Justia Civil Procedure Opinion Summaries

An inmate at a Wisconsin correctional institution was attacked by another prisoner, resulting in serious injury. The inmate alleged that prison officials were aware of the risk of such an attack but failed to take preventive action. After the incident, medical staff did not arrange for the inmate to see a specialist within the recommended timeframe. The inmate claimed to have filed a formal complaint about both the lack of protection and inadequate medical care by placing a completed complaint form in his cell door for collection on January 2, 2017. He did not receive an acknowledgment of receipt and, after inquiring with a complaint examiner a month later, was told no complaint had been received. He then filed a new complaint, referencing his earlier attempt and supporting it with a journal entry and correspondence to other inmates.The United States District Court for the Western District of Wisconsin granted summary judgment to the defendants, concluding that the inmate failed to exhaust administrative remedies as required by the Prison Litigation Reform Act. The court relied on the Seventh Circuit’s decision in Lockett v. Bonson, finding that the inmate’s evidence was insufficient to show timely filing and that he should have followed up sooner when he did not receive an acknowledgment.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The appellate court found that, unlike in Lockett, the inmate provided more than a mere assertion of timely filing, including a sworn declaration, a journal entry, and references in subsequent complaints. The court held that this evidence created a genuine dispute of material fact regarding whether a timely complaint was filed. The Seventh Circuit vacated the district court’s judgment and remanded the case for further proceedings, instructing the lower court to determine whether the exhaustion issue is intertwined with the merits, which could entitle the parties to a jury trial under Perttu v. Richards. View "Breyley v. Fuchs" on Justia Law

Several pilots were terminated by United Airlines after the company implemented a COVID-19 vaccine mandate. These pilots, represented by their union, the Air Line Pilots Association (ALPA), believed that the union did not do enough to oppose United’s vaccination policies. The pilots had previously filed grievances challenging the mandate, arguing that United’s actions violated the status quo required under the Railway Labor Act because the collective bargaining agreement had expired. ALPA did not support these grievances or file its own, but did file a separate grievance arguing that termination for being unvaccinated was not justified. The pilots’ termination grievances remain pending at their request.After their terminations, the pilots sued ALPA in the United States District Court for the Northern District of Illinois, Eastern Division, alleging that the union breached its duty of fair representation by failing to adequately oppose United’s vaccine mandate. ALPA moved to dismiss the complaint, arguing that the claim was unripe and failed to state a claim. The district court denied the motion to dismiss for lack of ripeness but granted the motion to dismiss for failure to state a claim. The court also denied the pilots’ request to file an amended complaint, finding that amendment would be futile.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s decisions de novo. The Seventh Circuit held that the case was ripe because the pilots’ alleged harm—termination—had already occurred. However, the court affirmed the dismissal, holding that the pilots failed to plausibly allege that ALPA’s actions were arbitrary, discriminatory, or in bad faith, as required to state a claim for breach of the duty of fair representation. The court also affirmed the denial of leave to amend, finding that the proposed amended complaint would not cure the deficiencies. The judgment of the district court was affirmed. View "Wickstrom v Air Line Pilots Association, International" on Justia Law

Dr. Padma Rao brought a defamation suit against JP Morgan Chase Bank and its employee, Keifer Krause, after Krause informed the administrator of her late mother’s estate that Rao, acting under a power of attorney, had designated herself as the payable on death (POD) beneficiary of her mother’s accounts. This statement led the estate administrator to accuse Rao of fraud and breach of fiduciary duty in probate court. The dispute centered on whether Rao had improperly used her authority to benefit herself, which would be illegal under Illinois law.The case was initially filed in Illinois state court, but Chase removed it to the United States District Court for the Northern District of Illinois before any defendant was served, invoking “snap removal.” The district court dismissed all claims except for defamation per se. On summary judgment, the court ruled in favor of the defendants, finding that Krause’s statements were not defamatory, could be innocently construed, and were protected by qualified privilege. Rao appealed both the dismissal of her consumer fraud claim and the grant of summary judgment on her defamation claim.The United States Court of Appeals for the Seventh Circuit first addressed jurisdiction, dismissing Krause as a party to preserve diversity jurisdiction. The court affirmed the dismissal of Rao’s consumer fraud claim, finding she had not alleged unauthorized disclosure of personal information. However, it reversed the summary judgment on the defamation per se claim against Chase, holding that Krause’s statements could not be innocently construed and that a qualified privilege did not apply, given evidence of possible recklessness. The case was remanded for a jury to determine whether the statements were understood as defamatory. View "Padma Rao v J.P. Morgan Chase Bank, N.A." on Justia Law

The petitioner, who entered the United States without authorization in 2006, lived with his wife and three children, all of whom are U.S. citizens. He was the primary financial provider for the family, earning significantly more than his wife and providing health insurance for the household. The family faced removal proceedings after the petitioner was arrested for driving on a suspended license and leaving the scene of an accident. The petitioner argued that his removal would cause his children exceptional and extremely unusual hardship, citing their emotional distress and the family’s financial dependence on him.An immigration judge found that the petitioner met all statutory requirements for cancellation of removal except for the “exceptional and extremely unusual hardship” standard. The judge determined that, while the family would experience financial and emotional difficulties, these did not rise above what is typically expected in removal cases. The petitioner appealed to the Board of Immigration Appeals, which affirmed the immigration judge’s decision, assuming for the sake of argument that all three children were qualifying relatives.The United States Court of Appeals for the Seventh Circuit reviewed the case, holding that it had jurisdiction to consider legal questions related to the application of the hardship standard. The court applied a deferential standard of review, as suggested by recent Supreme Court precedent, and concluded that the immigration judge’s findings were supported by substantial evidence and were not clearly erroneous. The court held that the petitioner had not demonstrated that his removal would result in hardship substantially beyond what is ordinarily expected in such cases. Accordingly, the Seventh Circuit denied the petition for review. View "Santos Mendoza v. Bondi" on Justia Law

A group of individuals in the custody of the Illinois Department of Corrections (IDOC) filed a lawsuit in 2007, alleging inadequate mental healthcare. The case developed into a class action, and in 2016, the parties reached a settlement agreement that required IDOC to meet specific mental-health treatment benchmarks. The agreement included a provision for $1.9 million in attorney’s fees to be paid to plaintiffs’ counsel if the court granted relief for violations of the agreement. In 2018, the district court found IDOC in breach and issued an injunction, triggering the fee provision. While the defendants appealed, the parties entered into further agreements, resulting in the $1.9 million being paid to plaintiffs’ counsel.The United States District Court for the Central District of Illinois later extended its enforcement jurisdiction over the settlement agreement, but after the expiration of that jurisdiction, the court returned the case to its active docket. The parties continued to litigate, with plaintiffs filing amended complaints and defendants moving to dismiss. More than a year after resuming active litigation, the district court raised concerns about its subject-matter jurisdiction, ultimately concluding that its jurisdiction over the underlying claims ended when its enforcement jurisdiction over the settlement agreement expired. The court dismissed all claims and denied the defendants’ motion to recover the $1.9 million in attorney’s fees.The United States Court of Appeals for the Seventh Circuit reviewed the case. It held that, under the parties’ agreements, the payment of $1.9 million in attorney’s fees to plaintiffs’ counsel was proper and did not need to be returned, even after the district court’s injunction was vacated. The court also vacated the district court’s dismissal of the underlying claims, remanding for the district court to determine whether the settlement agreement moots those claims. The Seventh Circuit affirmed the denial of the defendants’ motion to recover the attorney’s fees. View "Daniels v. Jones" on Justia Law

Indiana enacted a statute making it a misdemeanor for a person to knowingly or intentionally approach within 25 feet of a law enforcement officer who is lawfully engaged in official duties, after being ordered by the officer to stop approaching. Several media organizations and news outlets challenged this law, arguing that it is unconstitutionally vague under the Fourteenth Amendment because it allows police officers too much discretion in deciding when to issue a do-not-approach order, potentially leading to arbitrary or discriminatory enforcement. The plaintiffs asserted that the law chills their newsgathering activities, as journalists often need to approach police officers in public spaces to report on events.The United States District Court for the Southern District of Indiana denied the State’s motion to dismiss for lack of standing, finding that the plaintiffs had sufficiently alleged injury in fact. The district court then granted a preliminary injunction, concluding that the plaintiffs were likely to succeed on their Fourteenth Amendment vagueness claim, would suffer irreparable harm without relief, and that the balance of harms and public interest favored an injunction. The court did not address the plaintiffs’ First Amendment claims. The State appealed the preliminary injunction to the United States Court of Appeals for the Seventh Circuit, arguing that the law was not unconstitutionally vague and that the plaintiffs lacked standing.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s preliminary injunction. The appellate court held that the plaintiffs had standing and that the case was not moot, even though a second, narrower buffer law had been enacted. The court found that the original buffer law was unconstitutionally vague because it gave law enforcement officers unfettered discretion to decide when to issue a do-not-approach order, thus encouraging arbitrary or discriminatory enforcement. The court remanded the case for the district court to reconsider the appropriate scope of the injunction in light of recent Supreme Court precedent limiting universal injunctions. View "Reporters Committee for Freedom of the Press v. Rokita" on Justia Law

Monica Richards, a long-time employee in her early fifties, applied for a promotion at Eli Lilly & Company after serving as an interim District Sales Manager. The promotion was instead awarded to a younger, less experienced candidate. Richards filed suit in federal court, alleging age discrimination under the Age Discrimination in Employment Act (ADEA) and Massachusetts law. She sought to proceed collectively on behalf of all Eli Lilly employees aged 40 or older who were denied promotions since February 2022, claiming a companywide bias favoring “Early Career Professionals” over older employees.In the United States District Court for the Southern District of Indiana, Richards moved for conditional certification of a collective action and requested that notice be sent to potential opt-in plaintiffs. The parties disputed the appropriate standard for issuing such notice. The district court applied the Lusardi “modest factual showing” standard, declined to consider the employer’s opposing evidence, and granted conditional certification, agreeing to send notice. Recognizing uncertainty in the law, the district court certified the question for interlocutory appeal under 28 U.S.C. § 1292(b).The United States Court of Appeals for the Seventh Circuit reviewed the case to clarify the standard for issuing notice in Fair Labor Standards Act (FLSA) and ADEA collective actions. The court held that, before notice may issue, plaintiffs must present evidence raising a material factual dispute as to whether the proposed collective is similarly situated. Both parties’ evidence must be considered, and the district court retains discretion to manage the process, including authorizing limited discovery or narrowing the scope of notice. The court rejected both the lenient Lusardi standard and heightened standards requiring proof by a preponderance of the evidence or a strong likelihood of similarity. The Seventh Circuit vacated the district court’s order and remanded for further proceedings under the clarified standard. View "Richards v. Eli Lilly & Company" on Justia Law

In a suburban shopping center parking lot on July 1, 2016, Michael Cokes, Isaiah Stevenson, and Ronald Arrington waited in a car while Jimmie Malone robbed a restaurant manager. After the robbery, the men drove away with Malone, who later took over as the driver. When Illinois state troopers stopped the car, the men refused to exit, and Malone sped off, leading to a high-speed chase. During the chase, Chicago Police Officer Dean Ewing, driving an unmarked car, collided with the Pontiac, resulting in serious injuries to Cokes, Stevenson, and the officers in Ewing’s car, and the deaths of Malone and Arrington.The plaintiffs, including Arrington’s estate, sued the City of Chicago and Officer Ewing, alleging various torts related to the collision. After a nine-day trial, a jury found in favor of the defendants on all claims. The plaintiffs then moved for a new trial, challenging the district court’s decisions on affirmative defenses, jury instructions, and the admissibility of evidence. The district court denied these motions, leading to the current appeal.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s decisions. The appellate court found no legal error or abuse of discretion in the district court’s handling of the affirmative defenses, jury instructions, and evidentiary rulings. Specifically, the court upheld the district court’s decisions to allow the defendants to plead a joint enterprise theory of contributory negligence, to admit testimony about Arrington’s conduct under Federal Rule of Evidence 601 rather than the Illinois Dead Man’s Act, and to exclude the COPA report under Rule 403. The appellate court concluded that any potential errors did not substantially affect the jury’s verdict. View "Arrington v. City of Chicago" on Justia Law

Chosen Consulting, LLC, doing business as Chosen Healthcare, and other related entities (collectively "Chosen") filed a lawsuit against the Town Council of Highland, Indiana, the Highland Municipal Plan Commission, and the Town of Highland, Indiana (collectively "the Town"). Chosen alleged that the Town discriminated against patients with addiction-related ailments by refusing to provide a letter stating that Chosen’s proposed use of its property complies with local zoning requirements. Chosen claimed this discrimination violated the Americans with Disabilities Act (ADA) and the Rehabilitation Act of 1973, seeking compensatory, injunctive, and declaratory relief.The United States District Court for the Northern District of Indiana granted summary judgment to the Town. The district court held that Chosen's claim for injunctive relief under the ADA and the Rehabilitation Act was not ripe for adjudication because Chosen had not obtained a final decision from the local zoning authorities. The court indicated that Chosen needed to pursue its request for zoning approval through the Board of Zoning Appeals (BZA) and, if necessary, appeal any final decision entered by the BZA to the state courts before seeking an injunction in federal court.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The Seventh Circuit held that Chosen's claim for injunctive relief was not ripe because Chosen had not satisfied the finality requirement set forth in Williamson County Regional Planning Commission v. Hamilton Bank of Johnson City. The court emphasized that Chosen needed to follow the local zoning procedures, including applying for a use variance or seeking a declaratory judgment in state court, to obtain a final decision from the Town. Until Chosen completed these steps, the dispute was not ripe for federal court review. View "Chosen Consulting, LLC v Town Council of Highland" on Justia Law

Christian Arnold retained Binder & Binder in April 2018 to represent him in a claim for disability benefits under the Social Security Act. After the Commissioner of Social Security denied his claim, Arnold appealed to the district court, which remanded the case to the agency. An administrative law judge later determined Arnold was entitled to $160,797.10 in past-due benefits. Binder then moved for attorneys' fees under 42 U.S.C. § 406(b), seeking twenty-five percent of the retroactive benefits, amounting to $40,199.27. The district court awarded Binder $16,920, reducing the fee based on an effective hourly rate of $600.The United States District Court for the Central District of Illinois initially awarded Binder $16,920, despite the contingency fee agreement. Binder appealed, and the United States Court of Appeals for the Seventh Circuit held that the district court abused its discretion by not anchoring its reasonableness analysis on the contingency fee agreement. The case was remanded for further proceedings. On remand, the district court again awarded $16,920, maintaining that the contingency fee should be reduced to reflect a more reasonable effective hourly rate. Binder appealed once more.The United States Court of Appeals for the Seventh Circuit reviewed the case and found that the district court abused its discretion by inadequately explaining its decision to reduce Binder’s fees. The appellate court emphasized that the district court must begin with the contingency fee agreement and consider relevant factors, such as the plaintiff’s satisfaction and the attorney’s expertise. The appellate court reversed the district court’s decision and remanded with instructions to order the Social Security Administration to remit attorneys’ fees at Binder’s requested amount of $34,199.27. View "Arnold v. Bisignano" on Justia Law