Federal Civil Practice

Plaintiff filed a lawsuit against several employees of a prison where he was an inmate, alleging the defendants were deliberately indifferent to his health and safety in connection with plaintiff being attacked and injured by another inmate. The district court granted summary judgment in favor of the defendants by finding that plaintiff failed to exhaust his administrative remedies. The Seventh Circuit vacated and remanded, finding that plaintiff had offered sufficient evidence to create a genuine issue of material fact as to whether he timely filed an inmate complaint as was required to exhaust his administrative remedies. (WOOD and LEE, concurring)

Plaintiff filed a lawsuit under the Takings Clause of the Fifth Amendment after her home was badly damaged when local law enforcement executed a search warrant looking for a fugitive they incorrectly believed was inside the home. The district court dismissed the complaint, concluding that plaintiff failed to state a claim and plaintiff appealed. The Seventh Circuit affirmed, finding that plaintiff’s arguments for compensation were contrary to existing precedent. (ROVNER and SCUDDER, concurring)

Plaintiff, who was in training to be a deputy sheriff, was offered a letter of termination to sign after he was accused of circulating answers to an upcoming exam. The termination letter outlined how plaintiff’s behavior violated the sheriff’s office’s code of conduct. In response, plaintiff filed a lawsuit alleging that the letter was defamatory and deprived him of occupational liberty. The district court granted summary judgment for the defendants and plaintiff appealed. The Seventh Circuit affirmed, finding that plaintiff could not establish that the termination letter was publicly disseminated, which is a required element of defamation, and that the claim against an individual defendant was barred by absolute immunity. (ROVNER and SCUDDER, concurring)

Five citizens of India win the United States as students with F-1 visas, filed a lawsuit under the Administrative Procedure Act after they were denied re-entry after returning home for short periods of time. The district court dismissed the lawsuit for lack of subject-matter jurisdiction because the applicable statute forecloses judicial review of determinations relating to an order of removal. The Seventh Circuit affirmed, finding that neither the court of appeals nor the district court can review an expedited order of removal and that the APA does not authorize judicial review that is foreclosed by another statute. (HAMILTON and MALDONADO, concurring)

Plaintiff filed a qui tam action against defendant and 14 other drug manufacturers in federal court alleging that they falsely lowered drug prices, which led to Medicaid underpayments in violation of the Federal Claims Act. A jury returned a verdict in favor of the plaintiff, which was trebled under the provisions of the FCA. Defendant appealed, challenging the district court’s denial of its motion for summary judgment as well as they jury’s determinations on the issues of scienter and materiality. Plaintiff cross-appealed, arguing that the district court incorrectly calculated the number of violations under the FCA. The Seventh Circuit affirmed, finding no errors in the district court’s legal or factual analysis or in the jury’s verdict. (RIPPLE and JACKSON-AKIWUMI, concurring)