Federal Civil Practice

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)

After serving 10 years in prison for a murder that an Illinois court later determined he did not commit, Plaintiff filed a lawsuit under 42 U.S.C. § 1983 against the defendant City of Chicago and members of its police department alleging that his due process rights were violated by the concealment of exculpatory audio recordings. The district court determined that plaintiff failed to show that the detectives concealed or otherwise withheld the recording from the prosecutor and plaintiff appealed. The Seventh Circuit agreed and affirmed the district court’s entry of summary judgment for the defendants. (PRYOR and KOLAR, concurring)

Defendant was found guilty of seven counts of wire fraud and was sentenced to 90 months in prison in connection with an investment scheme where defendant misled investors and used upfront fees to cover a shortfall in revenue. On appeal, defendant challenged the sufficiency of the evidence and the district court’s manner of calculating the loss caused by his conduct. The Seventh Circuit Affirmed, finding that the district court did not err by finding evidence sufficient to affirm the jury’s verdict under plain error review and that the district court did not clearly err in denying a deduction in losses proposed by the defendant. (EASTERBROOK and PRYOR, concurring)

Plaintiff filed a lawsuit against defendant for infringement under the Copyright Act, alleging that the defendant illegally used his beat in a chart-topping song. The district court granted summary judgment on the merits in favor of the defendant and the court granted defendant’s motion for costs but denied his request for attorney’s fees. Plaintiff appealed the district court’s decision and defendant cross-appealed the denial of fees. The Seventh Circuit affirmed on both issues, concluding that plaintiff did not present sufficient evidence to show infringement of copyrighted work and that it was within the district court’s discretion to deny attorney’s fees and that the court’s discretion was properly exercised under the facts of the case. (BRENNAN and PRYOR, concurring)

The State of Illinois and City of Chicago filed a lawsuit seeking to prevent federalization of the Illinois National Guard after the president sought to federalize and deploy the National Guard in the state. Plaintiffs argued that none of the statutory predicates for federalizing the guard had been met and that the federalization also violated the Tenth Amendment and the Posse Comitatus Act. The district court granted plaintiffs’ request for a temporary restraining order and the administration appealed and moved for a stay of the order pending appeal. The Seventh Circuit concluded that the district court’s factual findings at the preliminary stage were not clearly erroneous and that the facts did not justify the administration’s actions. The appellate court denied the administration’s motion for a stay pending appeal, but continued to stay the portion of the order enjoining the federalization of the National Guard so that the administration remains barred from deploying the National Guard in Illinois.