Rao v. J.P. Morgan Chase Bank, N.A.

Federal 7th Circuit Court
Civil Court
Defamation
Citation
Case Number: 
No. 24-1347
Decision Date: 
August 27, 2025
Federal District: 
N.D. Ill., Eastern Div.
Holding: 
Affirmed in part, reversed in part, remanded.
Judge: 
JACKSON-AKIWUMI

Plaintiff filed a lawsuit alleging defamation, contending that statements made by the defendants led to allegations of fraud and misconduct against the plaintiff in probate court. The district court dismissed several claims, including one brought under the Illinois Consumer Fraud and Deceptive Business Practices Act and then granted summary judgment to the defendants on the remaining claim of defamation per se. The Seventh Circuit affirmed the dismissal of the consumer fraud claim because there was no allegation that defendants gave estate administrators unauthorized access to personal information but reversed the entry of judgment on the defamation per se claim because the statements were not subject to an innocent construction and a privilege did not apply. (BRENNAN and KOLAR, concurring)