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

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

Inendino v Nance-Holt

2026-07-16T09:01:22-08:00

A firefighter with sixteen years of service in the Chicago Fire Department (“CFD”) was terminated after an investigation revealed that he had posted racially offensive and derogatory content on his public Facebook account. He openly identified himself as a CFD firefighter on his page, which included photos in uniform, and his posts targeted Black and Asian Americans, groups served by the CFD. The posts prompted complaints from members of the public, leading to an Office of Inspector General investigation. The investigation concluded that the firefighter’s posts undermined public trust and recommended his dismissal, which the Fire Commissioner approved. The firefighter unsuccessfully challenged his termination through arbitration. He then sued the City of Chicago and two CFD officials in the United States District Court for the Northern District of Illinois, Eastern Division, alleging his termination violated his First Amendment rights and challenging the City’s social media policy as unconstitutionally vague and overbroad. The district court granted summary judgment for the City, holding that the firefighter’s posts were not protected by the First Amendment because they did not address matters of public concern. Alternatively, the court found that, even if the posts did touch on public concern, the City’s interest in departmental efficiency and maintaining public trust outweighed his free speech interests. The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court found that the district court erred in its analysis of public concern, concluding that the posts could be seen as addressing matters of public concern. However, applying the Pickering balancing test, the appellate court held that the City’s interests in preserving public trust, especially given the firefighter’s public identification with the CFD and the nature of his posts, outweighed his speech interests. The court affirmed summary judgment in favor of the City. View "Inendino v Nance-Holt" on Justia Law

USA v. Stapleton

2026-07-16T07:30:47-08:00

The defendant was convicted of possessing methamphetamine with intent to distribute and, after serving his sentence, was released on supervised release in September 2024. Within two months, he failed to attend required drug tests and tested positive for fentanyl and methamphetamine. His probation officer filed a petition to revoke his supervised release, and a warrant was issued. He was later arrested in Minnesota on state charges, convicted of providing false information to an officer, and then transferred to federal custody. The district court initially revoked his supervised release but, at his request, deferred sentencing to allow him to enter a residential drug treatment program. He failed to report to treatment and was again arrested for similar offenses. At a subsequent hearing, the court considered his repeated violations and imposed a 24-month prison sentence followed by four years of supervised release. The United States District Court for the Western District of Wisconsin handled the revocation and sentencing proceedings. The court explained that the sentence aimed to hold the defendant accountable for his violations, protect the community, and promote specific and general deterrence. The court did not refer to punishment for the seriousness of the underlying offense or the need to promote respect for the law. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s actions. The main issue was whether the district court improperly considered retributive factors when imposing the sentence for the supervised release violation. The Seventh Circuit held that the district court did not err, as its reasoning focused on permissible objectives such as deterrence, protection, and rehabilitation, rather than retribution for the underlying offense. The appellate court affirmed the district court’s judgment. View "USA v. Stapleton" on Justia Law

City of Chicago v BP P.L.C.

2026-07-15T14:00:48-08:00

The case involves a lawsuit filed in March 2024 by the City of Chicago against several major fossil fuel companies and a trade association. Chicago alleges the defendants misrepresented the effects of fossil fuel emissions on climate change, leading consumers to use more fossil fuels, which resulted in harm to the city such as increased illness, property damage, and environmental degradation. The city seeks damages only for harm attributable to increased fossil fuel usage due to the alleged misinformation, and specifically excludes claims related to federal property or specialized fuel sales to the federal government. After the complaint was filed in Illinois state court, the defendants removed the case to the United States District Court for the Northern District of Illinois, invoking the federal officer removal statute (28 U.S.C. § 1442(a)(1)). They argued that their work producing and supplying fossil fuels for the federal government brought the case within federal jurisdiction. The district court disagreed, finding the connection between the alleged misconduct and the defendants’ federal work too attenuated, and remanded the case to state court. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s remand order de novo. The Seventh Circuit held that the federal officer removal statute did not support removal here because the defendants’ federal work was not sufficiently connected to Chicago’s claims, which focus on alleged misrepresentations to consumers and resulting non-federal harm. The court noted that the city’s complaint expressly disclaimed injuries related to federal activities, and agreed with the reasoning of other circuits in similar cases. The Seventh Circuit therefore affirmed the district court’s remand order. View "City of Chicago v BP P.L.C." on Justia Law

USA v. Singleton

2026-07-15T07:30:48-08:00

Corrie Singleton, along with his brother and a minor, committed an armed robbery at a Chase Bank in Lansing, Illinois, using a stolen vehicle. Singleton held a loaded firearm to a Brink’s employee’s head during the robbery, while his accomplices emptied cash from the ATM and the armored truck. After fleeing the scene and crashing the getaway car, Singleton and the minor were apprehended by law enforcement, who recovered over $1 million in cash and firearms. Singleton’s brother escaped arrest. A federal grand jury charged Singleton with conspiracy to commit armed robbery, Hobbs Act robbery, and brandishing a firearm during and in relation to a crime of violence. Singleton pled guilty to the latter two charges. The United States District Court for the Northern District of Illinois, Eastern Division, sentenced Singleton in June 2025. The court reviewed the Presentence Investigation Report, which calculated an advisory guidelines range of 219 to 252 months’ imprisonment. Singleton requested a downward departure in light of his youth, lack of criminal history, and potential for rehabilitation, referencing a recent amendment to the Sentencing Guidelines. The government sought a sentence of 204 months. Ultimately, the district court imposed a below-guidelines sentence of 96 months for robbery, followed by the mandatory consecutive 84 months for the firearm charge, totaling 180 months’ imprisonment and four years of supervised release. The court explained its reasoning, referencing Singleton’s mitigating circumstances. On appeal, before the United States Court of Appeals for the Seventh Circuit, Singleton argued that his sentence was procedurally unreasonable because the district court failed to adequately consider his mitigation arguments and explain its reasoning. The Seventh Circuit held that the district court sufficiently addressed Singleton’s principal mitigation arguments and explained its rationale for the below-guidelines sentence. The court affirmed the district court’s judgment. View "USA v. Singleton" on Justia Law

Oak Lawn Respiratory and Rehabilitation Center v Small Business Administration

2026-07-14T12:30:59-08:00

A group of nursing homes under common ownership sought loan forgiveness under the Paycheck Protection Program (PPP), enacted as part of the CARES Act, after receiving loans during the COVID-19 pandemic. The Small Business Administration (SBA) had created the Corporate Group Rule, limiting the total amount of PPP loans eligible for forgiveness to $20 million for all businesses majority-owned, directly or indirectly, by a common parent. Although one of the nursing homes received a loan after the group had surpassed the cap, the SBA refused to forgive amounts exceeding $20 million collectively, leaving the remaining debt with the lenders. After administrative judges upheld the SBA’s application of the Corporate Group Rule, the nursing homes filed suit in the United States District Court for the Northern District of Illinois. The district court granted summary judgment to the SBA, finding the agency’s rule consistent with the statutory grant of discretion and not arbitrary or capricious. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the CARES Act and its incorporation of 15 U.S.C. § 636(a), together with emergency rulemaking authority granted to the SBA, allowed the agency to set aggregate lending limits for corporate groups. The court found that the SBA’s definition of a “corporate group” and its application to the nursing homes was supported by substantial evidence and was not arbitrary or irrational. The court further held that applying the Corporate Group Rule to the nursing homes’ loan forgiveness requests did not constitute impermissible retroactive rulemaking. Accordingly, the Seventh Circuit affirmed the district court’s judgment in favor of the SBA. View "Oak Lawn Respiratory and Rehabilitation Center v Small Business Administration" on Justia Law

Steidinger v Blackstone Medical Services

2026-07-14T09:31:07-08:00

The plaintiffs in this case are individuals who received marketing text messages and phone calls from a medical services company, promoting its home sleep tests. Despite their efforts to stop the communications—such as replying “STOP” to text messages and registering on the National Do-Not-Call Registry—they continued to receive unwanted texts and calls. They filed a consolidated class action complaint seeking monetary, injunctive, and declaratory relief for alleged violations of both the federal Telephone Consumer Protection Act (TCPA), 47 U.S.C. § 227, and the Florida Telephone Solicitation Act. The United States District Court for the Central District of Illinois reviewed the complaint after the defendant moved to dismiss the TCPA claims. The defendant argued that the relevant TCPA provision, § 227(c)(5), only provides a private right of action for unwanted telephone calls, not text messages. The plaintiffs did not argue that their suit could proceed based on calls alone. The district court agreed with the defendant, found that the plaintiffs failed to state a claim under the TCPA because their complaint focused on text messages, and declined to exercise supplemental jurisdiction over the state-law claim, ultimately dismissing the entire suit. The United States Court of Appeals for the Seventh Circuit reviewed the dismissal de novo. The main issue was whether § 227(c)(5)’s reference to “telephone calls” includes text messages. The court held that, based on the statute’s text, context, and the ordinary public meaning at the time of enactment, “telephone call” does not encompass text messages. The court also concluded that neither FCC interpretations nor prior decisions involving other TCPA provisions required a different outcome. The Seventh Circuit affirmed the district court’s dismissal. View "Steidinger v Blackstone Medical Services" on Justia Law

McCoy v. Mullin

2026-07-14T08:00:46-08:00

Derrick McCoy was employed as a Protective Services Officer by Paragon Systems, which provided security services for the Department of Homeland Security (DHS) at a Chicago Social Security field office. McCoy was terminated after an incident involving an unruly customer, during which he failed to properly restrain the individual and took photos with his personal device, violating established protocols. Paragon’s investigation concluded that McCoy did not follow procedures and terminated him. Through union grievance proceedings, Paragon agreed to reinstate McCoy if he obtained a favorable suitability determination from DHS. DHS, after reviewing the incident, issued an unfavorable suitability determination, making McCoy ineligible for reinstatement. The United States District Court for the Northern District of Illinois, Eastern Division, heard McCoy’s lawsuit against DHS, in which he alleged unlawful age discrimination under the Age Discrimination in Employment Act (ADEA). DHS moved for summary judgment, arguing McCoy could not establish a prima facie case of age discrimination. The district court granted summary judgment in DHS’s favor, finding no evidence that McCoy’s age was the reason for the adverse employment action. The court also declined to consider a proposed comparator, Lattrice Haywood, because McCoy had not disclosed her during discovery. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s grant of summary judgment de novo. The Seventh Circuit held that, even assuming DHS could be considered McCoy’s employer, McCoy failed to provide evidence that DHS’s suitability determination was based on his age. The court found no material issue of fact supporting age discrimination and affirmed the district court’s decision, concluding that McCoy had not met the requirements for a prima facie case under the ADEA or provided sufficient evidence under the holistic standard. View "McCoy v. Mullin" on Justia Law

Gibson v Chubb National Insurance Company

2026-07-13T13:30:50-08:00

A lightning strike in October 2019 caused a destructive fire at a large mansion in southern Illinois owned by Wesley Gibson. Gibson had acquired the property nearly 30 years earlier as a family vacation home and, over time, extensively renovated it and filled it with valuable furniture, antiques, and artwork. Eventually, he transformed the mansion and surrounding properties into a commercial lodging and events venue, hosting weddings, corporate retreats, and other gatherings. Gibson’s family continued to use the mansion for about 70 nights per year, but the property’s primary use became commercial, as evidenced by tax filings and significant rental income. Following the fire, Gibson filed a claim with Chubb National Insurance Company under his homeowner’s policy, which provided $8.75 million for the dwelling and $3.5 million for its contents. Chubb paid the dwelling coverage in full but limited payment for the contents to $25,000, citing a business property exclusion in the policy that capped coverage for property used in business at that amount. Gibson sued Chubb in the United States District Court for the Northern District of Illinois for breach of contract and violations of Illinois insurance and consumer-fraud statutes. On cross-motions for summary judgment, the district judge found that the majority of the contents were used for business purposes and subject to the $25,000 limit, granting partial summary judgment to Chubb. The judge allowed Gibson’s claim to proceed only for certain items kept in areas not accessible to guests. After settling remaining issues, final judgment was entered. The United States Court of Appeals for the Seventh Circuit affirmed. The court held that under the terms of the policy and Illinois law, Chubb properly classified most of the mansion’s contents as business property and was only obligated to pay the $25,000 sublimit. The court also affirmed summary judgment for Chubb on the statutory claims. View "Gibson v Chubb National Insurance Company" on Justia Law

Weissman v Clearview AI, Inc.

2026-07-13T10:00:47-08:00

Clearview AI, Inc. developed technology that collects and analyzes photographs from public websites to create facial recognition profiles, which can reveal personal details about individuals. After a media exposé in January 2020, multiple putative class-action lawsuits were filed against Clearview and related defendants, alleging misuse of biometric data. The cases were consolidated in the U.S. District Court for the Northern District of Illinois, and plaintiffs asserted claims on behalf of a nationwide class and state-specific subclasses (Illinois, California, New York, and Virginia), each based on differing statutory and common law rights. The litigation was extensive, involving motions to dismiss and discovery, before settlement negotiations began. The initial settlement talks failed due to Clearview’s limited financial resources. A second round resulted in a proposed settlement that offered class members a share in Clearview’s future equity, with a larger stake for members of certain state subclasses compared to the nationwide class. No original class representatives endorsed the settlement, prompting lead counsel to appoint new representatives, all from the favored subclasses. The district court, after considering objections, including from members of the nationwide class, approved the settlement as fair, reasonable, and adequate. The United States Court of Appeals for the Seventh Circuit reviewed the objections of nationwide class members. The court found no inherent flaw in the lack of injunctive relief or in the structure of monetary relief (an equity stake in the defendant). However, it held that the settlement was procedurally deficient because no representative of only the nationwide class participated in or approved the allocation of benefits, raising concerns about fair and adequate representation. The Seventh Circuit vacated the district court’s approval of the settlement and remanded for further proceedings. View "Weissman v Clearview AI, Inc." on Justia Law

Koehler v Infosys Technologies Limited, Inc.

2026-07-13T08:30:48-08:00

Infosys Technologies Limited, Inc. and Infosys Public Services, Inc. are global consulting and technology companies with substantial operations in the United States. Four individuals of non-South Asian descent, either former employees or applicants, brought suit against Infosys alleging they faced discrimination based on race and national origin. The plaintiffs pointed to various employment actions: one was terminated after a poor performance review coinciding with a reduction in force, another was not hired after failing to demonstrate required technical skills, a third was discharged from a temporary position, and the fourth claimed harassment and ultimately resigned, alleging a hostile work environment. The United States District Court for the Eastern District of Wisconsin reviewed the case. During discovery, plaintiffs relied heavily on an expert report by David Neumark, who used a “name-matching” methodology to identify South Asian employees and applicants in Infosys’s demographic data. The district court excluded Neumark’s testimony under Federal Rule of Evidence 702, finding him unqualified and his methodology unreliable. The court denied class certification, summary judgment supplementation with late-discovered demographic data, and ultimately granted summary judgment in favor of Infosys on all claims, including pattern and practice, disparate treatment, and disparate impact. On appeal, the United States Court of Appeals for the Seventh Circuit affirmed all district court decisions. The Seventh Circuit held that exclusion of Neumark’s expert testimony was within the district court’s discretion, given his lack of qualifications and unreliable methodology. Without that testimony, plaintiffs could not satisfy the requirements for class certification or prove disparate impact. The Seventh Circuit also held that plaintiffs failed to rebut Infosys’s legitimate, non-discriminatory reasons for the employment decisions in their individual disparate treatment claims, and that the evidence did not support a constructive discharge. The district court’s rulings were affirmed in full. View "Koehler v Infosys Technologies Limited, Inc." on Justia Law

Teva Pharmaceuticals USA, Inc. v Eli Lilly and Company

2026-07-13T07:31:15-08:00

A generic drug manufacturer and a brand-name drug company previously settled a patent infringement lawsuit concerning a medication used to treat osteoporosis. As part of their 2018 settlement, the generic manufacturer agreed not to sell its version of the drug until a specified “Entry Date,” and in return, the brand-name company covenanted not to take any action to prevent or delay the approval, launch, or marketing of the generic drug. The agreement did not specify a fixed expiration date for these obligations. Later, after the relevant patents expired in August 2019, the brand-name company submitted a supplemental application to the FDA, obtaining additional regulatory exclusivity that temporarily kept generics—including the plaintiff’s product—off the market. After being unable to enter the market due to this additional exclusivity, the generic manufacturer sued for breach of contract, arguing that the covenants in the settlement agreement required the brand-name company both to waive any exclusivity and not to interfere with its market entry. The United States District Court for the Southern District of Indiana dismissed the case, holding that the agreement and its obligations expired with the patents and therefore could not have been breached after that date. The United States Court of Appeals for the Seventh Circuit reviewed the dismissal de novo. It held that the generic manufacturer plausibly alleged breaches of contract terms that may have survived the expiration of the patents, as the settlement agreement did not clearly define its own duration. The court found that, under Indiana law, a contract without a fixed term remains effective for a “reasonable time,” which is a factual question not suitable for resolution on the pleadings. The Seventh Circuit reversed the district court’s judgment and remanded the case for further proceedings. View "Teva Pharmaceuticals USA, Inc. v Eli Lilly and Company" on Justia Law

Nautilus Insurance Company v Bee Quality Inc.

2026-07-09T14:00:46-08:00

A roofing contractor was sued in Illinois state court by the estates of two individuals who died when a building façade collapsed. The estates alleged that the contractor had negligently performed repairs on the building after it was damaged by a windstorm in August 2020. The repairs were completed by December 2020, and the fatal collapse occurred in April 2022. The contractor sought defense and indemnification from its commercial general liability insurer under a policy that began on February 8, 2022. The insurance policy included a “Prior Work Exclusion” that barred coverage for claims arising from work completed before the policy’s inception date. The insurer filed suit in the United States District Court for the Northern District of Illinois seeking a declaratory judgment that it had no duty to defend or indemnify the contractor in the underlying state lawsuit. The contractor counterclaimed for breach of contract and argued that the exclusion rendered coverage illusory. Both parties moved for judgment on the pleadings. The district court granted judgment to the insurer, holding that the exclusion applied because the work at issue was completed before the policy period and that the exclusion did not render the coverage illusory, as some coverage for completed operations remained. On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The court held that, under Illinois law, the Prior Work Exclusion clearly barred coverage for claims arising from work completed prior to February 8, 2022. The court further held that the exclusion did not make completed-operations coverage illusory because the policy still provided coverage for work completed during the policy period. The judgment in favor of the insurer was affirmed. View "Nautilus Insurance Company v Bee Quality Inc." on Justia Law

Wright v Department of Children and Family Services

2026-07-09T13:00:47-08:00

A father brought suit on behalf of his deceased minor son, who died while in his mother’s custody. The mother’s boyfriend was later charged with the child’s murder, following prior reports of domestic violence and child abuse in the home. Employees of the Illinois Department of Children and Family Services had previously investigated these reports but did not remove the child or otherwise intervene. The father alleged that the Department’s employees failed to properly investigate the abuse allegations and argued that their actions or omissions caused his son’s death. The case was first brought in Illinois state court, where the father asserted both state-law and federal claims under 42 U.S.C. § 1983. After removal to the United States District Court for the Northern District of Illinois, the defendants moved to dismiss, contending that the father’s complaint did not state a substantive due process claim because state actors are generally not liable for failing to prevent harm by private individuals. The district court dismissed the federal claim, granting the father an opportunity to amend his complaint. After a second amended complaint was again dismissed with prejudice for failure to state a claim, and a Rule 59(e) motion to vacate or amend was denied, the father appealed. The United States Court of Appeals for the Seventh Circuit reviewed the dismissal de novo. It held that the father failed to plausibly allege that the Department’s employees’ acts caused or increased the danger to the child, or that their conduct “shocked the conscience” as required under the narrow state-created danger exception to the general rule in DeShaney v. Winnebago County Department of Social Services. The appellate court affirmed the district court’s dismissal of the federal claim and its denial of leave to amend, and found no abuse of discretion in declining supplemental jurisdiction over the state-law claims. View "Wright v Department of Children and Family Services" on Justia Law

Barnett v Raoul

2026-07-09T11:30:58-08:00

In response to a mass shooting in Illinois, the state enacted the Protect Illinois Communities Act, which criminalized the manufacture, sale, and possession of assault weapons and large-capacity magazines, with a grandfather clause allowing current legal owners to retain these items if they completed a registration process. Plaintiffs, including individuals and organizations, challenged the Act in federal court, arguing it violated the Second Amendment. The district court for the Southern District of Illinois consolidated four related cases and, after a bench trial, found that much of the Act violated the Second Amendment, concluding that its main provisions were not severable and enjoining the enforcement of the entire Act. Prior to this, at the preliminary injunction stage, the plaintiffs had received relief, but similar challenges in the Northern District of Illinois had been denied. The Seventh Circuit consolidated appeals from all these cases and previously held in Bevis v. City of Naperville that the plaintiffs were unlikely to prevail on the merits under the Supreme Court’s framework from New York State Rifle & Pistol Association v. Bruen. After further factual development and trial, the district court entered a permanent injunction against the Act, which the defendants appealed. The United States Court of Appeals for the Seventh Circuit reviewed the case de novo on constitutional grounds. The court held that the Act’s restrictions on AR-15 rifles and thirty-round magazines are consistent with the nation’s historical tradition of firearms regulation. The court reasoned that legislatures have long imposed restrictions on particularly dangerous weapons, and Illinois’s law fits within this tradition. The court also held that the registration requirement was constitutional. The Seventh Circuit reversed the district court’s judgment and ordered the entry of judgment for the defendants, upholding the Act’s central restrictions. View "Barnett v Raoul" on Justia Law

USA v Kendrick

2026-07-09T11:30:55-08:00

In this case, federal drug enforcement agents received information suggesting that the defendant was involved in the distribution of large quantities of narcotics in Indiana. Following surveillance and a traffic stop that yielded evidence of drug activity, officers became concerned that the defendant was aware of their investigation. They installed a camera on a utility pole across the street from the defendant’s leased auto-repair shop without first obtaining a warrant. The property was surrounded by a six-foot fence, but it had significant gaps, including a thirty-foot-wide opening allowing vehicle and pedestrian access. The pole camera recorded activities on the property for approximately two weeks, capturing movements consistent with drug trafficking. Subsequent searches, supported by warrants, resulted in significant seizures of narcotics, firearms, and cash. The United States District Court for the Southern District of Indiana denied the defendant’s motion to suppress evidence obtained from the pole camera. The court held that the fence did not create a reasonable expectation of privacy in the observed activities because the gaps allowed visibility from the street. The court also found that the pole camera’s use was not a search requiring a warrant under prevailing precedent, and concluded that even without the camera footage, there was probable cause to support the search warrants. The court determined that, if necessary, the good-faith exception to the exclusionary rule would apply. On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The Seventh Circuit held that the use of the pole camera did not violate the Fourth Amendment. The court reasoned that the camera captured activities observable to passersby through the substantial gap in the fence, the technology was in common public use, and the officers were lawfully present. The court also emphasized that commercial properties receive less Fourth Amendment protection than residences. View "USA v Kendrick" on Justia Law

Estate of Thomson v. Behn

2026-07-09T08:00:45-08:00

Jason Thomson was transported to a hospital in Green Bay, Wisconsin after suffering a seizure, where he later became agitated and aggressive toward hospital staff. Officers from the Green Bay Police Department responded, restrained Thomson—who repeatedly complained that he could not breathe—and placed him in a WRAP restraint device. Officers monitored his breathing and obtained a medical clearance from hospital staff before transporting him to jail. During transport and upon arrival at the jail, Thomson continued to state he could not breathe. At the jail, medical staff determined he could not be admitted and needed further hospital evaluation. Shortly after, Thomson suffered a cardiac arrhythmia and died. The Estate of Jason Thomson filed suit in the United States District Court for the Eastern District of Wisconsin, alleging that the officers used excessive force and failed to provide adequate medical care in violation of the Fourth Amendment, and asserting a failure-to-train claim against the City of Green Bay under Monell v. Department of Social Services of the City of New York. The district court granted summary judgment to the officers, the city, and Brown County, finding that the officers’ actions were objectively reasonable, that they did not violate Thomson’s rights, and that they were entitled to qualified immunity. The claims against Brown County and its officers, as well as a claim against a nurse, were subsequently resolved or dismissed. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s rulings de novo. The court held that no reasonable jury could find that the officers violated Thomson’s constitutional rights regarding medical care or excessive force. The court further held that the officers were entitled to qualified immunity, and, because no underlying constitutional violation was established, the Monell claim against the city also failed. The Seventh Circuit affirmed the judgment of the district court. View "Estate of Thomson v. Behn" on Justia Law

Davis v. City of Elgin, Illinois

2026-07-09T06:00:46-08:00

After threatening his ex-wife and her nephew with what appeared to be a firearm while intoxicated, an individual left his home and fell asleep at a neighbor’s house. Police were alerted, and, believing him to be inside and armed, surrounded the residence with S.W.A.T. teams and other tactical units. Negotiators eventually reached him by phone, during which he threatened self-harm and was reported to have threatened the officers, though he denied threatening the officers directly. When he exited the house, police fired non-lethal projectiles after he refused commands to come off the porch, seriously injuring his arm. After briefly retreating indoors, he reemerged and was shot three more times with similar ammunition when he acted aggressively and shouted threats at the officers. The United States District Court for the Northern District of Illinois, Eastern Division, granted summary judgment in favor of the officers and the City, holding that the plaintiff failed to show the police violated clearly established constitutional rights under the Fourth Amendment. The district court distinguished the facts of this case from prior circuit precedent, including Phillips v. Community Insurance Corp., and found that the officers’ actions did not clearly contravene established law. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the summary judgment ruling de novo. The appellate court held that qualified immunity shielded the officers because no binding precedent placed the unconstitutionality of their specific actions beyond debate, given the circumstances—namely, threats involving firearms and knives and the plaintiff’s aggressive behavior. The court also noted that the plaintiff failed to articulate a viable claim against the City of Elgin. The Seventh Circuit therefore affirmed the district court’s grant of summary judgment for all defendants. View "Davis v. City of Elgin, Illinois" on Justia Law

Spengler v Cooperative Educational Service Agency 7

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

A special education administrator was employed by a Wisconsin state agency that facilitated educational services across multiple school districts. After a couple years, her supervisors, following directives from the Wisconsin Department of Public Instruction, pushed staff to adopt an “equity mindset,” which involved examining personal biases and working to disrupt systems influenced by white supremacy. The administrator disagreed with the perceived ideological requirements and refused to fully embrace the equity mindset, leading to concerns from the Department of Public Instruction, pressure on the agency, and her eventual demotion to a lower-paying job. The administrator filed suit in the United States District Court for the Eastern District of Wisconsin, alleging violations of Title VII and the Equal Protection Clause, claiming discrimination and retaliation based on her race. She also asserted a First Amendment claim, alleging retaliation based on her speech and beliefs. The district court granted summary judgment to the defendants on the Title VII and Equal Protection claims, finding no evidence that race was a motivating factor in her demotion, as the ideological requirements were applied to employees of all races. The court rejected her First Amendment claims regarding her speech and insufficiently pleaded her beliefs-based claim. The United States Court of Appeals for the Seventh Circuit reviewed the case. It affirmed the district court’s summary judgment on the Title VII and Equal Protection claims, holding that no reasonable jury could find her race was the cause of her demotion and that she did not engage in an objectively reasonable protected activity for retaliation purposes. However, the Seventh Circuit determined she adequately pleaded a First Amendment claim based on retaliation for her beliefs and remanded that claim for further proceedings. View "Spengler v Cooperative Educational Service Agency 7" on Justia Law

Boldt Company v Black & Veatch Construction, Inc.

2026-07-08T07:30:46-08:00

Black & Veatch Construction, Inc. contracted The Boldt Company as a subcontractor for the assembly of a windfarm in Illinois. The project quickly encountered delays due to late delivery of turbine parts, unsuitable site conditions, and issues with equipment, for which Boldt provided several written notices to Black & Veatch. Despite these notices, Black & Veatch issued multiple default warnings and ultimately terminated Boldt for cause, taking over the remaining work. Boldt sued, claiming wrongful termination and seeking payment for completed work, while Black & Veatch counterclaimed that Boldt breached by failing to perform on time. The United States District Court for the Northern District of Illinois granted summary judgment in favor of Black & Veatch, ruling that Boldt defaulted by failing to perform on schedule and that Black & Veatch properly terminated the subcontract. At trial, the jury was tasked only with determining damages and awarded Black & Veatch nominal damages of $1. Both parties filed post-trial motions, which the district court denied. Upon appeal, the United States Court of Appeals for the Seventh Circuit affirmed the jury’s nominal damages verdict, finding no reversible error in the district court’s evidentiary rulings or jury instructions. The appellate court also affirmed the district court’s grant of summary judgment as to Boldt’s claims for payment for completed work and for Black & Veatch’s alleged failure to provide adequate construction works. However, the Seventh Circuit reversed the grant of summary judgment on the wrongful termination claim, finding the subcontract ambiguous about whether Boldt was responsible for delays absent specific notice and that material factual disputes remained. The case was remanded for further proceedings on the wrongful termination claim. View "Boldt Company v Black & Veatch Construction, Inc." on Justia Law

USA v. Martinez

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

A semi-truck driver was stopped in Illinois after state police received a tip from another law enforcement agency that the truck was carrying a large amount of narcotics. Two K9 troopers, not on routine patrol, waited on the side of the highway in the early morning hours to intercept the vehicle. The stated purpose for the stop was to conduct an administrative Level 3 inspection under Illinois’s commercial trucking regulatory scheme, involving checks of driver and vehicle documents. During the stop, the trooper noticed several signs he considered suspicious, including an odor of air freshener and irregularities with the driver’s route and cargo. A dog sniff of the truck led to the discovery of narcotics, and the driver was arrested. The United States District Court for the Central District of Illinois heard the defendant’s suppression motion, in which he argued the stop was a pretextual administrative inspection aimed solely at investigating criminal activity, thus violating the Fourth Amendment. The district court denied the motion, reasoning that the officer’s subjective intent was irrelevant so long as the stop was authorized under Illinois’s regulatory scheme. On appeal, the United States Court of Appeals for the Seventh Circuit held that, in the context of administrative inspections, an officer’s actual motivation for conducting the stop is relevant. The court found that the evidence showed the stop was undertaken solely to further a criminal investigation, not to enforce administrative regulations. It further held that the government had failed to demonstrate the stop was justified in its inception under the administrative inspection exception to the warrant requirement. The court concluded that the evidence obtained as a result of the stop must be suppressed and that the good faith exception to the exclusionary rule did not apply. The Seventh Circuit reversed the district court’s denial of the suppression motion and remanded for further proceedings. View "USA v. Martinez" on Justia Law

E.E.V. v. Blanche

2026-07-06T14:00:47-08:00

Two noncitizens, E.E.V. and M.C.C.-G., challenged orders that would remove them from the United States to their native countries, where they claimed they would face persecution or torture. E.E.V., a citizen of El Salvador, was previously removed under an expedited removal order, reentered the U.S., and was then subject to a reinstatement order in 2015. She expressed fear of returning, was found to have a reasonable fear by an asylum officer, and was referred to withholding-only proceedings before an immigration judge, which remained pending. M.C.C.-G., a Mexican citizen, was issued a final administrative removal order in 2025 after a criminal conviction. She also expressed fear of return, was initially found not to have a reasonable fear, but that determination was vacated, and she was placed in withholding-only proceedings, which were still pending when these petitions were filed. Previously, under Seventh Circuit precedent, noncitizens like the petitioners were required to wait until all administrative proceedings—including withholding-only proceedings—were completed before seeking judicial review. However, after the Supreme Court’s decision in Riley v. Bondi, the statutory thirty-day deadline to file a petition for review was held to run from the issuance of a final administrative removal order, regardless of the status of withholding-only proceedings. The United States Court of Appeals for the Seventh Circuit considered the government’s motions to dismiss the petitions as untimely, as they were filed more than thirty days after the final removal orders, and also raised new jurisdictional arguments. The Seventh Circuit rejected arguments that reinstatement orders are not subject to judicial review and that the petitions were unripe. The court held that the thirty-day deadline is subject to equitable tolling due to petitioners’ reliance on the prior binding precedent, making these petitions timely. The court denied the motions to dismiss and to transfer venue, holding the petitions in abeyance pending completion of agency proceedings. View "E.E.V. v. Blanche" on Justia Law

Liapis v Bisignano

2026-07-06T12:00:46-08:00

The plaintiff, who has a history of bipolar disorder, chronic pain due to orthopedic injuries, and an ear injury, applied for disability benefits in July 2020, alleging an inability to work since December 2019. Several consultative medical examiners assessed the plaintiff’s physical and mental impairments. While most concluded that the plaintiff was capable of routine, unskilled work, one psychologist, Dr. Pushkash, found that the plaintiff’s ability to concentrate and persist on tasks was markedly impaired due to chronic pain and psychological symptoms, though his cognitive abilities were otherwise unremarkable. After his claim was denied by Wisconsin’s disability agency, both initially and on reconsideration, the plaintiff requested a hearing before an Administrative Law Judge (ALJ). The ALJ found the plaintiff was not disabled, deeming Dr. Pushkash’s opinion “generally unpersuasive” for reasons including the one-time nature of the evaluation and the psychologist’s comments on physical pain. The Appeals Council denied review, making the ALJ’s decision final. The plaintiff then sought review in the United States District Court for the Western District of Wisconsin, which affirmed the ALJ’s decision, focusing on the ALJ’s treatment of Dr. Pushkash’s opinion. On appeal, the United States Court of Appeals for the Seventh Circuit held that while the ALJ’s analysis of Dr. Pushkash’s opinion contained several legal errors—such as failing to properly address required regulatory factors and inconsistently assessing medical opinions—these errors were harmless. The court concluded that, even if Dr. Pushkash’s opinion were fully credited, the plaintiff would not meet the regulatory criteria for disability, as he did not have the requisite number of “marked” or “extreme” limitations in areas of mental functioning. Therefore, the Seventh Circuit affirmed the judgment of the district court. View "Liapis v Bisignano" on Justia Law

USA v Eta

2026-07-06T06:00:46-08:00

Federal authorities were investigating an individual suspected of orchestrating transnational cyber fraud and money laundering schemes originating in Nigeria and targeting U.S. nationals. Information from two sources, including a co-conspirator, implicated him as a leader of fraudulent operations. Investigators gathered corroborating evidence, such as suspicious messages, unusually high activity on messaging apps, and bank records showing millions in transactions with no apparent legitimate source. When authorities learned he would return to the U.S. from Nigeria, they requested a manual search of his electronic devices upon arrival at Atlanta’s international airport. Customs officers searched his phones, found evidence of criminal activity, and subsequently seized the devices for forensic imaging. Two days later, law enforcement obtained search warrants for the phones and their extracted data. The United States District Court for the Northern District of Illinois, Eastern Division, reviewed the defendant’s motion to suppress evidence from the warrantless border search of his cell phones, which he argued violated his Fourth Amendment rights. After an evidentiary hearing, the district court found law enforcement witnesses credible and denied the motion, concluding that the manual search at the border was justified under the border search doctrine. The defendant then entered a conditional guilty plea to wire fraud, preserving his right to appeal the suppression ruling. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s denial de novo. The court reaffirmed that routine, manual searches of electronic devices at the border do not require a warrant or individualized suspicion under circuit precedent, specifically United States v. Mendez, and Supreme Court precedent. The court held that the search was routine, reasonable, and justified by the border search exception. Even if a Fourth Amendment violation occurred, the good-faith exception would preclude suppression. The judgment of the district court was affirmed. View "USA v Eta" on Justia Law

City of Hammond v Lake County Board of Elections

2026-07-02T12:00:46-08:00

In this case, the City of Hammond and three individual voters challenged Indiana’s use of the “Missouri Plan”—a system in which the governor appoints superior court judges from a list of nominees vetted by a nonpartisan commission, followed by periodic retention elections—in Lake County. They argued that, unlike most other Indiana counties where superior court judges are chosen in open elections, the Missouri Plan in Lake County gives minority voters, who make up over 40% of the voting-age population there, less opportunity than white voters elsewhere in the state to select judges of their choice. Plaintiffs relied on demographic disparities and asserted that the system violated Section 2 of the Voting Rights Act. The United States District Court for the Northern District of Indiana, Hammond Division, entered summary judgment for the defendants. The district court found that Seventh Circuit precedent, specifically Quinn v. Illinois, foreclosed the plaintiffs’ claim, holding that Section 2 does not require any particular office to be filled by election rather than appointment. The district judge also noted contrary circuit precedent in Bradley v. Work, which addressed similar facts, but concluded that Quinn was controlling. On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The court concluded that, under the Supreme Court’s intervening decision in Louisiana v. Callais, Section 2 liability attaches only where circumstances strongly suggest intentional discrimination. The appellate court found no evidence that Indiana’s use of the Missouri Plan in Lake County was motivated by racial discrimination, as the change was prompted by concerns over partisanship and inefficiency in the courts rather than race. The court thus held that Section 2 could not impose liability under these facts and affirmed the summary judgment for the defendants. View "City of Hammond v Lake County Board of Elections" on Justia Law

USA v Rose

2026-07-02T09:01:19-08:00

In 2009, Jonathan Rose was involuntarily committed to a mental institution in Indiana due to a psychiatric disorder, though the specific diagnosis and its severity were not detailed in the record. He was released in early 2010 and has not been recommitted since. In 2022, Rose successfully purchased multiple firearms, though he was denied others after background checks revealed his prior commitment. In 2023, he was indicted under federal law for possessing firearms as a person previously committed to a mental institution and for making false statements to firearms dealers by denying his commitment history. The United States District Court for the Northern District of Indiana reviewed Rose’s case and dismissed the counts related to possession of firearms by a previously committed person under 18 U.S.C. §922(g)(4). The district court reasoned that this statute, as applied to someone no longer suffering from mental illness, was inconsistent with the Second Amendment, particularly in light of recent Supreme Court decisions emphasizing individualized assessments of current danger rather than permanent disabilities based on past conditions. The United States Court of Appeals for the Seventh Circuit considered the government’s appeal. The court determined that the district court should not have dismissed the indictment without an evidentiary hearing to assess Rose’s current mental health and dangerousness. The Seventh Circuit held that, after recent Supreme Court decisions, the constitutionality of §922(g)(4) as applied depends on whether the defendant currently poses a credible threat to the safety of others. Because the record lacked evidence concerning Rose’s present mental condition, the appellate court vacated the district court’s order and remanded for further proceedings to develop the necessary facts. View "USA v Rose" on Justia Law

USA v. Adefusi

2026-07-02T06:30:59-08:00

Babajide Adefusi entered a plea agreement with the United States Attorney’s Office for the Southern District of Texas in 2018, pleading guilty to aiding and abetting passport fraud. The scheme involved using counterfeit passports with Adefusi’s photo and false identity information to open bank accounts, into which funds from internet scam victims were wired. The total loss from the passport fraud scheme was approximately $2.2 million. The plea agreement included a promise by the “United States” not to pursue additional charges arising out of the scheme alleged in the charging document. The agreement, however, specified that it bound only the U.S. Attorney’s Office for the Southern District of Texas and not any other U.S. Attorney. After completing his sentence, Adefusi was indicted by a federal grand jury in the Central District of Illinois in 2023 for conspiring to commit wire fraud related to a scheme defrauding E-MedRx, a pharmacy billing company. Adefusi moved to dismiss the indictment, arguing that the earlier plea agreement barred the Central District of Illinois from prosecuting him due to factual overlap between the two schemes. The United States District Court for the Central District of Illinois denied the motion, finding the plea agreement unambiguously bound only the Southern District of Texas office. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s denial of Adefusi’s motion to dismiss. Applying principles of contract interpretation to the plea agreement, the Seventh Circuit held that the agreement unambiguously bound only the U.S. Attorney’s Office for the Southern District of Texas and not other U.S. Attorney’s Offices. Thus, the Central District of Illinois was not barred from prosecuting Adefusi for wire fraud conspiracy. The Seventh Circuit affirmed the district court’s decision. View "USA v. Adefusi" on Justia Law

Andric v. Blanche

2026-07-01T11:30:47-08:00

A Serbian professional soccer player entered the United States on a visitor visa and sought asylum, claiming past persecution due to his membership in a group he defined as “Serbian soccer players who are victims of violence from soccer hooligans,” as well as persecution based on an imputed political opinion. He described being assaulted by soccer hooligans after a game, suffering moderate injuries, and receiving subsequent threats. He did not report these incidents to police, fearing connections between the hooligans and law enforcement, and argued that relocation within Serbia would not protect him because of the reach of these groups. An immigration judge found the applicant credible but ruled that the harm he suffered did not amount to past persecution, as it was based on a single incident without lasting impairments and was motivated by personal dissatisfaction with his performance rather than a protected ground. The judge held that being a soccer player was not an immutable characteristic and that the proposed social group lacked particularity and specificity. Furthermore, the judge found no evidence of government unwillingness or inability to protect him, nor of an objectively reasonable fear of future persecution. The judge denied asylum as well as withholding of removal and protection under the Convention Against Torture, which the applicant did not appeal. The Board of Immigration Appeals affirmed the judge’s decision, finding that the revised social group definition was waived and agreeing that the applicant failed to establish a nexus to a protected ground. The United States Court of Appeals for the Seventh Circuit reviewed the agency’s conclusions for substantial evidence and held that the applicant’s harm did not occur on account of a protected ground, and that neither of his proposed social groups was cognizable under the law. The court denied the petition for review. View "Andric v. Blanche" on Justia Law

USA v. Espanola

2026-07-01T07:30:46-08:00

A contractor for the City of Moline, Illinois, discovered in early 2021 that city payments totaling over $420,000 had been diverted to a fraudulent bank account at Washington Federal Bank. That account belonged to Luisito Espanola, who had opened it under the name GS International, LLC, which he controlled. Investigators found that Espanola quickly moved the stolen funds by depositing checks to a Citibank account, purchasing cryptocurrency, and sending money to other entities. Digital evidence, including WhatsApp messages between Espanola and a co-conspirator, detailed their planning and execution of the fraud. The United States District Court for the Central District of Illinois tried Espanola on two counts of wire fraud and two counts of money laundering. During discovery, Espanola produced a WhatsApp chat log as a defense exhibit; the government then moved to admit the chat log in its case-in-chief. The district court admitted the messages, relying on their distinctive characteristics and Espanola’s production of them under Rule 16(b)(1)(A). The jury convicted Espanola on all counts, and the district court sentenced him to 32 months in prison. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether the district court’s reliance on Espanola’s production of the messages as a basis for authentication under Federal Rule of Evidence 901(b)(4) violated his right to testify. The court held that it did not, as the admission of government evidence does not infringe upon the defendant’s right to testify, which is implicated only by the exclusion of defense evidence. The Seventh Circuit further held that, regardless of circumstances of discovery, the WhatsApp messages were authenticated by their content and corroborating records. The court affirmed the district court’s judgment. View "USA v. Espanola" on Justia Law

USA v. Banks

2026-06-30T06:31:05-08:00

A man was stopped by police late at night after an officer observed him allegedly fail to signal 100 feet before making a left turn, as required by Illinois law. After he parked in a strip mall lot, officers initiated a traffic stop and asked for his license and proof of insurance. The driver’s insurance card was expired, prompting him to exit the car to call someone for updated proof. While the stop was ongoing, another officer arrived with a drug-sniffing dog, which alerted to narcotics outside the vehicle. Police then searched the car and found a handgun hidden in the center console, but no drugs. The driver was arrested and charged with being a felon in possession of a firearm. The United States District Court for the Central District of Illinois denied the defendant’s motion to suppress the handgun, finding the officer’s testimony credible enough to establish reasonable suspicion for the traffic stop and that the stop was not impermissibly prolonged. It also found the dog’s alert provided probable cause to search the vehicle. At trial, the court denied the defendant’s motion for a directed verdict, ruling there was sufficient evidence for the jury to convict him. The defendant’s post-trial motion for a new trial was also denied. The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s rulings. The appellate court held that the district court did not clearly err in crediting the officer’s testimony about the traffic violation, that the duration of the stop was not unreasonably extended, and that the dog’s alert provided probable cause for the search. The court also found that there was sufficient evidence to support the conviction for knowing possession of a firearm by a felon. The judgment was affirmed. View "USA v. Banks" on Justia Law

Creason v Elanco US Inc.

2026-06-29T10:00:53-08:00

Clayton Creason worked as an engineer for Elanco US from November 2017 to November 2021. During his employment, Elanco offered a standard paid vacation benefit and an optional “vacation buy” program that allowed employees to purchase an extra week of paid leave by accepting a reduction in weekly salary. Creason participated in this program, reducing his pay by approximately $84 per week for the additional vacation week. After resigning, he filed suit under the Indiana Wage Payment Statute, claiming Elanco owed him the amount of the salary reduction, arguing the program required a written assignment of wages with notice of the right to rescind, as specified by Indiana law. The suit was initially filed in Indiana state court, with Creason seeking class certification for similarly situated employees. Elanco removed the case to the United States District Court for the Southern District of Indiana under the Class Action Fairness Act. The district court denied Creason’s belated motion to remand, finding his delay in seeking remand unreasonable after substantial progress in federal court. The court then dismissed some claims on the pleadings and granted summary judgment to Elanco on the remaining issues, concluding the vacation buy program did not constitute an assignment of wages and that Elanco’s policies concerning unused pandemic-related vacation hours did not violate Indiana law. The United States Court of Appeals for the Seventh Circuit reviewed the case. It held that the district court acted within its discretion in denying the remand request due to Creason’s unreasonable delay. On the merits, the Seventh Circuit affirmed that the vacation buy program was not an assignment of wages under Indiana law and that Elanco was not obligated to pay out unused COVID-related vacation hours. The district court’s decision was affirmed. View "Creason v Elanco US Inc." on Justia Law

Pavlovich v. Gaiman

2026-06-29T08:30:54-08:00

The plaintiff, a New Zealand citizen who currently resides in Scotland, alleged that the defendant, a United Kingdom citizen and lawful permanent resident of Wisconsin, repeatedly sexually assaulted her while she was employed as a live-in nanny for the defendant’s family in New Zealand. The plaintiff claimed she was economically distressed and intermittently unhoused at the time, and accepted the job for secure employment and housing. She brought federal claims under the Trafficking Victims Protection Act and Wisconsin common law claims, seeking damages for the alleged assaults and related harms. After the plaintiff filed suit in the United States District Court for the Western District of Wisconsin, the defendant moved to dismiss the case on two grounds: forum non conveniens, arguing that New Zealand was a more appropriate forum, and failure to state a federal claim, contending the civil-remedy provision of the Act does not apply extraterritorially. The district court granted the motion to dismiss under forum non conveniens, finding that New Zealand was an available, adequate, and more convenient forum with a stronger connection to the dispute. The district court did not address the extraterritoriality issue. The plaintiff appealed the dismissal to the United States Court of Appeals for the Seventh Circuit. The United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal under forum non conveniens. The appellate court concluded there was no abuse of discretion in the district court’s findings that New Zealand was both an available and adequate forum, and it properly balanced public and private interest factors. The Seventh Circuit held that New Zealand’s connection to the dispute was stronger than that of the United States and that international comity concerns supported dismissal. The judgment was affirmed and the action dismissed without prejudice. View "Pavlovich v. Gaiman" on Justia Law

USA v. Turner

2026-06-29T08:00:45-08:00

Malaia Turner was indicted for conspiring to distribute 500 grams or more of methamphetamine. Evidence at trial showed that Turner and Marcus Posey operated a methamphetamine transportation and distribution scheme between California and Illinois, beginning in 2019. Turner was involved in purchasing, packaging, and shipping methamphetamine, recruiting couriers, and handling transactions. She and Marcus expanded their operations to include other individuals as couriers and negotiated deals for others. Turner also enforced payments from customers and handled large transactions herself. The evidence indicated that Turner and Marcus eventually split proceeds and consulted on pricing. The United States District Court for the Central District of Illinois conducted Turner’s jury trial, which resulted in her conviction. Prior to sentencing, the probation officer prepared a Presentence Investigation Report (PSR) recommending a two-level leader-organizer enhancement under U.S.S.G. § 3B1.1(c) and attributing substantial drug quantities to Turner. Turner objected to the drug amounts and the role enhancement in a sentencing memorandum. At the sentencing hearing, the district court overruled Turner’s objections to the PSR’s drug quantity calculations and the leader-organizer enhancement, adopted the factual findings, and sentenced Turner to 324 months’ imprisonment. Turner appealed, arguing procedural errors in the sentencing process and improper application of the enhancement. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s factual findings for clear error and legal conclusions de novo. The Seventh Circuit held that the district court properly applied the two-level leader-organizer enhancement based on Turner’s supervisory role and involvement in the conspiracy. The court also found no error in the adoption of drug quantities, concluding that any procedural error was harmless because the sentence would not have been affected. The Seventh Circuit affirmed the district court’s judgment. View "USA v. Turner" on Justia Law

USA v. Johnson

2026-06-26T07:30:46-08:00

Brian Johnson orchestrated a fraudulent scheme from 2010 onward, in which he posed as both the CEO and an employee of a fictitious adult film, photography, and art studio. He posted advertisements online, soliciting women to audition for purported modeling or adult film opportunities, promising substantial compensation and future work. Johnson required in-person meetings, during which he took nude photographs and videos, gave the women alcohol, and engaged in sexual acts with them. He falsely claimed their images needed to be reshot for a distributor and threatened to post the images online if they refused further participation. One victim, who was sixteen at the time, eventually revealed her true age and provided proof, but Johnson continued to possess and distribute her images. The United States District Court for the Northern District of Illinois, Eastern Division, conducted the trial. A jury convicted Johnson on seven counts of sex trafficking and three counts of child pornography. Johnson moved for acquittal post-trial; the district court denied his request regarding the sex trafficking convictions but granted acquittal on the child pornography convictions. Johnson was sentenced to 420 months in prison. Both Johnson and the government appealed: Johnson challenged his convictions and sentence, while the government cross-appealed the acquittal on the child pornography counts. The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s denial of Johnson’s motion for acquittal on the sex trafficking convictions, holding that fraudulent promises of future compensation and work opportunities can constitute “things of value” under 18 U.S.C. § 1591(e)(3) when the victims subjectively believe in their value. The court found the sentence substantively reasonable. However, it reversed the district court’s acquittal on the child pornography convictions, concluding that sufficient evidence supported the jury’s findings regarding Johnson’s knowledge of the victim’s age. The court vacated the sentence and remanded for reinstatement of the child pornography convictions and resentencing. View "USA v. Johnson" on Justia Law

USA v Morgan

2026-06-25T12:30:56-08:00

James Morgan was investigated by law enforcement for several years due to his online activity, which included posting instructions for making dangerous homemade weapons and advocating for violence against government officials and minority groups. His posts, while often protected speech, were accompanied by demonstrations of weapons such as pipe bombs, acid sprayers, and flamethrowers. In late 2023, federal agents sought and obtained a search warrant from a magistrate judge in the Eastern District of Wisconsin to search Morgan’s property, including a trailer parked in the Western District, based on an affidavit detailing his conduct and apparent intent to commit acts dangerous to human life. After executing the warrant, agents found pipe bombs in Morgan’s trailer. He was indicted by a grand jury in the Western District of Wisconsin for possession of unregistered destructive devices under 26 U.S.C. § 5861(d). Morgan moved in the United States District Court for the Western District of Wisconsin to suppress the evidence, arguing the magistrate lacked authority to issue an extra-district warrant under Federal Rule of Criminal Procedure 41(b), and to dismiss the indictment, claiming the statute exceeded Congress’s taxing power. The district court denied both motions, finding the affidavit provided probable cause that Morgan’s activities constituted domestic terrorism under Rule 41(b)(3) and that established precedent foreclosed his constitutional challenge. Morgan entered a conditional guilty plea, reserving his right to appeal. The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s rulings. The court held the affidavit supplied probable cause that Morgan’s activities met the statutory definition of domestic terrorism, authorizing the magistrate’s extra-district warrant under Rule 41(b)(3). It also concluded that Morgan’s constitutional challenge to 26 U.S.C. § 5861(d) was foreclosed by Supreme Court and Seventh Circuit precedent, upholding the statute as a valid exercise of Congress’s taxing power. View "USA v Morgan" on Justia Law

Certain Underwriters at Lloyd's v CSX Transportation, Inc.

2026-06-25T09:31:27-08:00

National Railway Equipment sought to deliver four rebuilt locomotives from Illinois to North Carolina for export. The company’s logistics manager used online systems to contract with two rail carriers: Evansville Western Railway for the Illinois-to-Indiana leg, and CSX Transportation for the Indiana-to-North Carolina leg. For each shipment, the manager selected a standard transportation commodity code and accepted the carriers’ publicly available rates, which included liability limits per locomotive. The manager could have selected higher rates for greater carrier liability but opted not to, as National Railway Equipment carried its own insurance for losses. After the locomotives were destroyed in a derailment during Hurricane Florence while in CSX’s possession, the company’s insurer, Certain Underwriters at Lloyd’s, paid the claim and pursued reimbursement from the carriers under the Carmack Amendment. Evansville Western Railway moved for summary judgment, arguing liability was contractually capped, while CSX went to trial on similar terms. The United States District Court for the Southern District of Illinois found for Evansville Western on summary judgment, concluding the liability cap applied, and the jury found for CSX, also applying the contractual cap. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether the carriers’ liability was properly limited under the Carmack Amendment. The court held that where a shipper knowingly selects a carrier’s rate that includes a liability cap, and the contractual documents (here, the bills of lading with the standard code) reflect this agreement, the limitation is enforceable—even if the cap is not stated verbatim in the bill of lading. The Seventh Circuit affirmed the district court’s summary judgment for Evansville Western and denial of judgment as a matter of law against CSX, upholding the application of the contractual liability limits. View "Certain Underwriters at Lloyd's v CSX Transportation, Inc." on Justia Law

Brown v Chicago Transit Authority

2026-06-24T14:00:46-08:00

An employee of the Chicago Transit Authority (CTA), represented by a union, was terminated after repeatedly failing to follow the proper procedure for reporting Family and Medical Leave Act (FMLA) absences. The CTA required employees to notify a third-party administrator, ReedGroup, as well as their work location, when taking FMLA leave. The employee, who is transgender and had previously advocated for workplace accommodations and insurance coverage related to his transition, applied for intermittent FMLA leave for back pain, but his application was denied after he failed to complete the required process for obtaining a third medical opinion. Despite the denial, he continued to report absences as FMLA leave only to his work location, not ReedGroup, resulting in his termination for falsification of leave. After his discharge, the employee sought the union’s assistance in contesting his termination and pursued the available grievance and arbitration procedures. He also filed charges with the Equal Employment Opportunity Commission, then sued both the CTA and the union in the United States District Court for the Northern District of Illinois, Eastern Division. He asserted claims of transgender discrimination and retaliation under Title VII, as well as FMLA interference and retaliation against the CTA, and a municipal liability claim. The district court granted summary judgment in favor of the CTA and the union, concluding that the employee had failed to produce evidence that would allow a reasonable jury to find in his favor. On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The court held that the employee failed to provide sufficient evidence that similarly situated non-transgender employees were treated more favorably, or that the CTA or the union’s actions were pretextual or motivated by discriminatory or retaliatory animus. The court also found no error in the exclusion of evidence and upheld the dismissal of the FMLA claims. The summary judgment for both defendants was affirmed. View "Brown v Chicago Transit Authority" on Justia Law

Jezior v City of Chicago

2026-06-24T13:30:46-08:00

Michael Jezior worked as an engineer-paramedic for the Chicago Fire Department until a stroke in 2013 left him with limited mobility. Unable to perform his original duties, Jezior was reassigned to a procurement position at O’Hare Airport. In 2021, Jezior became eligible for promotion to lieutenant. However, the Department informed him that all available lieutenant positions at the airport required active firefighting, which he could not perform due to his disability. Jezior was offered the option to seek an accommodation for a different lieutenant position or to remain in his current role without promotion. He declined to pursue the accommodation process, fearing it could result in medical disqualification and early retirement, and chose to stay in his current position. Jezior then sued the City of Chicago under the Americans with Disabilities Act (ADA), claiming denial of a reasonable accommodation and disability discrimination. The United States District Court for the Northern District of Illinois, Eastern Division, granted summary judgment for the City. The court found that Jezior was not a “qualified individual” for the lieutenant position at the airport because he could not perform the essential firefighting functions. It further held that the ADA does not require an employer to create a new position or provide the employee’s preferred accommodation. On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The Seventh Circuit held that Jezior was not qualified for the requested promotion because he could not meet the essential job requirements. The court also determined that the City was not obligated to provide Jezior his preferred accommodation or to promote him in place. Additionally, the court found no evidence of pretext or disparate treatment compared to similarly situated employees. The judgment for the City was affirmed. View "Jezior v City of Chicago" on Justia Law

Hossfeld v Allstate Insurance Co.

2026-06-24T13:00:47-08:00

Robert Hossfeld received twelve telemarketing calls advertising Allstate Insurance products, despite having previously requested that Allstate not contact him. The calls were made by Atlantic Telemarketing Center, which had been subcontracted by Transfer Kings, a company retained by Allstate’s insurance agents, Fleming and Gilmond. Allstate’s internal do-not-call list included Hossfeld’s number months before the calls occurred. Neither Allstate nor its agents were aware that Atlantic was involved in marketing Allstate insurance until after Hossfeld initiated his lawsuit. Hossfeld sued Allstate in the United States District Court for the Northern District of Illinois, alleging violations of the Telephone Consumer Protection Act (TCPA) because Allstate failed to maintain an adequate do-not-call policy and permitted calls to be made to him after his request. He also sought class certification for other similarly affected individuals. The district court denied class certification, finding Hossfeld had not demonstrated that the proposed class was sufficiently numerous. On cross-motions for summary judgment, the district court ruled in Hossfeld’s favor, holding Allstate vicariously liable for Atlantic’s calls under agency law and awarding treble damages for willful violations. The United States Court of Appeals for the Seventh Circuit reviewed the case. The appellate court affirmed the denial of class certification, agreeing that Hossfeld failed to prove numerosity and impracticability of joinder. However, it reversed the district court’s summary judgment on liability, concluding that Hossfeld failed to show Allstate was liable for Atlantic’s calls under any theory of agency law, including subagency, apparent authority, or ratification. The Seventh Circuit clarified that the willfulness standard under the TCPA requires reckless or knowing conduct, not merely volitional acts. The court affirmed in part and reversed in part, directing judgment for Allstate. View "Hossfeld v Allstate Insurance Co." on Justia Law

Jeffboat, Inc. v Director, OWCP

2026-06-23T12:00:45-08:00

The case concerns a worker who was employed as a ship painter at a shipyard in Indiana for twelve years. After being laid off in 2017, he filed a claim for workers’ compensation under the Longshore and Harbor Workers’ Compensation Act, alleging that he experienced breathing difficulties due to prolonged exposure to various lung irritants during his employment, including fumes from paints, paint thinners, sandblasting materials, and other chemicals. He had a history of health issues, including asthma, COPD, and emphysema, and was a longtime smoker who switched to vaping in 2015. Medical evidence was presented by both the claimant and the employer, with dueling expert reports on whether workplace exposures contributed to his lung conditions. The Department of Labor administrative law judge (ALJ) conducted a formal hearing. The ALJ found the claimant had suffered harm and that workplace conditions could have caused it, entitling him to a statutory presumption of causation. The employer rebutted this presumption, but after considering the evidence, the ALJ credited the claimant’s expert and concluded that workplace exposures contributed to his lung impairment. The ALJ awarded permanent partial disability benefits and medical expenses. The Office of the District Director later granted a reduced attorney’s fee award. The Benefits Review Board affirmed both the ALJ’s decision and the fee award, finding the factual and legal conclusions rational and supported by substantial evidence. The United States Court of Appeals for the Seventh Circuit reviewed the ALJ and District Director’s decisions directly. Applying the substantial evidence standard, the court held that the ALJ’s findings and conclusions regarding disability, causation, and the extent of impairment were supported by the record and consistent with applicable law. The court also found the employer’s challenge to the fee award waived for lack of record support and legal citation. The petition for review was denied, affirming the Board’s decision. View "Jeffboat, Inc. v Director, OWCP" on Justia Law

American Academy of Pediatrics v Uthmeier

2026-06-22T13:00:46-08:00

The case centers on a lawsuit filed by the Attorney General of Florida against the American Academy of Pediatrics (AAP) and other organizations, alleging that their advocacy for gender-affirming care violated several Florida statutes, including the state's Deceptive and Unfair Trade Practices Act, RICO Act, and antitrust law. The Florida enforcement action targeted AAP's policy statements and legal filings that supported access to gender-affirming care for transgender youth, with the Attorney General seeking significant monetary penalties and organizational restrictions. Although the lawsuit was publicized, there was a three-month delay before the organizations were served. Following the initiation of the Florida state court action, AAP, an Illinois nonprofit, filed a separate suit in the United States District Court for the Northern District of Illinois. AAP claimed that the Florida enforcement proceeding was brought in bad faith to retaliate against its First Amendment–protected advocacy. The district court granted a preliminary injunction to prevent the Florida Attorney General from pursuing the enforcement action against AAP and denied the Attorney General’s motion to dismiss, finding that personal jurisdiction and venue in Illinois were supported, and that the facts suggested the Florida action was brought in bad faith. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed only whether to stay the district court’s injunction during the expedited appeal. The Seventh Circuit denied the motion for a stay, holding that the Attorney General did not make a strong showing of likely success on the merits or irreparable harm. The court found that the bad-faith exception to Younger abstention applied based on the district court’s factual findings, and that jurisdiction and venue in Illinois were appropriate given the circumstances. The injunction against the Florida enforcement action remains in effect pending appeal. View "American Academy of Pediatrics v Uthmeier" on Justia Law

USA v Broadfield

2026-06-22T12:01:04-08:00

After serving a prison sentence for conspiracy to manufacture methamphetamine, the defendant began a term of supervised release, which included a condition that he refrain from any use of alcohol. The defendant, who is a practicing Messianic Jew, asked the court to modify this condition to allow him to drink a glass of wine during religious ceremonies on his Sabbath, arguing that the complete alcohol ban violated his rights under the Religious Freedom Restoration Act (RFRA) and imposed a greater deprivation of liberty than necessary under 18 U.S.C. § 3553(a). The defendant had a lengthy history of alcohol abuse intertwined with criminal behavior, including prior convictions related to intoxication and repeated violations of probation and supervised release conditions. Medical reports and court findings noted his inability to control alcohol consumption and recommended complete abstinence. The United States District Court for the Central District of Illinois denied the defendant’s motion to modify the supervised release condition. The court found that the government had a compelling interest in prohibiting the defendant from consuming alcohol entirely, given his history of rapid escalation from initial drinking to dangerous behavior. The court also found that alternatives—such as monitoring with breathalyzers—were not feasible for ensuring compliance and public safety, and therefore, a total ban was the least restrictive means to further the government’s interests. Reviewing the case, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The Seventh Circuit held that, under RFRA, the complete alcohol ban was the least restrictive means to further the government’s compelling interests in public safety, rehabilitation, and preventing recidivism, given the defendant’s history. The court also held that the condition did not involve a greater deprivation of liberty than necessary under § 3553(a). The district court’s denial of the motion to modify supervised release was affirmed. View "USA v Broadfield" on Justia Law

Stevens v. ICE

2026-06-22T09:31:02-08:00

A university professor submitted requests under the Freedom of Information Act (FOIA) to a federal agency, seeking the files of three named immigration detainees. The agency was slow to respond, leading the professor to file a lawsuit in the United States District Court for the Northern District of Illinois. Over the course of the litigation, the agency provided some documents but was criticized for delays and for the quality of its responses, particularly concerning certain categories of records like grievances, commissary accounts, and work program participation. The agency’s explanations for its searches and redactions—detailed in a Vaughn index—were found lacking by the district judge, who was especially critical of redactions that seemed baseless or were applied to information already in the public domain. The judge questioned the good faith of the agency and its FOIA director, ordered all contested pages released without redaction, and required additional searches and explanations. After the agency appealed, the district judge entered an injunction intended to require release of the records, but the injunction was vague and did not specify precisely what documents had to be produced or by whom they were identified. This lack of clarity made enforcement problematic. The United States Court of Appeals for the Seventh Circuit reviewed the case. It held that while sanctions against the agency for its mishandling of the FOIA requests may be justified, the district court abused its discretion by ordering wholesale release of all documents, including information potentially affecting third parties and law enforcement interests, without adequate explanation or consideration of less drastic alternatives. The appellate court vacated the injunction for lack of sufficient detail and remanded the case with instructions to reconsider the sanction and limit disclosures to information about the agency’s own operations or privileges that the agency itself could waive. View "Stevens v. ICE" on Justia Law

USA v. Jackson

2026-06-22T07:30:45-08:00

Cornelius M. Jackson was investigated after Milwaukee police responded to reports involving a woman, AV-4, who initially denied any wrongdoing but later disclosed that Jackson had choked her, threatened her, and forced her into commercial sex work. AV-4 described Jackson’s control over her activities and earnings, and her account was corroborated by pole camera footage and a bystander’s report. Based on AV-4’s statements, Waukesha police sought and received a search warrant for Jackson’s residence, where they recovered multiple electronic devices and evidence linking him to sex trafficking. Jackson was indicted for four counts of sex trafficking by force, fraud, or coercion, and one count of conspiracy to engage in sex trafficking. In the United States District Court for the Eastern District of Wisconsin, Jackson moved to suppress evidence from his electronic devices, asserting the search warrant lacked probable cause and that the supporting affidavit omitted material facts, entitling him to a Franks hearing. He also objected to the admission of expert testimony regarding sex trafficking dynamics. The district court denied Jackson’s motions, found probable cause for the warrant, determined the omissions were not material, and permitted the expert to testify with limitations. After a jury convicted Jackson on all counts, he was sentenced to concurrent terms totaling 30 years’ imprisonment. On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The court held that the warrant affidavit established probable cause, the omitted facts were not material enough to require a Franks hearing, and the district court did not abuse its discretion in admitting the government’s expert witness under Daubert and Rule 702. The judgment of conviction and sentence was thus affirmed. View "USA v. Jackson" on Justia Law

Craig v City of Richmond

2026-06-18T13:00:56-08:00

An industrial facility in Richmond, Indiana, owned by both private parties and the City of Richmond, caught fire in April 2023 and burned for more than a week. The fire caused the evacuation of nearby residents and allegedly released hazardous substances that damaged hundreds of properties and caused various injuries. Plaintiffs—both individuals and businesses—claimed that the private property owners’ failure to maintain the site and the City’s failure to remediate hazardous conditions after acquiring part of the property led to the fire. The lawsuit sought compensatory and punitive damages under several tort theories, including negligence, nuisance, trespass, and emotional distress. The plaintiffs initially filed their suit in the Wayne County, Indiana Circuit Court, but the defendants removed the action to the United States District Court for the Southern District of Indiana, arguing it qualified as a “mass action” under the Class Action Fairness Act (CAFA), and thus belonged in federal court. The district court, after briefing on whether the action fell within the CAFA “local event or occurrence” exception, concluded that the exception applied. The court found that all claims arose from the single fire event, which occurred in Indiana, and remanded the case to state court for lack of federal subject matter jurisdiction. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s remand order. The court held that the local event or occurrence exception in CAFA is jurisdictional, meaning it can be raised at any time and by the court sua sponte. The appellate court determined that all claims indeed arose from the single fire event and that the exception applied. Therefore, federal jurisdiction was lacking under CAFA. The Seventh Circuit affirmed the district court’s order remanding the case to state court. View "Craig v City of Richmond" on Justia Law

Office of the Special Deputy Receiver v Hartford Fire Insurance Company

2026-06-18T12:30:47-08:00

The Office of the Special Deputy Receiver (OSD), an Illinois non-profit that manages receiverships for insolvent insurance companies, purchased a Financial Institution Bond from Hartford Fire Insurance Company. The bond included coverage for computer systems fraud and for electronic mail initiated transfer fraud, subject to certain exclusions. Hackers infiltrated OSD’s Chief Financial Officer’s email account via a spear phishing attack, impersonated the CFO, and sent fraudulent instructions to other OSD employees, resulting in unauthorized wire transfers and a loss of nearly $4 million. OSD filed claims with both Hartford and another insurer. Hartford denied coverage, asserting that an exclusion in the bond applied to the loss. OSD sued both insurers in the United States District Court for the Northern District of Illinois, seeking declaratory relief and alleging breach of contract. The district court granted Hartford’s motion to dismiss under Rule 12(b)(6), finding that the policy’s exclusion for losses resulting from fraudulent instructions sent to OSD by email applied, and denied the other insurer’s motion. OSD later voluntarily dismissed its claims against the second company, and judgment was entered. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the dismissal de novo. The court held that the exclusion in Rider 17 of the Hartford bond unambiguously barred coverage for losses resulting from fraudulent email instructions sent to OSD—even if the sender was impersonating an internal employee—because the exclusion focused on the recipient, not the sender. The court found no ambiguity or conflict between the exclusion and other coverage provisions, and concluded that OSD’s losses fell outside the scope of coverage. The Seventh Circuit affirmed the district court’s dismissal of OSD’s claims against Hartford. View "Office of the Special Deputy Receiver v Hartford Fire Insurance Company" on Justia Law

Peters Broadcast Engineering, Inc. v PEM Consulting Group, LLC

2026-06-17T11:30:47-08:00

A small Indiana telecommunications engineering company entered into a master services agreement with a larger firm, Crown Castle, for potential construction work on cell tower sites. The agreement did not guarantee specific work or payment, and required approval of any subcontractors. Before the agreement was signed, the company began discussions with a group including the defendants about subcontracting the construction work because it lacked sufficient resources. Communications between the parties included a draft proposal but no finalized agreement. Nevertheless, work commenced, with the defendants providing crews, equipment, and funding, and the plaintiff company also supplying resources and covering expenses. Throughout the project, both parties disputed their responsibilities, and payments were made and later charged back. Eventually, the defendants contacted Crown Castle directly seeking payment, and the project ended with Crown Castle terminating its contract with the plaintiff due to poor work quality. The United States District Court for the Northern District of Indiana granted summary judgment for all defendants. The court found there was no enforceable contract, as both sides admitted no final agreement was reached and essential terms were missing. The court also rejected the plaintiff’s claims for fraudulent inducement, fraud, and negligent misrepresentation, finding no actionable reliance or advisory relationship. The claim for unjust enrichment failed because no benefit was conferred that would make retention unjust. The claim of tortious interference with business relations was dismissed because the defendants’ actions were justified by their legitimate interest in payment. The district court accordingly granted summary judgment to the insurers as well. The United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The appellate court held there was no enforceable contract, no actionable fraud or misrepresentation, no unjust enrichment, and no tortious interference, and upheld summary judgment for all defendants. View "Peters Broadcast Engineering, Inc. v PEM Consulting Group, LLC" on Justia Law

Zurbriggen v Twin Hill Acquisition, Inc.

2026-06-16T10:01:02-08:00

American Airlines contracted with a uniform manufacturer to provide new apparel for its employees. After distribution, many employees reported health issues, including skin and respiratory symptoms, allegedly connected to wearing or being near the uniforms. The airline allowed employees to stop wearing the uniforms, ultimately replacing them. Laboratory and government testing found low levels of chemicals in the uniforms but concluded these were unlikely to cause the reported symptoms. Multiple alternative causes were identified, and the scientific evidence did not support the employees' claims. A group of employees sued American Airlines, the manufacturer, and others in the United States District Court for the Northern District of Illinois, initially seeking class certification under the Class Action Fairness Act (CAFA). After several amended complaints and significant discovery disputes, the plaintiffs dropped their request for class certification, briefly raising questions about the court’s subject matter jurisdiction under CAFA. They later re-pled their class allegations in a fourth amended complaint, and the district court determined it retained jurisdiction. The defendants moved for summary judgment and to exclude the plaintiffs’ expert witnesses, arguing these experts were essential to prove defect and causation. The United States Court of Appeals for the Seventh Circuit reviewed the case. It held that the district court properly retained jurisdiction under CAFA after plaintiffs reasserted class claims. The Seventh Circuit affirmed the exclusion of the plaintiffs’ experts due to unreliable methodologies. It further held that, without expert evidence, the plaintiffs could not establish a defect or causation under strict or negligent products liability. The court also held that neither the Tweedy doctrine nor res ipsa loquitur provided an evidentiary shortcut under the case facts, since the alleged injuries did not inherently indicate a product defect or negligence. The judgment for the defendants was affirmed. View "Zurbriggen v Twin Hill Acquisition, Inc." on Justia Law

Echevarria v. Jackson

2026-06-16T07:30:48-08:00

A man was reported by a caller to have exposed himself in a public area of the Forest Preserve. The caller provided a description of the suspect and his vehicle. Officer Jackson responded, met the complainant at the scene, and was told the suspect was still present. Officer Jackson then located the plaintiff, who substantially matched the description and was driving the specified vehicle. The plaintiff was detained, cited for public indecency, and his vehicle was authorized to be towed. The plaintiff exhibited signs of distress and told the officer he suffered from PTSD. The complainant later left the scene, so the only evidence of the alleged offense was the initial call. The citation was dismissed for lack of evidence. The plaintiff brought suit in the United States District Court for the Northern District of Illinois, Eastern Division, alleging Fourth Amendment violations for unreasonable seizure of his person and property, a Monell claim against the Forest Preserve, intentional infliction of emotional distress, and malicious prosecution under Illinois law. The district court granted summary judgment to the defendants on all counts. The court deemed the defendants’ statements of fact admitted because the plaintiff failed to properly respond under Local Rule 56.1, and found that probable cause existed for the detention and vehicle seizure. The court also held the officer’s comments did not rise to the level of extreme and outrageous conduct required for an emotional distress claim. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s grant of summary judgment de novo, accepting the defendants’ facts as admitted. The Seventh Circuit held that probable cause existed to detain the plaintiff and seize his vehicle under the applicable ordinance, defeating the Fourth Amendment and malicious prosecution claims. The court also found no basis for intentional infliction of emotional distress under Illinois law. The judgment was affirmed. View "Echevarria v. Jackson" on Justia Law

USA v Pramaggiore

2026-06-15T12:30:50-08:00

The case centers on two former executives, one the CEO of an Illinois utility company and the other a lobbyist, who were involved in a series of transactions with the Speaker of the Illinois House of Representatives and his associates. These transactions included setting up contracts, some of which were for no-show jobs, that funneled over $1.3 million to the Speaker's associates over several years. The prosecution alleged that these payments were made in exchange for favorable legislative actions, and that the defendants falsified corporate books and records to conceal these arrangements, in violation of federal statutes including the Foreign Corrupt Practices Act. In the United States District Court for the Northern District of Illinois, Eastern Division, the jury convicted both defendants on all counts, including conspiracy, bribery under 18 U.S.C. § 666, and falsification of books and records. The jury’s verdict was general, without specifying which object of the conspiracy formed the basis for conviction. After the trial, but before sentencing, the Supreme Court decided Snyder v. United States, which limited the scope of § 666 to quid pro quo bribery, excluding illegal gratuities. Based on Snyder, the district court vacated the § 666 convictions and denied the defendants' motions for acquittal or a new trial on the remaining conspiracy and FCPA counts. The United States Court of Appeals for the Seventh Circuit reviewed the case and vacated the conspiracy and FCPA convictions. The court held that because the jury instructions allowed conviction based on legally invalid objects (now invalid under Snyder), and it was unclear on which theory the jury relied, the convictions could not stand. The court further rejected the argument that recent case law required acquittal on the FCPA counts, finding sufficient evidence for a properly instructed jury to convict. The court remanded for possible retrial at the government’s discretion. View "USA v Pramaggiore" on Justia Law

Betts v Boone County

2026-06-15T11:30:55-08:00

In 1977, Louise Betts was kidnapped, raped, and murdered in Boone County, Illinois. The county coroner, Wesley Hyland, conducted an autopsy and returned her body to her family for burial. Decades later, it was revealed that Hyland had secretly kept Louise’s skull, along with the skulls of other deceased individuals, as macabre trophies. In 2022, after Hyland’s death, the coroner’s office notified Louise’s brothers, Gary and Earl, of the skull’s existence, which led the family to exhume her casket to reunite her remains. The Betts brothers filed a lawsuit in the United States District Court for the Northern District of Illinois, Western Division, against Boone County and the current coroner, alleging that the county, through Hyland’s actions, violated their Fourteenth Amendment due process rights by retaining Louise’s skull without notice. They pursued their claim under 42 U.S.C. § 1983, arguing that Hyland’s conduct constituted an official county policy of unconstitutionally retaining property. The district court allowed them to amend their complaint several times but ultimately dismissed the case for failure to state a claim, concluding that Hyland’s actions did not represent official county policy under Monell v. Department of Social Services of City of New York. Upon review, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The Seventh Circuit held that the county was not liable under Monell because Illinois law expressly requires coroners to return all bodily remains to the next of kin. Hyland’s actions were contrary to, rather than representative of, official county policy. The court concluded that a municipality cannot be held liable under § 1983 when its official acts in direct violation of state law, and thus, no official policy of unconstitutional retention was established by Hyland’s conduct. View "Betts v Boone County" on Justia Law

USA v Bolden

2026-06-12T09:01:45-08:00

Police in Milwaukee received information from a confidential informant identifying a drug dealer known as “Blessed,” who was described as armed and driving a red BMW. Investigation linked the BMW to Latia Johnson at a residence on North 42nd Street, and records showed Johnson was the girlfriend of Fernando Bolden, whom the informant identified as “Blessed.” Surveillance video captured Bolden arriving at the residence with a gun and entering the house. A few days later, police obtained a warrant to search the residence, finding firearms, ammunition, large amounts of cash, fentanyl, and other drugs. Bolden was initially prosecuted in Wisconsin state court, but after it was discovered he continued drug activity while on bail, a federal grand jury indicted him on multiple drug and firearm charges. He moved to suppress the evidence from the search, arguing that the affidavit for the warrant did not establish sufficient ties between him and the residence and contained material misrepresentations or omissions. A magistrate judge in the United States District Court for the Eastern District of Wisconsin concluded that the affidavit established probable cause or, at a minimum, that the officers acted in good faith reliance on the warrant. The district court found the affidavit lacking in probable cause but still denied the suppression motion, applying the good-faith exception, and also denied Bolden’s request for a Franks hearing. Bolden then entered a conditional guilty plea, reserving his right to appeal. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s denial of the suppression motion de novo, and its factual findings for clear error. The court held that, even if probable cause was lacking, the good-faith exception applied because the officers reasonably relied on the warrant and there was no evidence of deliberate or reckless misrepresentation or omission in the affidavit. The court affirmed Bolden’s convictions. View "USA v Bolden" on Justia Law

Khouri v Highland Park CVS, L.L.C.

2026-06-11T08:30:46-08:00

A customer was injured at a retail pharmacy when numerous beverage bottles fell from a cooler shelf, striking him and causing him to fall. The coolers in the store were stocked by both employees and independent beverage vendors, with vendors responsible for the majority of products and annual “resets” involving shelf removal and cleaning. Employees did not oversee these resets or move shelves due to their weight, and had limited interaction with the shelves apart from maintaining CVS products and general cleaning. On the day of the incident, the customer saw nothing unusual about the cooler shelf, but when he removed a bottle, many others fell, resulting in his injuries. Store staff responded promptly, but neither had ever seen such an incident or received reports of defective shelves. The customer filed a negligence claim in the Cook County Circuit Court, alleging the pharmacy was responsible for his injuries. The case was removed to the United States District Court for the Northern District of Illinois based on diversity jurisdiction. Following discovery, including expert testimony limitations, the district court held a bench trial. The court found the plaintiff failed to prove negligence under the doctrine of res ipsa loquitur because the evidence did not establish that the pharmacy had exclusive control over the cooler shelves, given the substantial involvement of third-party vendors. 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 res ipsa loquitur did not apply since the plaintiff did not show that the defendant was more likely than not responsible for the injury. The court also found no abuse of discretion in the district court’s evidentiary rulings and limitations on expert testimony. View "Khouri v Highland Park CVS, L.L.C." on Justia Law

Revolinsky v Bayer Corporation

2026-06-10T12:31:15-08:00

This appeal concerns attorney fee allocation following the settlement of multidistrict litigation related to alleged injuries caused by Seresto flea and tick collars. Plaintiffs across the country, including Laura Revolinsky, brought class actions against Bayer and Elanco, claiming the products harmed their pets. Revolinsky’s attorneys sought to have these cases consolidated in New Jersey, while other plaintiffs’ counsel advocated for centralization in Missouri. The Judicial Panel on Multidistrict Litigation ultimately transferred the cases to the Northern District of Illinois, where the district court appointed lead and liaison counsel, but did not appoint Revolinsky’s attorneys to leadership positions. The court entered a case management order requiring counsel to seek advance approval for compensable work and to submit monthly reports; it generally limited compensation to work performed after leadership was appointed, though it allowed lead counsel some discretion to compensate earlier work if it benefited the class. After settlement was reached and a fund established, lead counsel applied for attorney fees, excluding pre-transfer and untimely work by Revolinsky’s attorneys. The district court approved the settlement and fee allocation, and Revolinsky’s attorneys later discovered their compensation was much less than anticipated. They did not timely object to the allocation or procedures. Instead, months after the deadline, they filed a separate motion seeking additional compensation for pre-transfer and untimely work. The United States Court of Appeals for the Seventh Circuit reviewed only the denial of this later motion. The court held that the district court did not abuse its discretion in denying the untimely motion because the procedures and deadlines for fee submissions were clear and had been reasonably enforced. The court affirmed the district court’s order, emphasizing that objections to fee allocations must be raised in a timely manner under court-established protocols. View "Revolinsky v Bayer Corporation" on Justia Law

City of Chicago v Falkner

2026-06-10T12:01:25-08:00

Two individuals filed Chapter 13 bankruptcy petitions, each proposing repayment plans that prioritized payment of their attorneys’ fees before distributing funds to nonpriority unsecured creditors, such as the City of Chicago. Both debtors had below-median incomes and lived in Illinois. One plan proposed to pay secured and priority creditors, the trustee, and attorneys’ fees, with any leftover funds distributed pro rata to nonpriority unsecured creditors. The other plan left no remaining funds for nonpriority unsecured creditors after paying attorneys’ fees. The City of Chicago objected to both plans in the United States Bankruptcy Court for the Northern District of Illinois. The City argued that these plans violated 11 U.S.C. § 1325(b)(1)(B) because they allocated projected disposable income to attorneys’ fees, claiming that bankruptcy attorneys are not unsecured creditors, and thus should not receive such payments. Alternatively, the City argued that even if attorneys are unsecured creditors, they were ineligible for payment because they had not filed proofs of claim. The bankruptcy court overruled the City’s objections, confirming both plans. The court adopted its reasoning from previous cases, finding that attorneys’ fees could be paid during the commitment period and that attorneys did not need to file proofs of claim for payment. On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the bankruptcy court’s decision. The Seventh Circuit held that Chapter 13 plans may provide for the payment of attorneys’ fees before or at the same time as payments to nonpriority unsecured creditors during the commitment period, as required by other sections of the Bankruptcy Code. The court also held that bankruptcy attorneys, as holders of administrative priority claims, are not required to file proofs of claim to receive payment under the plan. View "City of Chicago v Falkner" on Justia Law

Jewel Sanitary Napkins, LLC v Busy Beaver Publications, LLC

2026-06-10T11:30:47-08:00

Jewel Sanitary Napkins, a Georgia-based company, sells feminine hygiene products that it claims provide health benefits, including products containing graphene. The company developed a market among the Amish community and advertised its products through Busy Beaver Publications, which circulates regional advertising papers to that community. In August 2022, Busy Beaver published an ad submitted by a reader, Betty Lantz, that questioned the safety of Jewel's products, suggesting that graphene could attract electrical waves or radiation and pose health risks. The ad was published anonymously at Lantz’s request. Jewel asserted that the ad contained false statements and damaged its reputation. After the ad’s publication, Jewel contacted Busy Beaver to request a retraction, but Busy Beaver instead offered free advertising, consistent with its policy of not issuing retractions. Jewel declined and sued in the United States District Court for the Western District of Wisconsin for libel and trade libel. During discovery, Jewel sought the original ad submission. Busy Beaver initially believed the form had been destroyed per company practice, but later obtained it from Lantz and provided it to Jewel. Jewel withdrew a related spoliation motion but then sought sanctions over the delay. The district court denied Jewel’s motions, including a request to reopen summary judgment briefing, and granted summary judgment to Busy Beaver. The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. It held that, under Wisconsin law and the First Amendment standard for public figures, Jewel failed to present evidence that Busy Beaver acted with actual malice when publishing the ad. The appellate court also found no abuse of discretion in denying sanctions against Busy Beaver. The court affirmed the district court’s judgment in favor of Busy Beaver. View "Jewel Sanitary Napkins, LLC v Busy Beaver Publications, LLC" on Justia Law

United States v. Schatz

2026-06-09T13:00:46-08:00

Joshua Schatz was charged with possessing child pornography in violation of federal law and pled guilty, reserving his right to appeal the application of a statutory enhanced mandatory minimum sentence. The enhancement applies to defendants with a prior state conviction “relating to aggravated sexual abuse, sexual abuse, or abusive sexual conduct involving a minor or ward.” Schatz’s prior conviction was for child molesting under Indiana Code § 35-42-4-3(b), which prohibits sexual contact with children under fourteen. He argued that Indiana’s statute, protecting victims up to fourteen years old and lacking certain federal requirements (like an age-difference between offender and victim), was not sufficiently congruent with federal sex-abuse statutes, which generally protect children under twelve absent an age difference. The U.S. District Court for the Southern District of Indiana applied recent Seventh Circuit precedent, including United States v. Liestman and United States v. Kraemer, which interpreted “relating to” in the enhancement provision broadly. The district court found that the Indiana statute triggered the enhancement, holding that differences in victim ages and other elements were immaterial under a broad reading of “relating to.” Schatz was sentenced to the mandatory minimum of ten years’ imprisonment, which was higher than the guidelines range he would have faced without the enhancement. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the statutory interpretation de novo. Applying the categorical approach and following its prior decision in Liestman, the court held that “relating to” should be read broadly, so Indiana’s child molesting statute categorically relates to the conduct described in the federal enhancement provision. The court affirmed the district court’s judgment, ruling that the enhancement was properly applied to Schatz’s sentence. View "United States v. Schatz" on Justia Law

United States v Washington

2026-06-09T12:30:57-08:00

Frank Washington, III, was convicted after pleading guilty to possessing a firearm as a convicted felon, in violation of 18 U.S.C. § 922(g)(1). During sentencing, his presentence report calculated a guideline range of 70 to 87 months’ imprisonment. Washington requested a 57-month sentence, arguing primarily that his health issues—including high blood pressure, diabetes, and a recent heart attack—increased his vulnerability in prison. He also pointed to other mitigating factors, such as his lack of disciplinary problems in pretrial detention, no substance abuse history, his family relationships, and his acceptance of responsibility. The United States District Court for the Northern District of Indiana, Hammond Division, sentenced Washington to 70 months, at the bottom of the guideline range. The court stated that it had considered all relevant materials and recited several statutory sentencing factors, but it did not specifically address Washington’s mitigation arguments or explain how it weighed those factors in determining the sentence’s length. The court did recommend, at Washington’s request, that he be placed in a facility that could address his cardiac health needs. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether the district court provided an adequate explanation for the sentence imposed. The Seventh Circuit held that the district court’s explanation—consisting of a rote recitation of the statutory sentencing factors without individualized reasoning or discussion of Washington’s specific mitigation arguments—was insufficient under governing precedent. The appellate court vacated Washington’s sentence and remanded the case for resentencing, requiring the district court to articulate an individualized assessment that explains the chosen sentence in light of the arguments and facts presented. View "United States v Washington" on Justia Law

Johnson v Amazon.com Services LLC

2026-06-09T09:03:51-08:00

Two hourly warehouse employees for a large national retailer, on behalf of a putative class, sought compensation for overtime hours spent undergoing mandatory pre-shift COVID-19 health screenings at their workplace during the pandemic. These screenings, lasting roughly 10 to 15 minutes per shift, were required before employees could clock in and begin paid work. The employees asserted that, over time, these unpaid screenings amounted to significant uncompensated overtime in violation of the Illinois Minimum Wage Law (IMWL). The United States District Court for the Northern District of Illinois dismissed their claim, agreeing with the employer’s argument that the IMWL incorporated the federal Portal-to-Portal Act of 1947, which excludes preliminary activities, such as pre-shift screenings, from compensable work. On appeal, the United States Court of Appeals for the Seventh Circuit certified to the Illinois Supreme Court the question of whether the IMWL in fact incorporates these federal exclusions. The Illinois Supreme Court held that the IMWL does not incorporate the Portal-to-Portal Act’s preliminary activities exclusion and that the relevant state regulations define compensable “hours worked” more broadly, including all time an employee is required to be on the employer’s premises. Upon receiving this answer, the Seventh Circuit reversed the district court’s judgment. The appellate court held that the IMWL does not adopt either the preliminary activities exclusion of the Portal-to-Portal Act or the “benefit of the employer” test derived from federal law, except in two specific contexts outlined in state regulations (meal periods and travel). The case was remanded for further proceedings consistent with these interpretations. View "Johnson v Amazon.com Services LLC" on Justia Law

Hundley v. Brookhart

2026-06-09T08:31:17-08:00

A group of correctional officers was terminated by the Illinois Department of Corrections after an incident involving a wheelchair-dependent inmate who refused to comply with orders to place his hands through a cuffing port for removal of handcuffs. Instead of following certain established protocols, the lead officer decided not to activate the tactical team or notify a supervisor, but instead assembled additional officers to enter the inmate’s cell. The officers attempted to remove the handcuffs, leading to a physical altercation in which the inmate resisted, was dragged out of his cell, sprayed with pepper spray, and then left tethered in a shower area for two hours. Incident reports filed by the officers failed to accurately describe the use of force, omitting details such as dragging the inmate. Following an internal investigation, administrative hearings, and review by the Illinois Civil Service Commission, the officers were discharged for violating rules that require force to be used only as a last resort and for submitting false reports. The Commission found that the officers had other options available, had sufficient time to consider alternatives, and that the use of force was not justified as a first response. The Commission also concluded that the failure to report the incident accurately was egregious. The officers filed suit in the United States District Court for the Central District of Illinois, contending that the Department’s use-of-force rules were unconstitutionally vague and thus their termination violated their Fourteenth Amendment due process rights. The district court granted summary judgment to the defendants, finding the rules were sufficiently clear. The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. It held that the “force as a last resort” rule was not unconstitutionally vague as applied to the officers, providing fair warning of prohibited conduct, and that the truthful reporting requirements were also sufficiently clear. The grant of summary judgment for the defendants was affirmed. View "Hundley v. Brookhart" on Justia Law

Arcidiacono v Whitehorn

2026-06-08T12:31:36-08:00

Four individuals who were Medicaid beneficiaries in Illinois were admitted to long-term care facilities between 2018 and 2023. The facilities submitted required electronic admission packets to the Illinois Department of Healthcare and Family Services so that the cost of care could be reimbursed by Medicaid. In each case, the Department either rejected or mishandled these admission packets, resulting in the facilities not being reimbursed for all or part of the care provided. Despite regulations prohibiting providers from billing Medicaid beneficiaries for unreimbursed care, the facilities sent bills to the plaintiffs. The plaintiffs, however, did not pay these bills, nor did they suffer any loss of benefits or interruption in care. The plaintiffs filed a proposed class action in the United States District Court for the Northern District of Illinois against state officials responsible for Medicaid administration. They alleged violations of due process and the Medicaid Act, and requested only injunctive relief to require systemic changes in the admission packet review process. The defendants moved to dismiss, arguing both lack of standing and failure to state a claim. The district court found that the plaintiffs had standing because they received bills, but it dismissed the case for failure to state a claim, reasoning that the plaintiffs were not denied benefits or services and no statutory or constitutional rights were violated. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed only standing. The appellate court held that the plaintiffs lacked standing for injunctive relief because they did not allege a real and immediate threat of repeated injury. The prior receipt of bills did not amount to legal harm, as the plaintiffs had no obligation to pay. The court modified the district court’s judgment to reflect a jurisdictional dismissal for lack of standing and affirmed the judgment as modified. View "Arcidiacono v Whitehorn" on Justia Law