Taylor v. The Salvation Army National Corporation

Federal 7th Circuit Court
Civil Court
Labor and Employment Law
Citation
Case Number: 
No. 23-1218
Decision Date: 
August 6, 2024
Federal District: 
N.D. Ill., Eastern Div.
Holding: 
Affirmed.
Judge: 
RIPPLE

Plaintiffs, a group of five former participants in the defendant’s residential rehabilitation center, filed a lawsuit alleging that they were subjected to forced labor in violation of federal law. The district court granted the defendant’s motion to dismiss and plaintiffs appealed. The Seventh Circuit affirmed, explaining plaintiffs’ claims failed because they either participated in the program while subject to criminal sentences, which constrained their liberty, or were “walk-in” participants who were free to leave at any time and that the defendant was entitled to condition its provision of food, housing, and clothing on their continued satisfactory participation in the program. The Seventh Circuit also held that the district court correctly denied leave to amend the complaint because the proposed amended complaint did not contain plausible allegations indicating that the defendant violated the forced labor provisions at issue in the case. (SCUDDER, concurring and JACKSON-AKIWUMI, concurring in part and dissenting in part)