Federal Civil Practice

In a contract dispute, plaintiffs filed a lawsuit seeking enforcement of guaranties in connection with plaintiffs’ leasing out of several skilled nursing facilities where the tenants breached their leases. Plaintiffs successfully sought to dismiss one of the defendants in order to maintain diversity jurisdiction and the district court ultimately granted summary judgment in favor of the plaintiffs. The remaining defendant then appealed, arguing that the district court improperly dismissed his non-diverse former co-defendant and, in the alternative, that the district court erred when it granted summary judgment on damages. The Seventh Circuit reversed and remanded as to the calculation of two narrow categories of damages but otherwise affirmed the judgment of the district court. (ROVNER and SCUDDER, concurring)

Plaintiffs filed a lawsuit against their former employer alleging that their constitutional and statutory rights were violated by the employer’s Covid-19 vaccination policy. Plaintiffs’ claims were not based on a denial of a religious exemption, which they were granted, but rather that their rights were violated when they were required to input their vaccination status and Covid-19 testing results into a database. The district court dismissed the complaint for failure to state a claim and the Seventh Circuit affirmed. (RIPPLE and KIRSCH, concurring)

Plaintiffs alleged that the defendants denied the plaintiffs’ request for a permit to operate an outdoor beer garden in retaliation for Plaintiff’s political speech. The district court declined to enter a preliminary injunction in favor of the plaintiffs, finding that they were unlikely to succeed on the merits because they conceded that they violated many permit conditions and could not point to any evidence of pretext for the permit denial. The Seventh Circuit agreed and affirmed. (EASTERBROOK and ST. EVE, concurring)

The Seventh Circuit considered a motion for sanctions in a family law case that was removed from state court to the federal district court and was then remanded back to the state court for lack of jurisdiction. The defendant that removed the case to federal court appealed and the Seventh Circuit dismissed the case for lack of appellate jurisdiction. The non-moving party moved for sanctions under Rule 38 of the Federal Rules of Appellate Procedure, arguing that the appeal was frivolous. The Seventh Circuit granted the motion and found that the request for attorney’s fees and costs was just and reasonable. (HAMILTON and JACKSON-AKIWUMI, concurring)

Plaintiffs, as heirs of a German art collector who was persecuted by the Nazi government, brought federal legal action against defendants seeking to recover a painting by Vincent van Gogh. Plaintiffs alleged that defendants wrongfully converted the painting and exploited it for financial gain. The district court dismissed the various counts of the complaint and plaintiffs appealed. The Seventh Circuit affirmed, finding that two counts of the complaint did not present a federal cause of action and, even if they did, the district court lacked in personam jurisdiction over the defendants. The appellate court likewise determined that the court lacked in personam jurisdiction over the defendants on the remaining claims. (LEE and PRYOR, concurring)

Plaintiff brought a wrongful conviction lawsuit under 42 U.S.C. § 1983 against the City of Chicago after his sentence for murder was vacated. A jury found in favor of the plaintiff and awarded damages for pain, suffering, and loss of a normal life. The district court awarded him prejudgment interest for the more than six years it took for plaintiff to obtain the judgment in his favor. The defendant appealed the award of prejudgment interest, arguing that it was not available as a matter of law for non-economic damages or, in the alternative, that the district court abused its discretion. The Seventh Circuit affirmed in all respects but remanded with instructions for the district court to recalculate the interest award after apportioning the jury’s verdict between past and future damages because future damages are not interest-eligible. (BRENNAN and MALDONADO, concurring)

Plaintiffs filed a lawsuit against a clothing manufacturer bringing a variety of claims, including breach of warranty and personal injury related to dye used in uniforms made by defendant and worn by the plaintiffs that they alleged leached onto their property and caused medical symptoms. The district court entered summary judgment in favor of the defendant on the breach of warranty and personal injury claims and plaintiffs appealed. The Seventh Circuit affirmed, finding that plaintiffs failed to offer expert testimony establishing that the uniforms were defective and because the plaintiffs failed to abide by the warranty’s reasonable terms. (PRYOR and MALDONADO, concurring)