Federal Civil Practice

Harris v. W6LS, Inc.

Federal 7th Circuit Court
Civil Court
Arbitration Clause
Citation
Case Number: 
No. 24-2056
Decision Date: 
March 31, 2026
Federal District: 
N.D. Ill., Eastern Div.
Holding: 
Affirmed.
Judge: 
KOLAR

Plaintiff borrowed money from the defendant at a high interest rate and later sued the defendants under state and federal law. Defendants sought to enforce an arbitration provision in their loan contracts. The district court denied the motion to compel arbitration and defendants appealed. The Seventh Circuit affirmed, finding that there was no mutual assent where the arbitration agreement directed the arbitrator to apply a body of law that did not exist and which the defendants maintained a unilateral ability to invent and that there was no indication that the plaintiffs intended to agree to those terms. (PRYOR and MALDONADO, concurring)

Liu v. Monthly

Federal 7th Circuit Court
Civil Court
Personal Jurisdiction
Citation
Case Number: 
No. 25-2074
Decision Date: 
March 31, 2026
Federal District: 
N.D. Ill., Eastern Div.
Holding: 
Vacated and remanded.
Judge: 
KIRSCH

Plaintiff filed multiple lawsuits against online vendors for allegedly infringing on her registered trademark. The defendants failed to appear in district court and the court entered default judgment against them. Defendants eventually appeared and moved to vacate the default judgment, arguing that the district court lacked personal jurisdiction. The district court denied the motion and defendants appealed. The Seventh Circuit found that the district court erred in finding that the defendants sold products to state residents and that the remaining facts were insufficient to support a finding of personal jurisdiction. (ROVNER and MALDONADO, concurring)

Dec v. Mullin

Federal 7th Circuit Court
Civil Court
Subject Matter Jurisdiction
Citation
Case Number: 
No. 25-2417
Decision Date: 
March 30, 2026
Federal District: 
N.D. Ill., Eastern Div.
Holding: 
Affirmed.
Judge: 
BRENNAN

Plaintiff, who was present in the country unlawfully for more than one year, sought a waiver of inadmissibility in an attempt to be eligible to obtain a family-based visa. The agency denied her application of waiver and she challenged the agency’s decision in federal court. The district court dismissed the claim for lack of subject-matter jurisdiction and plaintiff appealed. The Seventh Circuit affirmed, explaining that the applicable federal statute unequivocally precludes judicial review of all agency decisions as to waivers, including eligibility determinations. (EASTERBROOK and TAIBLESON, concurring)

Overcoming Discovery Obstruction

Presented by the ISBA Tort Law Section

Co-presented by the ISBA Civil Practice & Procedure Section, ISBA Federal Civil Practice Section, ISBA General Practice Section, ISBA Insurance Law Section, ISBA Young Lawyers Division



2.25 hours MCLE credit, including 2.25 hours approved Professional Responsibility MCLE credit in the following category: Professionalism, Civility, Legal Ethics, or Sexual Harassment Prevention credit



Chicago Headline Club v. Noem

Federal 7th Circuit Court
Civil Court
Preliminary Injunction
Citation
Case Number: 
No. 25-3023
Decision Date: 
March 5, 2026
Federal District: 
N.D. Ill., Eastern Div.
Holding: 
Order vacated, appeal dismissed.
Judge: 
PER CURIAM

A group of protesters and journalists filed a lawsuit against multiple federal defendants alleging violations of their First and Fourth Amendment rights by using tear gas and other chemical agents to break up protests without justification. The district court entered an injunction regulating all federal immigration enforcement efforts district wide. The government appealed the injunction order. The plaintiffs then asked the district court to voluntarily dismiss the case by asserting that the immigration activities giving rise to the proceedings had ended. The defendants also filed a motion to dismiss the appeal and vacate the preliminary injunction. The Seventh Circuit vacated the district court’s preliminary injunction and dismissed the appeal. (EASTERBROOK, dissenting)

Svoboda v. Amazon.com Inc.

Federal 7th Circuit Court
Civil Court
Class Certification
Citation
Case Number: 
No. 25-1361
Decision Date: 
March 6, 2026
Federal District: 
N.D. Ill., Eastern Div.
Holding: 
Affirmed.
Judge: 
SCUDDER

Plaintiffs filed a class action lawsuit alleging that defendant’s virtual try-on feature violated the Illinois Biometric Information Privacy Act through its capture and use of their facial data. The district court certified a class of users in the state of Illinois and defendant filed an interlocutory appeal. The Seventh Circuit found no abuse of discretion and affirmed, explaining that common questions relating to the defendant’s liability predominate and that class certification will streamline the litigation and that the district court did not abuse its discretion in finding that users of the product lacked sufficient incentive to bring individual lawsuits. (HAMLTON and ROVNER, concurring)