had not produced sufficient evidence that their political activity motivated their terminations. The court found that the undisputed evidence showed neither the new supervisor nor the trustees knew of the plaintiffs' political involvement, and there were valid, non-retaliatory reasons for the personnel changes. The court affirmed the district court’s grant of summary judgment for the township. View "Fox v DuPage Township" on Justia Law

USA v Ghosh

2026-07-31T11:31:21-08:00

The defendant, a physician specializing in obstetrics and gynecology in Illinois, owned and operated a medical practice where she engaged in fraudulent billing to health care benefit programs, including Medicaid and Tricare, from February 2018 to April 2022. She submitted claims for procedures and services that were either not provided or not medically necessary, including telemedicine visits, office visits, and tests. Some of these fraudulent claims were for endometrial ablations, a procedure with significant consequences for patients’ reproductive health. Facing a thirteen-count indictment for health care fraud, the defendant pleaded guilty to two counts pursuant to a plea agreement. These counts specifically alleged the submission of fraudulent claims to Tricare for a telemedicine visit and lab testing. The United States District Court for the Northern District of Illinois, Eastern Division, held a sentencing hearing, during which it considered testimony from patients, expert witnesses, and victim impact statements. The court found that the defendant performed medically unnecessary procedures without informed consent, and that her statements during the plea hearing and subsequent professional regulation proceedings indicated a failure to accept responsibility. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed three main issues: the district court’s denial of a reduction for acceptance of responsibility, application of a sentencing enhancement for reckless risk of serious bodily injury, and the substantive reasonableness of the 120-month sentence. The Seventh Circuit held that the district court did not clearly err in its factual findings, properly applied the sentence enhancement, and did not abuse its discretion in weighing aggravating and mitigating factors. The court affirmed the judgment of the district court, upholding the defendant’s sentence. View "USA v Ghosh" on Justia Law

Hooper v Crawford

2026-07-31T11:31:20-08:00

The debtor in this case filed for Chapter 13 bankruptcy and proposed a plan that included distributions to Bank of America, a creditor with a secured claim on the debtor’s residence. The bankruptcy court confirmed the amended plan on January 31, 2023, before the bar date for creditors to file claims had passed. Bank of America did not file a proof of claim and did not object to its inclusion in the plan. Over a year later, the Chapter 13 trustee sought to modify the plan to remove Bank of America from distributions, arguing that only creditors with allowed claims—those who have filed proofs of claim—should receive payments under the plan. The United States Bankruptcy Court for the Northern District of Illinois denied the trustee’s motion to modify the plan, relying on its reasoning in In re Ellis, which supported the district’s “plan forward” procedures. The United States District Court for the Northern District of Illinois affirmed the bankruptcy court’s order, agreeing that the inclusion of Bank of America in the confirmed plan required the trustee to make distributions according to the plan, regardless of whether Bank of America had filed a proof of claim. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the legal conclusions de novo. The court held that under the Bankruptcy Code, the provisions of a confirmed Chapter 13 plan are binding on all parties, including creditors listed in the plan, regardless of whether they have filed proofs of claim. The court concluded that confirmation of the plan “allows” the claims contained therein, and the trustee must distribute payments as directed by the plan. The court affirmed the district court’s order and did not reach the trustee’s argument regarding modification of the confirmed plan. View "Hooper v Crawford" on Justia Law

USA v. Jones

2026-07-31T09:01:42-08:00

Federal agents obtained a warrant to search the defendant’s mobile home in Moline, Illinois, for evidence of drug trafficking. The warrant was based on an affidavit describing a lengthy investigation into a drug organization operating between Arizona and the Quad Cities area. Key facts included intercepted packages containing money and drugs, suspicious phone calls linked to the defendant, phone records connecting him to individuals involved in the drug operation, and utility records showing a person of interest lived with him. In addition, agents conducted two searches of trash outside his residence, finding small amounts of discarded marijuana, mail addressed to the defendant and his housemate, vacuum-seal bags, and a shipping box. When agents executed the warrant, they discovered marijuana and over eight hundred grams of methamphetamine. In the United States District Court for the Central District of Illinois, the defendant moved to suppress evidence obtained during the search, arguing the warrant lacked probable cause. The district court acknowledged that the information connecting the defendant’s address to the drug organization was somewhat stale and attenuated, but ultimately found that the marijuana recovered from the trash alone supplied probable cause for the search under United States v. Leonard. The defendant entered a conditional guilty plea, preserving his right to appeal the suppression ruling. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s denial of the motion to suppress. The court applied a standard giving great deference to the issuing magistrate judge but reviewed legal conclusions de novo. The Seventh Circuit affirmed the denial, holding that officers reasonably relied on the warrant in good faith because the affidavit’s information, taken as a whole, came close enough to establishing probable cause for drug trafficking. The court did not rely solely on the marijuana found in the trash but emphasized the broader context of the ongoing investigation and ties to the defendant’s residence. View "USA v. Jones" on Justia Law

Stokes v. Illinois Department of Corrections

2026-07-31T08:30:47-08:00

The plaintiff worked as a mental-health professional at a state prison in Illinois, but was employed by Wexford Health Services, an independent contractor providing medical staff to the Illinois Department of Corrections. She was hired, trained, paid, and supervised by Wexford, though her work took place at the prison and she was subject to some policies set by the Department, such as dress codes for security reasons. After multiple incidents involving confrontations about her attire by prison staff, she resigned from her position. She then filed suit, alleging that she had experienced discrimination, a hostile work environment, and retaliation based on her race and sex, in violation of Title VII. In the United States District Court for the Central District of Illinois, the Department of Corrections moved for summary judgment, arguing it was not her employer for Title VII liability purposes. The district court agreed, applying the five-factor test from Knight v. United Farm Bureau Mutual Insurance Co., and found the Department was not a joint employer. Consequently, summary judgment was granted for the Department, and the claims against Wexford were voluntarily dismissed by the plaintiff. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court’s decision. The appellate court applied the Knight test, focusing on control, skill provision, responsibility for operational costs, and payment. It found that Wexford, not the Department, exercised primary control over the plaintiff’s employment, training, pay, and discipline. The court held that the Department of Corrections was not a joint employer under Title VII and thus could not be held liable for the alleged discrimination. The judgment in favor of the Department was affirmed. View "Stokes v. Illinois Department of Corrections" on Justia Law

Arkeyo LLC v Saggezza, Inc.

2026-07-30T12:00:46-08:00

Two software development companies became involved in a dispute after a UK bank, Metro Bank PLC, hired one company, Arkeyo LLC, to create software for its coin-counting machines. Years later, as Arkeyo’s product became outdated, Metro Bank engaged Saggezza UK (a subsidiary of Saggezza, Inc.) to build replacement software. During development, Metro Bank provided Saggezza with an Arkeyo-operated touchscreen computer for reference. Arkeyo later alleged that Saggezza, Inc. infringed its copyrights and trade secrets, interfered with its contract and business relationship with Metro Bank, and converted Arkeyo’s property. The United States District Court for the Northern District of Illinois granted summary judgment for Saggezza, Inc. on all claims, ruling that Arkeyo did not show Saggezza, Inc. was responsible for the alleged infringement or tortious acts—these, if they occurred, were committed by Saggezza UK, which was not a defendant. The district court also denied Arkeyo’s motions for sanctions and for reconsideration based on purportedly new evidence, and it awarded attorney’s fees to Saggezza, Inc. under federal statutes. The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s decisions. The appellate court held that Arkeyo’s copyright claims failed because there was no evidence of copying. The trade secret claims failed due to Arkeyo’s public disclosure of its software and the generic nature of the alleged secrets. The tortious interference claims were rejected because Saggezza’s competitive conduct was not “wrongful” under Illinois law, and the conversion claim failed since Arkeyo did not own or demand the property. The appellate court also affirmed the denial of sanctions, the denial of reconsideration, and the award of attorney’s fees. View "Arkeyo LLC v Saggezza, Inc." on Justia Law

Sykes v Experian Information Solutions, Inc.

2026-07-30T12:00:46-08:00

In this case, the plaintiff executed a deed in lieu of foreclosure on her home in 2016 after defaulting on her mortgage, and subsequently received a Chapter 13 bankruptcy discharge in 2018. When she reviewed her credit report in 2022, the report stated that she had both a bankruptcy discharge and an outstanding balance on her mortgage account, along with a balloon payment due in the future. She argued that this combination of information was inaccurate or misleading, given her bankruptcy discharge and the deed in lieu of foreclosure. The United States District Court for the Northern District of Illinois dismissed her complaint. The district court determined that her claim depended on resolving legal questions—specifically, whether her mortgage was discharged in bankruptcy and the effect of the deed in lieu of foreclosure on her debt status. The court found that these were legal issues and that the Fair Credit Reporting Act (FCRA) does not require a consumer reporting agency to resolve such questions. Therefore, the court concluded that she failed to allege a factual inaccuracy that could support a claim under the FCRA. The United States Court of Appeals for the Seventh Circuit reviewed the dismissal de novo. It affirmed the lower court’s judgment, holding that the FCRA does not obligate credit reporting agencies to make legal determinations regarding the discharge status or enforceability of debts. The court reasoned that the alleged inaccuracy was not objectively apparent from the records available to the credit reporting agency, and resolving it would require legal analysis beyond the agency’s competency. Therefore, the plaintiff’s claim could not proceed, and the district court's dismissal was affirmed. View "Sykes v Experian Information Solutions, Inc." on Justia Law

Rojas v Olson

2026-07-30T11:30:55-08:00

After entering the United States in 2018 without inspection, Jaciel Cirrus Rojas, a Mexican national, was arrested by the Department of Homeland Security (DHS) in 2025. Initially, DHS detained him under 8 U.S.C. § 1226, and an immigration judge found he was neither a danger to the community nor a flight risk, ordering his release on bond pending removal. However, DHS changed its position based on new agency guidance, asserting that Rojas should instead be detained under 8 U.S.C. § 1225(b)(2)(A), which mandates detention without bond for certain “applicants for admission.” Rojas sought asylum, withholding of removal, and protection under the Convention Against Torture. DHS appealed the bond order to the Board of Immigration Appeals (BIA), which adopted the agency’s new interpretation and reversed the immigration judge’s bond order. Rojas remained in custody as DHS stayed the bond order pending appeal. He then filed a petition for a writ of habeas corpus in the United States District Court for the Eastern District of Wisconsin. The district court agreed with DHS’s interpretation and denied the habeas petition, concluding Rojas must be detained pending his removal proceedings. Rojas appealed this decision. The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and first found that the appeal was not moot, as DHS had stated its intention to re-detain Rojas if the BIA reversed his bond release. The court then held that Section 1225(b)(2)(A) applies only to “applicants for admission” who are also “seeking admission,” interpreting “seeking admission” according to its ordinary meaning. Because Rojas did not seek admission but applied for forms of relief that do not constitute admission, the court ruled he is not subject to mandatory detention under Section 1225(b)(2)(A). Instead, he falls under Section 1226 and is eligible for a bond hearing. The Seventh Circuit reversed the district court’s denial of habeas relief and remanded with instructions to grant the writ. View "Rojas v Olson" on Justia Law

Bad River Band of the Lake Superior Tribe of Chippewa v Enbridge Energy Company, Inc.

2026-07-30T11:01:02-08:00

A company operates a pipeline transporting oil and natural gas liquids between the United States and Canada. A portion of this pipeline crosses twelve miles of land within a Native American reservation in northern Wisconsin. In 2013, the company’s rights-of-way over certain parcels of reservation land expired. During the intervening years, the tribal band acquired ownership interests in a number of these parcels. The company continued to operate the pipeline without securing the tribal band’s renewed consent for the necessary easements. Following a breakdown in negotiations, the tribal band filed suit, alleging trespass and public nuisance. The band also pointed to the risk of a pipeline rupture near a river bend where erosion threatened pipeline safety. The United States District Court for the Western District of Wisconsin granted summary judgment for the tribal band on its trespass and unjust enrichment claims, and against the company on its breach-of-contract counterclaim. After a bench trial, the district court awarded the band restitution for past trespass, ordered future disgorgement of profits, and issued an injunction requiring the company to cease operations across the affected parcels within three years and to implement a monitoring and shutdown protocol to abate the alleged nuisance. Both parties appealed; the district court stayed the shutdown portion of the injunction while the appeal was pending. The United States Court of Appeals for the Seventh Circuit affirmed the finding that the company was trespassing on the parcels at issue and that restitution and injunctive relief are appropriate remedies. However, the court vacated the district court’s restitution calculation and the three-year shutdown deadline, remanding for a new determination of remedies that accounts for the public interest and ongoing pipeline reroute efforts. The court also held that federal statutory law displaced the band’s federal common law nuisance claim and vacated the related injunction. View "Bad River Band of the Lake Superior Tribe of Chippewa v Enbridge Energy Company, Inc." on Justia Law

Joliet Avionics, Inc. v City of Aurora

2026-07-29T12:30:58-08:00

A company that operated as a fixed-base operator at a municipal airport sued the city that owns and operates the airport. The company alleged that the city provided more favorable lease terms and selectively excused certain regulatory requirements for a competing operator, thereby disadvantaging the plaintiff. The city’s leases with the plaintiff and with its competitor differed in several respects, including rent abatement periods, required capital investments, and compliance with fuel storage and insurance requirements. The plaintiff argued that these differences, along with the city’s alleged failure to strictly enforce its own policies and federal grant assurances, constituted both an equal protection violation under a “class-of-one” theory and a breach of contract. The lawsuit was originally filed in Illinois state court, but the city removed it to the United States District Court for the Northern District of Illinois. The plaintiff amended its complaint to drop claims against the competitor and proceeded against the city for breach of contract and equal protection violations. After discovery, both sides moved for summary judgment. The district court granted summary judgment for the city on both claims, finding that the class-of-one theory did not apply in the context of government contracting and that the contractual documents did not incorporate the policies or grant assurances as enforceable obligations. On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The appellate court held that a class-of-one claim under the Equal Protection Clause is not available where a company challenges the terms of its lease or its competitor’s treatment under a different lease, absent any class-based discrimination. The court also held that the city’s policy and grant assurances were not incorporated into the plaintiff’s lease as enforceable contract terms, nor did the law provide a private right to enforce them in this context. The court affirmed the district court’s summary judgment in favor of the city. View "Joliet Avionics, Inc. v City of Aurora" on Justia Law

Richardson v Northwestern Memorial Healthcare

2026-07-29T12:01:04-08:00

A neurosurgeon, age 75 at the time of hire, was employed by a physician group affiliated with two hospitals. He worked primarily as an assistant to another neurosurgeon, with responsibilities and compensation more in line with advanced practice professionals (APPs) than with other neurosurgeons, and did not independently cover on-call duties at both hospitals. Over time, the physician group moved toward a staffing model that relied more on APPs and expected neurosurgeons to independently manage full surgical and on-call responsibilities. During the onset of the COVID-19 pandemic, the neurosurgeon was required to work from home, with comments from supervisors referencing his age and vulnerability to COVID-19. Several months later, he was informed his employment would be terminated, with the group citing operational changes and a desire to hire a neurosurgeon able to fully cover both hospitals. The United States District Court for the Northern District of Illinois, Eastern Division, reviewed the case after the neurosurgeon brought suit alleging age discrimination under the Age Discrimination in Employment Act (ADEA). The district court granted summary judgment for the employer, determining that no reasonable jury could find in favor of the plaintiff. The court found the employer’s stated reasons for termination were not pretextual and that evidence did not support a causal link between age and the termination. The United States Court of Appeals for the Seventh Circuit affirmed the district court’s grant of summary judgment. The court held that, even under the correct “but-for” causation standard required by Gross v. FBL Financial Services, Inc., the record did not contain sufficient evidence for a reasonable jury to find that age was the but-for cause of the termination. The court concluded that the employer’s nondiscriminatory reasons for termination were supported by the record, and no inference of age discrimination arose from the available evidence. View "Richardson v Northwestern Memorial Healthcare" on Justia Law

USA v Randle

2026-07-29T11:31:03-08:00

Police in Illinois used a confidential informant to arrange a controlled purchase of methamphetamine involving the defendant at a hotel near Chicago. The informant met the defendant, facilitated the transaction, and provided police with a sample of the drugs. The following day, officers observed the defendant leave the hotel, place a suitcase in his car, and drive away. Shortly thereafter, state troopers conducted a traffic stop of the vehicle. During the stop, a canine unit alerted to the presence of drugs, and a subsequent search uncovered nearly three pounds of methamphetamine in the trunk. The defendant was indicted for possession with intent to distribute methamphetamine. In the United States District Court for the Central District of Illinois, the defendant moved to suppress the drug evidence, arguing the stop and search violated the Fourth Amendment. He also sought disclosure of the confidential informant’s identity and production of the grand jury transcript, claiming both were necessary for his defense. After an evidentiary hearing, the district court denied all three motions. The court held that the search was justified under the automobile exception based on probable cause from the controlled buy, and that the stop and search did not violate constitutional standards. It further concluded that the defendant had not sufficiently demonstrated a need for the informant’s identity or the grand jury transcript. The defendant then entered a conditional guilty plea, reserving his right to appeal these rulings. The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s decisions. The appellate court held that police had probable cause to search the defendant’s car under the automobile exception, independent of the validity of the traffic stop and dog sniff. Additionally, the court found no abuse of discretion in denying the motions for disclosure of the informant’s identity and the grand jury transcript, as the defendant failed to show a particularized need for either. View "USA v Randle" on Justia Law

Kamberos v. Kutrubis

2026-07-29T08:30:46-08:00

Lambros J. Kutrubis held a life insurance policy, originally naming the trustee of his trust as the beneficiary. As his health declined, he sought to change the beneficiary to his ex-wife, Betty Stokes, and his adopted son, John Kutrubis. Lambros dictated and signed a letter requesting this change, with two witnesses and a notary present. At his instruction, a friend mailed the letter to the insurer, Banner Life Insurance Company. After Lambros’s death, Banner had no record of receiving the letter before his death. Betty and John claimed the proceeds based on the letter, while Eugenia Kamberos, Lambros’s sister and trustee of the trust, also claimed the funds. Banner initiated an interpleader action to determine the rightful recipient. The United States District Court for the Northern District of Illinois, Eastern Division, handled the interpleader. Betty and John moved for summary judgment, submitting affidavits supporting Lambros’s intent and actions. Eugenia responded with a brief but failed to file a proper response to their statement of facts as required by local rules. The district court deemed Betty and John’s facts admitted due to this noncompliance and granted summary judgment in their favor, finding that Lambros substantially complied with the policy’s beneficiary change procedures. Eugenia appealed, challenging the district court’s evidentiary decisions and the grant of summary judgment. The United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The appellate court held that the district court acted within its discretion in deeming facts admitted due to Eugenia’s procedural noncompliance. It concluded that Lambros had substantially complied with the policy requirements to change the beneficiary, as evidenced by his clear intent and concrete steps. The court also found that, apart from the affidavit of an interested party (Betty), the admissible evidence sufficiently supported summary judgment in favor of Betty and John. View "Kamberos v. Kutrubis" on Justia Law

Abdullah v Mead Johnson & Company LLC

2026-07-28T11:30:58-08:00

Several parents whose premature infants developed necrotizing enterocolitis (NEC) after being fed cow’s milk-based formula at Pennsylvania Hospital sued the manufacturers of the formula, as well as the hospital, in Pennsylvania state court. The parents alleged that the manufacturers’ products caused NEC and that the hospital failed to warn of the risks and implement policies to protect patients. Some plaintiffs were Pennsylvania citizens and others from New Jersey. The hospital and its related entities were named as defendants, and the claims against them were based on state law. After the lawsuits were filed, the manufacturers removed the cases to federal court. The United States District Court for the Eastern District of Pennsylvania transferred the cases to a multidistrict litigation proceeding in the Northern District of Illinois. The plaintiffs’ initial motion to remand was granted after the district court found that the claims against the hospital were potentially viable, defeating removal on diversity grounds. The cases returned to Pennsylvania state court, where discovery proceeded and the hospital was later dismissed with prejudice after the state court sustained preliminary objections. The plaintiffs did not immediately appeal. The manufacturers then removed the cases a second time, arguing that the hospital had been fraudulently joined solely to defeat diversity jurisdiction. The district court denied the plaintiffs’ motion to remand, this time concluding that the plaintiffs’ lack of active pursuit of claims against the hospital showed “no real intention in good faith to prosecute the action,” amounting to fraudulent joinder. On interlocutory appeal, the United States Court of Appeals for the Seventh Circuit reversed. The Seventh Circuit held that fraudulent joinder exists only where a plaintiff makes false jurisdictional allegations or has no chance of success against the non-diverse defendant, taking all facts and law in the plaintiff’s favor. The court held that the plaintiffs’ litigation conduct and subjective intent are not proper bases for finding fraudulent joinder. The case was remanded for further proceedings. View "Abdullah v Mead Johnson & Company LLC" on Justia Law

Franco v Chobani, LLC

2026-07-27T13:30:48-08:00

Jason and Abigail Franco purchased a yogurt product marketed as “sugar free” by Chobani, LLC. The product, however, contained four grams per serving of allulose, a naturally occurring sweetener. The Francos alleged that Chobani’s labeling was deceptive and violated various state consumer protection laws. Their claims depended on whether allulose is considered a “sugar” under federal regulations; if so, Chobani’s labeling would violate federal standards, and the state-law claims could proceed. If not, the Federal Food, Drug, and Cosmetic Act (FDCA) would preempt the action. The United States District Court for the Northern District of Illinois reviewed Chobani’s motion to dismiss under Rule 12(b)(6), focusing on the issue of preemption. The court deferred to FDA enforcement guidance that excluded allulose from “total sugars,” found that the Francos’ claims were preempted by federal law, and dismissed the case. On appeal, the United States Court of Appeals for the Seventh Circuit applied de novo review. The court received input from the FDA, which clarified that the relevant regulation unambiguously includes all monosaccharides—including allulose—in the definition of “total sugars.” The court found the FDA’s interpretation persuasive and concluded that the regulation’s definition of “total sugars” encompasses allulose. As a result, the Francos’ claims, which sought to enforce requirements identical to federal standards, were not preempted. The Seventh Circuit also held that the Francos plausibly alleged consumer deception, as the complaint claimed Chobani labeled its product “sugar free” despite containing allulose. The court reversed the district court’s dismissal and allowed the Francos’ suit to proceed. View "Franco v Chobani, LLC" on Justia Law

Felton v Johnson

2026-07-27T13:00:47-08:00

A correctional officer with almost nineteen years of service was terminated by the state corrections department after he disclosed information about an upcoming search (“shakedown”) to his son, who was incarcerated at a different facility. The department conducted an investigation following a recorded phone call and statements gathered from both the officer and his son. The officer’s son allegedly boasted about receiving advance notice of the search, while the officer admitted in the investigation that he inadvertently shared information. After the investigation, the officer was fired for violating departmental policy. The officer attempted to appeal his termination, but filed his grievance with the wrong agency and did not follow up for over two years. The United States District Court for the Eastern District of Wisconsin dismissed the son’s First Amendment retaliation claim at the screening stage and later granted summary judgment in favor of the corrections department on the officer’s First Amendment retaliation and Fourteenth Amendment procedural due process claims. The district court determined that the officer’s speech was not protected because it did not address a matter of public concern, and that adequate pre- and post-termination procedures were available to the officer, despite his procedural missteps. The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decisions. The appellate court held that the officer’s statement about the shakedown was not protected speech under the First Amendment, as it was private and not of public concern. It also found that the officer received sufficient notice and opportunity to respond before termination, and that adequate avenues for post-termination review were available, even if he failed to properly use them. The court further concluded that the son’s claim did not state a constitutional violation. The district court’s dismissal and summary judgment orders were affirmed. View "Felton v Johnson" on Justia Law

Lutz v Froedtert Health, Inc.

2026-07-27T12:00:46-08:00

The plaintiff worked as a Sterile Processing Technician for the defendant, a health system, and was compensated with a base hourly wage, shift differentials, weekend differentials, extra pay for additional hours, and bonuses for on-call time. The dispute centered on how overtime and holiday pay were calculated. The defendant included shift and weekend differentials and extra pay in the regular rate calculation, but excluded holiday premiums. The plaintiff, representing a certified class, alleged that the defendant’s method improperly credited regular-rate compensation toward overtime premiums and wrongly excluded holiday pay from the regular rate, in violation of the Fair Labor Standards Act (FLSA) and Wisconsin law. The United States District Court for the Eastern District of Wisconsin granted summary judgment to the defendant on all class-wide claims. The court found that the defendant’s approach to overtime calculations—using total remuneration (excluding statutory exclusions) divided by total hours worked, and then applying a 0.5 multiplier to the regular rate for overtime hours—was consistent with federal and state law. The court also concluded that statutory exclusions in § 207(e)(6) of the FLSA permitted the exclusion of holiday premiums from the regular rate. The plaintiff’s motion for reconsideration was denied, and the case was dismissed with prejudice. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the summary judgment de novo. The court held that the defendant’s methodologies for calculating overtime and excluding holiday premiums complied with both the FLSA and Wisconsin law. The court affirmed the district court’s judgment and denied the plaintiff’s request to certify a question to the Wisconsin Supreme Court regarding holiday pay exclusions. The district court’s decisions granting summary judgment and denying reconsideration were affirmed. View "Lutz v Froedtert Health, Inc." on Justia Law

USA v Dorfman

2026-07-27T11:30:47-08:00

The case concerns the owner and CEO of a telemarketing company that sold limited indemnity healthcare insurance plans, which provided fewer benefits than traditional health insurance. The CEO, along with other executives, instructed sales employees to use deceptive and misleading scripts to sell these plans, resulting in customers being misled about the scope of coverage. The government alleged that these practices were designed to create the false impression that customers were purchasing more comprehensive health insurance than they actually received. The case was first tried in the United States District Court for the Southern District of Illinois. One executive pleaded guilty and testified against the CEO and another defendant, who were tried before a jury. After an eleven-day trial, the jury convicted both remaining defendants on all counts, including conspiracy to commit wire fraud, wire fraud, and mail fraud. The CEO moved for acquittal or a new trial, but the district court denied those motions and sentenced him to 300 months imprisonment on the conspiracy count and 240 months on the other counts, with all terms to be served concurrently. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed several challenges to the conviction. The court held that the jury instructions on “scheme to defraud” accurately reflected the law, clarifying that actual falsity is not required and that misleading or deceptive statements, including omissions or half-truths, can support a conviction under the relevant statutes. The court also found no plain error in the admission and use of a training video exhibit during jury deliberations, and rejected claims of constructive amendment and the need for a specific unanimity instruction. The Seventh Circuit affirmed the district court’s judgment. View "USA v Dorfman" on Justia Law

Mar v Abbott Laboratories

2026-07-24T13:30:48-08:00

A premature infant was born in West Virginia in 2014 and, after initially being fed her mother’s milk, was switched to a cow’s-milk-based infant formula manufactured by Abbott Laboratories when her mother could no longer produce usable breast milk and no donor milk was available. The hospital, following policy, did not allow sharing of untested breast milk. Shortly after being fed the formula, the infant was diagnosed with necrotizing enterocolitis (NEC) and died the next day. The infant’s mother alleged that Abbott failed to adequately warn about the risks of NEC associated with its formula. The mother brought suit in the United States District Court for the Northern District of Illinois, Eastern Division, as part of a multidistrict litigation. After discovery, the district court granted summary judgment for Abbott. The court found that the plaintiff had not shown a feasible alternative design for the formula and, on the failure-to-warn claim, concluded there was insufficient evidence that a different warning would have prevented the infant’s death. The court also denied a Rule 59(e) motion to reconsider, as the plaintiff’s new witnesses were available during discovery. The United States Court of Appeals for the Seventh Circuit reviewed the case. It affirmed the district court’s grant of summary judgment, holding that the plaintiff had not provided sufficient evidence that an alternative warning would have changed the outcome, given that the hospital had no donor milk and enforced a policy against sharing untested milk. The court also affirmed the denial of the Rule 59(e) motion, finding no abuse of discretion because the proposed new evidence was not newly discovered. The judgment of the district court was affirmed. View "Mar v Abbott Laboratories" on Justia Law

USA v Fung

2026-07-24T11:30:46-08:00

A licensed podiatrist in Illinois, holding a DEA registration, was investigated for his opioid prescription practices. After an undercover operation involving agents posing as patients, he was indicted on 74 counts for unlawfully prescribing controlled substances. The indictment included prescriptions written for undercover agents and several patients, with each count corresponding to a specific prescription. At trial, the evidence focused on a single undercover visit where the agent explicitly stated she was not in pain but only had discomfort from work. Despite this, the doctor prescribed her 90 hydrocodone pills without any medical examination, diagnosis, or documentation. A jury in the United States District Court for the Northern District of Illinois, Eastern Division, found the doctor not guilty on 73 counts but convicted him on the count related to prescribing opioids to the undercover agent who reported only discomfort. The district court sentenced him to six months’ incarceration, three years of supervised release, and imposed a $50,000 fine. The defendant challenged the sufficiency of the evidence, certain evidentiary rulings, the denial of his motion for a mistrial, and the imposition of the fine. The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the district court did not abuse its discretion in admitting lay testimony from a pharmacist, as it was limited to personal observations and did not constitute expert opinion. The court also held there was no error in denying a mistrial based on a stray witness remark, as it was isolated and unrelated to the count of conviction. The Seventh Circuit found the evidence sufficient to support the conviction and concluded that the district court properly considered the relevant factors in imposing the fine. The conviction and sentence were affirmed. View "USA v Fung" on Justia Law

Passwater v. Pretorius

2026-07-23T14:00:46-08:00

An individual incarcerated at an Indiana correctional facility, who had a well-documented history of paranoid schizophrenia, experienced a significant mental health crisis after his medication regimen was altered. While on constant suicide watch due to suicidal ideation, he received an emergency dose of psychotropic medication ordered remotely by the facility’s psychiatrist, but no post-administration monitoring occurred. The medication worsened his psychosis, leading to severe self-harm, including blinding and genital mutilation. Monitoring of suicidal inmates was partly conducted by trained inmate “suicide companions,” who were required to maintain constant, unobstructed observation. At the time of the incident, the assigned suicide companion was seated and failed to observe the self-harm events. After the incident, the plaintiff brought a suit under 42 U.S.C. § 1983 against the remote psychiatrist and the deputy warden. The claims alleged deliberate indifference to serious medical needs in violation of the Eighth Amendment—specifically, that the psychiatrist provided no follow-up care after the emergency medication, and that the deputy warden failed to address systemic lapses in the suicide companion monitoring policy. The United States District Court for the Southern District of Indiana granted summary judgment in favor of the defendants. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court determined there was insufficient evidence to support a finding that the psychiatrist’s actions constituted deliberate indifference, as the conduct did not rise to the level where “no minimally competent professional would have so responded.” Regarding the deputy warden, the court found that although there was evidence of policy noncompliance, proximate causation was lacking because the suicide companion’s own failure to follow instructions was a superseding cause of the injuries. Accordingly, the Seventh Circuit affirmed the district court’s grant of summary judgment for both defendants. View "Passwater v. Pretorius" on Justia Law

USA v Doss

2026-07-23T12:31:08-08:00

The defendant was convicted after pleading guilty to being a felon in possession of a firearm, in violation of federal law. His prior criminal history included a 2017 Indiana felony conviction for sexual battery under Indiana Code § 35-42-4-8(a)(2), which criminalizes nonconsensual sexual touching when the victim is unaware that the touching is occurring. At his federal sentencing, the Presentence Investigation Report classified this conviction as a “crime of violence” under the United States Sentencing Guidelines, leading to an enhanced base offense level. The defendant did not object to this classification at the time of sentencing. The United States District Court for the Northern District of Indiana, Hammond Division, adopted the recommendations in the Presentence Investigation Report, applied the “crime of violence” enhancement, and imposed a sentence of 41 months’ imprisonment followed by two years of supervised release. The defendant appealed, arguing for the first time that his prior sexual battery conviction did not qualify as a “crime of violence” under the relevant Guideline and requested resentencing. The United States Court of Appeals for the Seventh Circuit reviewed whether the district court erred in classifying the Indiana sexual battery conviction as a “crime of violence.” Applying the categorical and modified categorical approaches, the appellate court determined that the statute of conviction is a “forcible sex offense” as defined by the Guidelines, because it criminalizes nonconsensual sexual contact and the absence of valid consent is sufficient. The court held that such an offense qualifies as a “crime of violence” under the Sentencing Guidelines. Finding no error in the district court’s application of the enhancement, the Seventh Circuit affirmed the sentence. View "USA v Doss" on Justia Law

Pratt v Wisconsin Aluminum Foundry

2026-07-23T12:00:54-08:00

A human resources manager at a Wisconsin aluminum foundry reported multiple incidents of discrimination and harassment involving both herself and other employees. She relayed complaints of inappropriate and sexist behavior by male managers, including offensive language and conduct directed at women and minorities. After raising these concerns to her supervisor and reporting her own experiences with sexist insults, she received a negative performance review citing divisiveness and lack of trust. She then complained about possible retaliation and was terminated shortly thereafter. Her starting salary as HR manager was lower than that of a subsequent male hire for a related managerial position, although their exact responsibilities differed. The United States District Court for the Eastern District of Wisconsin dismissed her hostile work environment claim at the pleading stage. After discovery, the court granted summary judgment for the employer on the remaining claims: sex discrimination, pay discrimination, and retaliation. The court found that she had not met the performance expectations required for a prima facie case of sex discrimination, failed to identify a sufficiently close comparator for pay discrimination, and had not engaged in protected activity for retaliation. She appealed the summary judgment rulings except for the hostile work environment dismissal. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s grant of summary judgment de novo. The court held that the plaintiff had offered sufficient evidence of sex discrimination and retaliation under Title VII for a reasonable jury to find in her favor, particularly considering the discriminatory workplace culture, questionable justifications for her termination, and the timing of her firing after protected activity. However, the court affirmed summary judgment for the employer on the pay discrimination claim due to insufficient evidence regarding comparators. The case was remanded for trial on the sex discrimination and retaliation claims. View "Pratt v Wisconsin Aluminum Foundry" on Justia Law

BBLI Edison, LLC v. City of Chicago

2026-07-22T08:00:46-08:00

A property owner acquired a Chicago apartment building through foreclosure in February 2024, after the city’s ordinance requiring new owners of foreclosed rental properties to negotiate new 12-month leases with existing tenants and provide a $10,600 relocation fee to those who decline new leases went into effect. Upon acquisition, the owner notified more than 220 tenants of their rights, and at least five tenants declined to sign new leases, requesting the relocation assistance. The property owner filed suit against the City of Chicago, claiming that the ordinance’s relocation fee requirement constituted an unconstitutional taking under the Fifth Amendment. The United States District Court for the Northern District of Illinois reviewed the owner’s complaint, which sought to enjoin enforcement of the ordinance. The court dismissed the complaint, concluding that the ordinance did not violate the Constitution, and the owner declined to amend its pleading before appealing. The United States Court of Appeals for the Seventh Circuit considered whether the ordinance’s relocation assistance requirement amounted to a physical or regulatory taking, or imposed an unconstitutional condition. The court held that the ordinance, which regulates the landlord-tenant relationship and imposes financial obligations similar to permissible rent control schemes, is not a per se physical taking. Applying the Penn Central factors, the court found no regulatory taking, noting the property owner’s lack of allegations regarding economic infeasibility and that the acquisition occurred after the ordinance’s enactment. The court also determined that the unconstitutional conditions doctrine did not apply, as the ordinance directly mandates a fee rather than leveraging a permitting process. The Seventh Circuit affirmed the district court’s dismissal, holding that the ordinance does not violate the Takings Clause. View "BBLI Edison, LLC v. City of Chicago" on Justia Law

USA v Bridges

2026-07-21T13:00:48-08:00

During the summer of 2016, a group led by Narcellus Taylor targeted consumer electronics stores in the Rockford, Illinois area for robberies. Taylor and his cousin Brenda Price organized the robberies, assigning roles to participants and dividing stolen goods among those who fulfilled their tasks. Price, who was dating Katrail Bridges, testified that Bridges participated in two specific robberies: a Best Buy in DeKalb and a Simply Mac store in Cherry Valley, both in December 2016. Surveillance footage and testimony placed Bridges at both locations, though in the Best Buy incident, Bridges left early and was not paid because he did not complete his assigned role. In 2018, Bridges was indicted on two counts of Hobbs Act robbery and one count of conspiracy to commit Hobbs Act robbery. The United States District Court for the Northern District of Illinois, Western Division, rejected Bridges’s attempted guilty plea due to his denial of involvement in the Best Buy robbery during the plea colloquy. At trial, Bridges was acquitted by a jury on both robbery counts but convicted on the conspiracy count. The verdict did not specify which robberies the conspiracy conviction related to. At sentencing, the district court applied a Sentencing Guidelines enhancement under U.S.S.G. § 1B1.2(d), treating Bridges’s conspiracy conviction as if he had been convicted of conspiracy for each robbery. Bridges argued that the enhancement required findings beyond a reasonable doubt for each object offense, citing circuit precedent and the Guideline’s application notes. The district court acknowledged the correct legal standard but failed to make explicit or implicit findings on the record that Bridges conspired to commit either robbery beyond a reasonable doubt. The United States Court of Appeals for the Seventh Circuit held that the district court erred by not making the required findings under the reasonable-doubt standard before applying the § 1B1.2(d) enhancement. The court vacated Bridges’s sentence and remanded the case for resentencing. View "USA v Bridges" on Justia Law

Schukar v Kenosha County

2026-07-21T12:00:56-08:00

During widespread civil unrest in Kenosha County, Wisconsin, following the police shooting of Jacob Blake, two photojournalists, Alyssa Schukar and Scott Olson, were documenting protests outside the Kenosha County Courthouse. The protest escalated, with some participants engaging in violent behavior and law enforcement responding with crowd-control measures, including foam baton rounds. Schukar and Olson were struck and injured by these rounds while covering the protest, though they did not observe who fired at them. Neither wore visible press credentials, but both carried cameras and equipment. Schukar and Olson brought suit in the United States District Court for the Eastern District of Wisconsin against two officers, Deputy Steven Robakowski and Officer Ryan Jacobs, alleging violations of their First Amendment rights through retaliatory targeting and Fourth Amendment rights through excessive force. The district court granted summary judgment for the officers. It found no evidence of retaliatory animus and concluded that if the officers struck the journalists, it was accidental and not a violation of their rights. The court also determined that an accidental use of force against unintended targets did not constitute a seizure under the Fourth Amendment. The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The Seventh Circuit held that the plaintiffs failed to present evidence showing the officers intentionally targeted them because of their protected activity. It further held that, given the unsettled legal landscape, it was not clearly established in 2020 that an officer’s intentional deployment of less-than-lethal munitions that accidentally struck an unintended target constituted a Fourth Amendment seizure. As a result, the court affirmed summary judgment and held that the officers were entitled to qualified immunity. View "Schukar v Kenosha County" on Justia Law

Friend v. City of Decatur, Illinois

2026-07-21T08:00:47-08:00

Charles Friend was arrested for domestic battery after his ex-girlfriend, Jacqueline Hathaway, was found at a hospital with injuries and reported to various individuals, including her daughter, paramedics, and police officers, that Friend had beaten her two days earlier. Hathaway’s recounting of events included inconsistencies and recantations, and her daughter and a colleague described a history of altercations between Hathaway and Friend, though neither could confirm what happened on this occasion. Friend later provided evidence, including doorbell camera footage and phone records, suggesting he had not visited Hathaway at the time she claimed. Nevertheless, the police arrested him at his mother’s home, following an invitation to meet there and after being welcomed inside by Friend’s mother. The United States District Court for the Central District of Illinois, with a magistrate judge presiding by consent, granted summary judgment in favor of the officers and the City of Decatur on Friend’s claims under 42 U.S.C. § 1983. Friend alleged arrest without probable cause and without a warrant, as well as municipal liability under Monell v. Department of Social Services, 436 U.S. 658 (1978). The district court found that the officers had probable cause and that the warrantless entry was justified by consent. Friend’s post-judgment motion under Rule 59(e) was denied. The United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The Seventh Circuit held that the officers had probable cause to arrest Friend based on the totality of the circumstances, including Hathaway’s statements and injuries, and the corroborating history of domestic incidents. The court also held that the warrantless arrest was lawful due to the voluntary consent given by Friend and his mother for the officers’ entry. With no constitutional violation established, the Monell claim against the City also failed. View "Friend v. City of Decatur, Illinois" on Justia Law

USA v. Mendoza-Rubio

2026-07-21T07:01:11-08:00

Between December 2020 and April 2021, a licensed accountant from Mexico participated in a complex conspiracy to launder over $5.1 million in criminal proceeds. She acted as a broker, converting U.S. cash to Bitcoin for a fee, and coordinated with multiple coconspirators who picked up, deposited, and tracked cash, and purchased Bitcoin for clients. Her involvement was central to directing and managing the steps of the operation, including overseeing cash pickups, maintaining ledgers, directing the conversion of funds, and serving as the sole contact with clients for Bitcoin wallet information. The scheme came to light following an investigation into a theft from a Wisconsin business. After pleading guilty to conspiracy to commit money laundering, she entered a binding plea agreement in the United States District Court for the Western District of Wisconsin, limiting her sentence to between three and six and a half years. The initial presentence report did not recommend a sentencing enhancement for a managerial or supervisory role. However, after the government’s objection, the probation office revised the report to include a three-level enhancement under the United States Sentencing Guidelines. The district court adopted this enhancement, finding that she played a managerial role, and sentenced her to 60 months in prison, which was below the calculated guidelines range but within the plea agreement’s bounds. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether the district court erred in applying the managerial enhancement and in failing to address sentencing disparities among coconspirators. The appellate court held that the record supported the enhancement, as she exercised sufficient control and coordination over others. The court further found that the sentence was reasonable and not procedurally flawed, affirming the judgment. View "USA v. Mendoza-Rubio" on Justia Law

USA v. Palma

2026-07-20T10:00:55-08:00

In 2015, Giulio Palma and his friend Graham Kos developed a plan to pool investor funds to purchase and develop luxury properties in Italy, with the aim of reselling them or operating short-term rentals. Palma claimed to have exclusive connections enabling access to discounted properties. Over several years, they raised about $6 million from multiple investors, all of whom believed their funds would be used exclusively for acquiring and developing Italian properties. Contrary to his repeated assurances and the terms of their arrangements, Palma withdrew approximately $2 million for personal use, concealing these actions from investors. These unauthorized transactions were discovered in 2019. The United States District Court for the Northern District of Illinois, Eastern Division, indicted Palma on seven counts of wire fraud under 18 U.S.C. § 1343. Following a jury trial in 2023, Palma was convicted on six counts. He moved for a judgment of acquittal and a new trial, but the district court denied both motions, finding that the evidence overwhelmingly supported the jury’s verdict. The district court then sentenced Palma to 36 months in prison. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the denial of the motion for judgment of acquittal de novo, applying the standard for sufficiency of the evidence. The court held that the evidence was more than sufficient for a rational jury to find that Palma engaged in a scheme to defraud and acted with intent to defraud. The Seventh Circuit affirmed the judgment of the district court, upholding both the conviction and the sentence. View "USA v. Palma" on Justia Law

Arana v. Board of Regents of the University of Wisconsin

2026-07-20T10:00:55-08:00

A freshman student at the University of Wisconsin, Madison alleged that she had been sexually assaulted by another student. Upon receiving her complaint, the university provided her academic accommodations, imposed a no-contact order to separate her from the accused student, and expelled him following a disciplinary process that found him responsible for sexual assault and harassment under the university’s policies. The accused was also acquitted of related criminal charges in state court, after which he petitioned for readmission to the university, citing new evidence that had emerged during his trial. The university’s chancellor reviewed the new information, determined that the preponderance of evidence standard was no longer met for the sexual assault finding, and readmitted him. The university maintained the no-contact order but did not implement additional safety measures for the complainant. The United States District Court for the Western District of Wisconsin granted summary judgment for the university, concluding that the university’s actions did not amount to deliberate indifference under Title IX. A panel of the United States Court of Appeals for the Seventh Circuit initially reversed this decision, but the full court granted rehearing en banc and vacated the panel’s opinion. Reviewing the case en banc, the United States Court of Appeals for the Seventh Circuit held that a school is liable under Title IX for student-on-student harassment only if it responds with deliberate indifference—that is, with conduct clearly unreasonable in light of known circumstances. The court found that the university’s actions, including the prompt issuance and enforcement of a no-contact order, the investigation, and the imposition of discipline, constituted a reasonable response. The court also determined that neither the decision to readmit the accused student nor the refusal to implement additional safety measures amounted to deliberate indifference. Accordingly, the court affirmed the district court’s grant of summary judgment for the university. View "Arana v. Board of Regents of the University of Wisconsin" on Justia Law

Havlik v. University of Chicago

2026-07-20T09:30:59-08:00

A participant in two ERISA-qualified retirement plans at a university sought to change the beneficiary designation shortly before his death, naming trust accounts for his grandchildren as primary beneficiaries and removing his wife as a primary beneficiary. The plan documents required spousal consent for such changes. The participant’s wife, who was still living at the time, had previously executed a Wisconsin statutory power of attorney appointing her son-in-law as her agent. The agent signed the spousal consent form on her behalf, but the power of attorney did not expressly grant authority to waive her spousal survivor annuity rights. The plan recordkeeper rejected the beneficiary change form as deficient, and the participant died soon thereafter. The wife died about a year later. The plaintiffs, including family members and trustees, sought to enforce the beneficiary change, arguing that the power of attorney provided sufficient authority. After the recordkeeper’s rejection, the plaintiffs made a claim for benefits with the university as plan administrator. The university denied the claim, determining that Wisconsin law required a specific grant of authority in the power of attorney to waive spousal survivor benefits, which was absent in this case. The plaintiffs appealed the denial, but the university upheld its decision. Plaintiffs then filed suit in the United States District Court for the Northern District of Illinois, asserting claims under ERISA for benefits, breach of fiduciary duty, and negligence. The district court granted summary judgment for the defendants, concluding the waiver was invalid and finding no merit in the other claims. The United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The Seventh Circuit held that under Wisconsin law, specifically Wis. Stat. § 244.41(1)(f), a power of attorney must expressly grant authority to an agent to waive spousal rights to a joint and survivor annuity. Because the power of attorney did not contain such an express grant, the attempted waiver was invalid, and the plaintiffs’ ERISA claim failed. The court also affirmed dismissal of the fiduciary duty and negligence claims and denied the plaintiffs’ motion to certify a question to the Wisconsin Supreme Court. View "Havlik v. University of Chicago" on Justia Law

USA v. Boltz

2026-07-20T09:01:05-08:00

Andrew Boltz, age 25, met A.S., a 16-year-old, through the website Omegle in early 2020. Their communication continued across various platforms, including Snapchat, and involved frequent daily contact. Boltz repeatedly requested sexually explicit images and videos from A.S., fully aware of her minor status. A.S. testified that she was uncomfortable with these requests but ultimately sent nude photos. Law enforcement was alerted after A.S.’s mother discovered the relationship, leading to Boltz’s arrest. The United States District Court for the Northern District of Illinois, Eastern Division, presided over Boltz’s jury trial on charges including sexual exploitation of a minor. The court made several key evidentiary rulings: it excluded evidence that A.S. had sent explicit photos to other men under Federal Rule of Evidence 412 (the rape shield rule), allowed the government to introduce Rule 404(b) evidence that Boltz had groomed another minor, and permitted A.S.’s mother to testify about A.S.’s vulnerability. After his conviction, Boltz moved for a new trial, arguing the government failed to preserve exculpatory Snapchat messages. The district court denied the motion, finding no bad faith by the government. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed these rulings. The court held that the district court properly excluded evidence of A.S.’s sexual conduct with others under Rule 412, as it was either sexual behavior or predisposition and not central to Boltz’s defense. The court also found that the Rule 404(b) evidence was properly admitted for the non-propensity purpose of establishing Boltz’s identity, due to the distinctive similarities between the incidents. The court further ruled that A.S.’s mother’s testimony was relevant and that the government did not act in bad faith regarding evidence preservation. The Seventh Circuit affirmed the district court’s decision. View "USA v. Boltz" on Justia Law

Hineman v. Chase

2026-07-20T08:30:56-08:00

A man was convicted of first-degree child sexual assault in Wisconsin after a two-day jury trial. The victim, a minor, had a prior relationship with the defendant, who was not his biological father but remained involved in his life. In late 2014, after the defendant cared for the child during the father’s hospitalization, the child’s behavior changed and troubling statements were made, leading to a report to Child Protective Services (CPS). A police investigation followed, and after a forensic interview in August 2015, the child disclosed inappropriate contact by the defendant, who was then charged with sexual assault. The State made various pre-trial disclosures, including a police report summarizing the CPS report, but did not provide the actual CPS report. At trial, the prosecution relied on testimony from the forensic interviewer, the child, the child’s grandmother, and the investigating officer. The defense had access to the police report but did not use it to impeach the officer’s testimony. The defendant testified and denied the allegations. The jury found him guilty, and he was sentenced to twenty-five years. He moved for postconviction relief, arguing suppression of material evidence and ineffective assistance of counsel. The postconviction court denied relief, but the Wisconsin Court of Appeals reversed. The Wisconsin Supreme Court unanimously reinstated the conviction. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s grant of habeas relief de novo, applying the deferential standard required by the Antiterrorism and Effective Death Penalty Act. The Seventh Circuit held that the Wisconsin Supreme Court reasonably applied federal law in finding that the suppressed CPS report was cumulative of evidence already available to the defense and not material, and that trial counsel’s performance did not prejudice the outcome. The Seventh Circuit reversed the district court’s judgment and denied habeas relief. View "Hineman v. Chase" on Justia Law

Elmar Hotel Management, LLC v Unite Here Local 1

2026-07-17T13:00:47-08:00

Several related companies, along with an individual, operated the Inn of Chicago. After purchasing the property, they assumed an existing collective bargaining agreement (CBA) with a labor union. When the City of Chicago approached them to use the Inn to house displaced migrants, the operation resumed, but the employers did not use union members for typical hotel functions. Instead, these tasks were handled by an outside staffing agency and later by another company managed by the same people. The labor union learned of this arrangement, filed grievances alleging violations of the CBA, and submitted the dispute to arbitration. The union also filed an unfair labor practice charge with the National Labor Relations Board, which was consolidated with the arbitration. The United States District Court for the Northern District of Illinois, Eastern Division, reviewed the arbitration award. The arbitrator had found that the Inn was operating as a “hotel” within the meaning of the CBA while housing migrants, that the related companies and individual were a “single employer” under the CBA, and that they violated both the CBA and the National Labor Relations Act by failing to use union employees and failing to provide notice or bargain with the union. The district court confirmed the arbitration award, rejecting the employers’ arguments regarding arbitrability, notice, and authority. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s confirmation of the arbitration award. The court held that the employers were bound by the arbitration because they participated without reserving objections, and the arbitrator’s findings drew from the CBA and issues submitted by the parties. The court found no due process or public policy violation and affirmed the district court’s confirmation of the award. View "Elmar Hotel Management, LLC v Unite Here Local 1" on Justia Law

USA v Carter

2026-07-17T13:00:46-08:00

Robert Carter, convicted of wire fraud, sought compassionate release from his sentence under 18 U.S.C. § 3582(c)(1)(A), citing family caregiving obligations. The United States District Court for the Western District of Wisconsin denied his motion on February 6, 2026. Carter was required to file a notice of appeal within 14 days, but his notice was postmarked February 27 and received March 2, missing the deadline even under the prison-mailbox rule. Following the denial, Carter did not file a motion for extension of time, which would ordinarily be fatal in civil cases under Federal Rule of Appellate Procedure 4(a)(5). However, Rule 4(b)(4), governing criminal cases, allows the district court to extend the time to appeal “with or without motion” for up to 30 days after the deadline. Carter argued that the district judge implicitly granted an extension by docketing his late notice of appeal, but the court found this reasoning unpersuasive, emphasizing that docketing is a ministerial act and does not imply a judicial finding of excusable neglect or good cause. The United States Court of Appeals for the Seventh Circuit reviewed the matter. Adopting the consensus of other circuits, the court held that if a notice of appeal in a criminal case is filed within the 30-day extension window, the appeal should not be dismissed until the district judge has made a finding regarding excusable neglect or good cause, even without a formal motion for extension. Accordingly, the Seventh Circuit suspended further proceedings and remanded the issue to the district court for a determination on whether Carter’s delay was justified. View "USA v Carter" on Justia Law

Rush v GreatBanc Trust Co.

2026-07-17T12:30:46-08:00

Segerdahl Corporation, a direct-mail printing company wholly owned by an employee stock ownership plan (ESOP), was sold to a private equity firm in 2016. Bruce Rush, a senior manager and ESOP shareholder, alleged that the sale was improperly organized and approved for less than the company’s fair market value. He claimed that the Defendants—the ESOP trustee GreatBanc and several Segerdahl Board members—breached their fiduciary duties under ERISA by favoring financial buyers, inadequately marketing the company, and failing to secure a higher sale price. The sale process involved negotiations led by JP Morgan, with only financial buyers considered, culminating in an agreement with ICV Partners for $265 million. The United States District Court for the Northern District of Illinois, Eastern Division, certified a class of ESOP shareholders and denied summary judgment for most claims. After a three-week bench trial, the district court issued a comprehensive opinion finding in favor of Defendants on all counts. The court determined that the Defendants did not intentionally depress the sale price, had obtained the best possible price given Segerdahl’s declining performance, and had fulfilled their fiduciary obligations. The district court also found no prohibited transactions under ERISA and concluded that Rush failed to prove damages, rejecting expert testimony that relied on hypothetical buyers and unsupported valuations. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s legal conclusions de novo and factual findings for clear error. The appellate court affirmed the district court’s judgment, holding that there was no clear error in the findings that Defendants did not breach their fiduciary duties, did not engage in prohibited transactions, and that the sale price reflected fair market value. The district court’s decision was affirmed in full. View "Rush v GreatBanc Trust Co." on Justia Law

Agee v Hickenbottom

2026-07-17T11:30:47-08:00

A mother, Jacqueline, who is an Illinois police officer, and her son John, who lived in Indiana, were the subjects of criminal allegations after a local resident reported that someone at their home pointed a gun at children walking home from school. Three St. John, Indiana police officers responded and gathered witness statements, some of which vaguely described the suspect and referred to a gun that appeared to be a BB or pellet gun. The officers questioned Jacqueline and John, who admitted to handling an airsoft gun but denied aiming it at anyone. Without making arrests, the officers later pursued criminal charges: John was accused of intimidation with a deadly weapon, and Jacqueline was cited for allegedly permitting the discharge of a pellet gun within town limits. Ultimately, the prosecutor declined to pursue John’s charge, and Jacqueline’s citation was dismissed. Jacqueline filed suit in the United States District Court for the Northern District of Indiana, asserting federal claims under 42 U.S.C. § 1983 for malicious prosecution, false arrest, failure to intervene, and abuse of process, along with a state indemnification claim. The district court dismissed the case and denied leave to amend the complaint to add class-of-one equal protection claims, finding them futile because the officers purportedly had probable cause. The United States Court of Appeals for the Seventh Circuit reviewed the case. It affirmed the dismissal of the malicious prosecution, false arrest, failure-to-intervene, abuse-of-process, and municipal claims. However, it held that the district court erred in denying leave to amend to add class-of-one equal protection claims, as the proposed amended complaint did not conclusively establish probable cause and plausibly alleged differential treatment based on animus. The court reversed in part and remanded, allowing the equal protection claims to proceed, and ordered the state indemnification claim dismissed without prejudice. View "Agee v Hickenbottom" on Justia Law

Abayomi v Collins

2026-07-16T13:30:47-08:00

The plaintiff, an African American clinical pharmacist, worked at a Department of Veterans Affairs facility in Illinois. He was the only African American pharmacist at his workplace and was employed on a yearlong probationary period. After receiving a “fully successful” performance review, his new supervisor criticized his productivity, which later improved. The plaintiff filed an internal Equal Employment Opportunity (EEO) complaint alleging race-based disparate treatment and retaliation by his supervisor, referencing racially charged remarks and disparate scrutiny. Weeks after the complaint, the department received anonymous reports of several medication errors allegedly committed by the plaintiff. He admitted to most of these errors in a subsequent investigatory meeting. Days after mediation regarding his EEO complaint, which he voluntarily withdrew, the plaintiff was terminated just before his probationary period ended. The United States District Court for the Northern District of Illinois granted summary judgment for the Department, dismissing both the race discrimination and retaliation claims. The district court found that the plaintiff failed to establish a prima facie case of race discrimination, as there was no evidence he was treated less favorably than similarly situated employees outside his protected class. The court also concluded that the Department’s stated reasons for termination—medication errors—were legitimate and not shown to be pretextual. The retaliation claim was rejected for lack of evidence showing a causal connection between the EEO complaint and his termination. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court’s judgment. The appellate court held that the plaintiff failed to provide evidence that the Department’s stated nondiscriminatory reason for his termination was pretextual or that his protected activity was the but-for cause of his termination. The judgment for the Department was affirmed. View "Abayomi v Collins" on Justia Law

Romero v Corona Investments, LLC

2026-07-16T09:31:21-08:00

Romero owned a home in Chicago but failed to pay property taxes from 2018 to 2021, resulting in Cook County holding a lien on his property. Rather than foreclosing, the county conducted a tax sale, at which Corona Investments acquired a Certificate of Purchase for Romero’s property in November 2021. This certificate gave Corona the right to take title after a waiting period unless Romero redeemed the property by paying the outstanding taxes plus penalty interest. Romero had until October 2024 to redeem, but filed for Chapter 13 bankruptcy one week before the deadline, triggering an automatic stay and preventing Corona from seeking a tax deed. In the United States Bankruptcy Court for the Northern District of Illinois, the judge determined that Corona Investments held a secured claim of $26,134.95 in the bankruptcy proceeding. The bankruptcy court classified Corona's claim as a "tax claim" under 11 U.S.C. § 511(a), which meant that the interest rate on the claim would be governed by applicable nonbankruptcy law. The court found that the relevant rate was 18%, as provided by 35 ILCS 200/21-15 of the Illinois Property Tax Code. The court rejected arguments for applying a lower redemption rate or the rate determined by the "formula approach" from Till v. SCS Credit Corp. The United States Court of Appeals for the Seventh Circuit reviewed the bankruptcy court’s decision. The Seventh Circuit affirmed, holding that a tax sale purchaser’s secured claim qualifies as a “tax claim” under 11 U.S.C. § 511(a), and that the applicable nonbankruptcy law—the Illinois Property Tax Code—provides an 18% annual interest rate for such claims in Cook County. The court also declined to impose sanctions related to briefing errors, concluding they did not materially affect the appeal. View "Romero v Corona Investments, LLC" on Justia Law