Justia Civil Procedure Opinion Summaries

A minor, B.D., through his guardian, sued Samsung SDI, a South Korean battery manufacturer, after one of its batteries exploded in his pocket in Indiana. Samsung SDI moved to dismiss the complaint for lack of personal jurisdiction, which the district court granted. The court found that Samsung SDI had not purposefully availed itself of the Indiana forum through sales of individual batteries, as the battery was purchased through an unauthorized transaction.The United States District Court for the Southern District of Indiana initially denied Samsung SDI's motion to dismiss, concluding that B.D. made a prima facie case for personal jurisdiction. However, upon remand for further jurisdictional discovery, the district court granted Samsung SDI's renewed motion to dismiss, reasoning that B.D. failed to show that Samsung SDI purposefully availed itself of the Indiana forum.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The court held that Samsung SDI purposefully availed itself of the Indiana forum through an end-product stream of commerce by selling batteries to sophisticated customers, who then incorporated them into products available in Indiana. However, the court found a disconnect between Samsung SDI's purposeful contacts with Indiana and B.D.'s lawsuit, which stemmed from a consumer purchase of an individual battery. This disconnect precluded the exercise of specific personal jurisdiction over Samsung SDI. The court emphasized that the unilateral actions of third parties made individual batteries available to Indiana consumers, not Samsung SDI's deliberate actions. Thus, the court affirmed the dismissal of the lawsuit for lack of personal jurisdiction. View "B.D. v. Samsung SDI Co., Ltd." on Justia Law

Lisa Johnson and Gale Miller Anderson, former Amazon warehouse employees, alleged that Amazon violated federal and Illinois wage laws by not compensating them for time spent in mandatory pre-shift COVID-19 screenings. These screenings, which included temperature checks and symptom questions, took 10-15 minutes on average and were required before employees could clock in for their shifts. Johnson and Miller Anderson argued that this time should be compensable as it was necessary for their work and primarily benefited Amazon by ensuring a safe workplace during the pandemic.The United States District Court for the Northern District of Illinois dismissed their claims under the Fair Labor Standards Act (FLSA) and the Illinois Minimum Wage Law (IMWL). The court found that the FLSA claims were barred by the Portal-to-Portal Act of 1947 (PPA), which excludes certain pre-shift activities from compensable time. The district court also concluded that the IMWL claims failed because it assumed the IMWL incorporated the PPA’s exclusions.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether the IMWL incorporates the PPA’s exclusions for compensable time. The court noted the lack of Illinois state court decisions directly addressing this issue and found the arguments from both parties plausible. To resolve this important and unsettled question of state law, the Seventh Circuit decided to certify the question to the Illinois Supreme Court, seeking a definitive answer on whether the IMWL includes the PPA’s limitations on pre-shift compensation. The court stayed further proceedings pending the Illinois Supreme Court's decision. View "Johnson v. Amazon.com Services LLC" on Justia Law

James Reilly, a deputy in the Will County Sheriff's Office, alleged that his employer and Sheriff Michael Kelley retaliated against him for criticizing Kelley during a 2018 election campaign by not promoting him to sergeant. Reilly filed his complaint over two years after his eligibility for promotion expired. The defendants moved to dismiss the complaint, arguing it was untimely. The district court agreed, granted the motion to dismiss, and entered judgment in favor of the defendants. Reilly then requested the district court to set aside its judgment and allow him to amend his complaint, but the court denied this request, applying a heightened standard and requiring extraordinary circumstances for relief.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that the district court had mistakenly applied a heightened standard to Reilly's Rule 59(e) motion instead of the liberal standard for amending pleadings. The appellate court concluded that Reilly's proposed amended complaint stated a plausible claim for relief and that he had not pled himself out of court based on the statute of limitations. The court noted that Reilly's claim could not be conclusively determined as time-barred at this stage and that the defendants could raise the statute of limitations defense later in the case on a more complete factual record.The Seventh Circuit vacated the district court's judgment and remanded the case for further proceedings, allowing Reilly to proceed with his amended complaint. View "Reilly v Will County Sheriff's Office" on Justia Law

Ruben Santoyo, proceeding without counsel, filed a lawsuit under 42 U.S.C. § 1983 against the City of Chicago and two police officers, challenging the constitutionality of his arrest. Over three years, Santoyo repeatedly filed frivolous motions, many of which attacked the competence and integrity of the district judge. Despite numerous warnings from the judge that further frivolous filings would result in sanctions, Santoyo continued his behavior.The United States District Court for the Northern District of Illinois granted summary judgment in favor of the defendants and denied Santoyo's motions to vacate the judgment. While Santoyo's appeal of the denial was pending, the defendants moved to recover their costs. Instead of addressing the merits of this motion, Santoyo accused the defendants of bad faith and requested disciplinary action against their counsel. The district judge, having lost patience, granted the defendants' motion for costs, imposed a $1,500 sanction on Santoyo, and referred him to the district's Executive Committee, which barred future filings until the sanction was paid.The United States Court of Appeals for the Seventh Circuit reviewed the case. Santoyo argued that the district judge violated his due process rights by not notifying him of the sanction or giving him an opportunity to respond. The appellate court disagreed, noting that Santoyo had been warned multiple times about the consequences of further frivolous filings. The court held that the district judge provided sufficient notice and opportunity for Santoyo to respond, satisfying due process requirements. The Seventh Circuit affirmed the district court's imposition of sanctions. View "Santoyo v. City of Chicago" on Justia Law

Ferida H. Moy suffers from severe PTSD due to her experiences during the Yugoslav Wars. She applied for disability insurance benefits and supplemental security income, citing her PTSD and related mental health issues. An administrative law judge (ALJ) denied her application, finding that she had the residual functional capacity to perform simple, routine tasks with minimal contact with supervisors and co-workers. This decision was upheld by the district court, leading Moy to appeal.The ALJ found that Moy had moderate limitations in concentrating, persisting, or maintaining pace but concluded that she could work at a consistent production pace. The ALJ's decision was based on the testimony of a vocational expert who stated that a person with Moy's limitations could work as a dining room attendant, bus person, scrap sorter, industrial cleaner, or dishwasher. However, the vocational expert also testified that regular absences or being off-task for more than 15% of the workday would result in job loss. The ALJ's decision was affirmed by the district court.The United States Court of Appeals for the Seventh Circuit reviewed the case and found that the ALJ failed to build a logical bridge between Moy's limitations and the conclusion that she could work at a consistent production pace. The court noted that the ALJ's determination did not adequately account for Moy's limitations in concentration, persistence, and pace. The court emphasized that the ALJ's reasoning was internally inconsistent and did not reflect Moy's documented symptoms and treatment needs. Consequently, the Seventh Circuit vacated the judgment and remanded the case to the Commissioner of Social Security for further consideration consistent with its opinion. View "Moy v Bisignano" on Justia Law

Salvatore Ziccarelli, a former employee of the Cook County Sheriff's Office, used intermittent FMLA leave to manage his PTSD. In 2016, after his condition worsened, he discussed taking block leave with the FMLA coordinator, Wylola Shinnawi, who allegedly warned him against using more FMLA leave. Ziccarelli took one more day of leave and then resigned. He filed a lawsuit alleging FMLA interference and retaliation. The district court granted summary judgment for the Sheriff's Office on both claims, but the Seventh Circuit reversed and remanded the interference claim for trial.At trial, the jury awarded Ziccarelli $240,000. The Sheriff's Office moved for judgment as a matter of law under Rule 50(b), arguing that Ziccarelli could not show prejudice from the alleged interference since he took an additional day of FMLA leave after the phone call. The district court granted the motion and conditionally granted a new trial, reasoning that Ziccarelli's post-call leave negated any reasonable inference of prejudice.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court reversed the district court's entry of judgment as a matter of law, finding that the grounds for the Rule 50(b) motion were not properly presented before the verdict. However, the court affirmed the district court's alternative decision to grant a new trial, agreeing that the evidence did not support a finding of prejudice. The case was remanded for further proceedings consistent with the opinion. View "Ziccarelli v Dart" on Justia Law

Mary Ann Arnold worked for United Airlines from 1994 to 2020. She alleged age discrimination, retaliation, hostile work environment, and constructive discharge after experiencing changes in her job responsibilities and being placed on a Performance Improvement Plan (PIP). Arnold claimed these actions were due to her age and previous complaints about discrimination and harassment.The United States District Court for the Northern District of Illinois granted summary judgment in favor of United Airlines on Arnold's claims of discrimination, retaliation, and hostile work environment. The court dismissed her constructive discharge claim without prejudice, citing failure to exhaust administrative remedies.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's decision, holding that Arnold did not provide sufficient evidence to show that she suffered adverse employment actions due to age discrimination. The court also found that her retaliation claim failed because the actions taken by United were not materially adverse and were not shown to be causally connected to her complaints. Additionally, the court held that Arnold did not demonstrate a hostile work environment based on age, as the incidents she described were not severe or pervasive enough to meet the legal standard. The court also upheld the dismissal of her constructive discharge claim due to failure to exhaust administrative remedies. View "Arnold v. United Airlines, Inc." on Justia Law

Eric Holmes, an Indiana state prisoner, filed a lawsuit against the Marion County Sheriff’s Office under 42 U.S.C. § 1983, alleging unlawful imprisonment in violation of the Fourteenth Amendment. Holmes sought to proceed in forma pauperis, but the Prison Litigation Reform Act (PLRA) restricts this ability for prisoners who have had three prior civil actions or appeals dismissed as frivolous, malicious, or for failing to state a claim.The United States District Court for the Southern District of Indiana found that Holmes had incurred three strikes under the PLRA. The court determined that a previous case dismissed for failure to state a claim because it was barred by Heck v. Humphrey counted as Holmes’s third strike. Holmes did not contest the validity of his first two strikes. He filed a notice of appeal and moved to proceed in forma pauperis on appeal, but a motions panel of the Seventh Circuit denied his motion, identifying a different case dismissed due to judicial immunity as his third strike.The United States Court of Appeals for the Seventh Circuit reviewed whether dismissals based on affirmative defenses, such as those barred by Heck or due to judicial immunity, count as strikes under the PLRA. The court held that a case dismissed for failure to state a claim because it was barred by Heck counts as a strike if the Heck bar is clear from the face of the complaint. Similarly, a case dismissed on judicial immunity grounds incurs a strike if the immunity defense is clear from the face of the complaint. The court affirmed the district court’s dismissal of Holmes’s current suit, concluding that both the Heck dismissal and the judicial immunity dismissal counted as strikes. View "Holmes v Marion County Sheriff's Office" on Justia Law

Carl and Roberta Culp filed a lawsuit alleging federal and state law claims against various defendants, including Fort Wayne and Allen County police officers. The claims included excessive force under 42 U.S.C. § 1983, intentional and negligent infliction of emotional distress, assault and battery, criminal mischief, and violations of the Rehabilitation Act and the Americans with Disabilities Act (ADA). The incident in question occurred on August 20, 2018, when Carl Culp, a double amputee, expressed suicidal intentions during a psychiatric appointment, leading to police intervention.The United States District Court for the Northern District of Indiana granted summary judgment in favor of the defendants on most claims, leaving only Carl Culp’s § 1983 excessive force claim and state law claims against Officers Woods and Schulien for trial. A jury found in favor of the defendants on all claims except for Roberta Culp’s state law battery claim against Officer Woods, awarding her nominal damages of $1. The Culps appealed the summary judgment decision, and Woods and Schulien cross-appealed the denial of costs.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the district court did not err in granting summary judgment to the defendants, as the defendants’ brief complied with the local rules. The court also found that the Culps failed to present evidence of discrimination or failure to accommodate under the ADA and Rehabilitation Act. The court assumed, without deciding, that these laws applied to law enforcement actions but concluded that the evidence did not support the Culps' claims.Regarding the cross-appeal, the Seventh Circuit upheld the district court’s decision to deny costs to both parties, recognizing the mixed outcome of the case. The court affirmed the district court’s judgment in its entirety. View "Culp v. Caudill" on Justia Law

Jacqueline Sterling failed to pay $500 in gym membership fees to Southlake Nautilus Health and Racquet Club, leading to a default judgment against her in the Superior Court of Lake County, Indiana. Despite a bankruptcy court discharging her debt, Southlake continued to enforce the judgment. Sterling did not notify the Lake County court of her bankruptcy or appear at a hearing, resulting in a bench warrant for her arrest. A year later, she was arrested during a traffic stop and spent a weekend in jail, missing work and suffering emotional distress.The bankruptcy court found Southlake in civil contempt for violating the discharge order and contributing to Sterling's arrest and resulting damages. The court also found Sterling partially at fault for not notifying the Lake County court of her bankruptcy. Applying comparative fault principles, the court allocated half the liability for Sterling's lost wages, emotional distress, and attorney’s fees to each party. Sterling was awarded $9,724.50 in compensatory damages and $99,355 in attorney’s fees.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that while compensatory damages in civil contempt proceedings must be awarded if the complainant proves the defendant's actions caused the injury, the court has broad discretion in awarding attorney’s fees. The bankruptcy court erred by not recognizing this distinction and improperly applied comparative fault principles to reduce the attorney’s fees award. The Seventh Circuit vacated the judgment in part and remanded the case to the bankruptcy court to reassess the attorney’s fees in light of its broad discretion. The court also clarified that costs should be allowed and directed the bankruptcy court to set a deadline for Sterling to file a bill of costs. View "Sterling v Southlake Nautilus Health & Racquett Club, Inc." on Justia Law