7th Circuit Case Commentaries

Garcia v. Noem: Seventh Circuit Clarifies “Some-Injury” Standard Post-Muldrow and Narrows Culture-of-Discrimination Evidence under Rule 404(b)

Date: Jul 31, 2025

Garcia v. Noem: Seventh Circuit Clarifies “Some-Injury” Standard Post-Muldrow and Narrows Culture-of-Discrimination Evidence under Rule 404(b) Introduction Martin Garcia, a Mexican-American Federal...

United States v. McLain: Seventh Circuit Narrows Admissibility of Neuropsychological Evidence Offered to Negate Specific Intent

Date: Jul 31, 2025

United States v. McLain Seventh Circuit Narrows Admissibility of Neuropsychological Evidence Offered to Negate Specific Intent Introduction United States v. Auston McLain, No. 23-3384 (decided...

Christensen v. Weiss: Seventh Circuit Endorses Wisconsin’s Supervised-Social-Worker Rule and Re-affirms the “Exacting” Deliberate-Indifference Standard in Jail-Suicide Litigation

Date: Jul 31, 2025

Christensen v. Weiss: Seventh Circuit Endorses Wisconsin’s Supervised-Social-Worker Rule and Re-affirms the “Exacting” Deliberate-Indifference Standard in Jail-Suicide Litigation Introduction In...

Small v. Woods: A Seventh-Circuit Blueprint for Overcoming AEDPA Barriers When State Courts Misread the Record

Date: Jul 31, 2025

Small v. Woods: A Seventh-Circuit Blueprint for Overcoming AEDPA Barriers When State Courts Misread the Record Introduction The Seventh Circuit’s decision in Dante Small v. Ryan Woods (No. 23-1397,...

Fletcher v. Doig (7th Cir. 2025): A Denial of Summary Judgment Does Not Immunize Parties from Later Rule 11 and § 1927 Sanctions

Date: Jul 31, 2025

Fletcher v. Doig (7th Cir. 2025): A Denial of Summary Judgment Does Not Immunize Parties from Later Rule 11 and § 1927 Sanctions I. Introduction The Seventh Circuit’s opinion in Robert Fletcher &...

Denial of Summary Judgment Is No Shield from Post-Trial Sanctions – The Seventh Circuit’s Clarification of Continuing Rule 11 and § 1927 Duties in Robert Fletcher v. Peter Doig

Date: Jul 31, 2025

Denial of Summary Judgment Is No Shield from Post-Trial Sanctions – The Seventh Circuit’s Clarification of Continuing Rule 11 and § 1927 Duties in Robert Fletcher v. Peter Doig Introduction The...

Expanding the Remedial Toolkit: Seventh Circuit Confirms Monetary Sanctions Are Permissible under Rule 37(e)(1) and Sets Clear-Error Review for Intent Findings in E-Discovery Spoliation

Date: Jul 30, 2025

Expanding the Remedial Toolkit: Seventh Circuit Confirms Monetary Sanctions Are Permissible under Rule 37(e)(1) and Sets Clear-Error Review for Intent Findings in E-Discovery Spoliation Introduction...

“Active-Resistance Reasonableness” – Seventh Circuit Re-affirms Split-Second Force and Prompt Post-Restraint Care in Snukis v. Taylor

Date: Jul 30, 2025

“Active-Resistance Reasonableness” – Seventh Circuit Re-affirms Split-Second Force and Prompt Post-Restraint Care in Snukis v. Taylor 1. Introduction On 28 July 2025 the United States Court of...

“No Reliance, No Reversal” – The Seventh Circuit’s Refined Standard for PSR Errors in United States v. Swartz

Date: Jul 30, 2025

“No Reliance, No Reversal” – The Seventh Circuit’s Refined Standard for PSR Errors in United States v. Swartz 1. Introduction In United States v. David Swartz, No. 24-2459 (7th Cir. 2025), the Court...

Seventh Circuit Clarifies that Appraisers May Decide Causation and Limits Insurers’ “Right-to-Deny” After Appraisal

Date: Jul 30, 2025

Seventh Circuit Clarifies that Appraisers May Decide Causation and Limits Insurers’ “Right-to-Deny” After Appraisal Introduction Mesco Manufacturing, LLC (“Mesco”) and Motorists Mutual Insurance...

Alexander v. Kramer: Clarifying the Evidentiary Threshold for Deliberate Indifference Claims under the Eighth Amendment

Date: Jul 30, 2025

Alexander v. Kramer: Clarifying the Evidentiary Threshold for Deliberate Indifference Claims under the Eighth Amendment 1. Introduction Ricky N. Alexander, a Wisconsin inmate, sued two prison nurse...

The Upchurch Clarification: Proper State-Agency Identification under Title VII and the Evidentiary Floor for Pretext & Retaliation Claims

Date: Jul 30, 2025

The Upchurch Clarification: Proper State-Agency Identification under Title VII and the Evidentiary Floor for Pretext & Retaliation Claims 1. Introduction In Timothy Upchurch v. State of Indiana, the...

Vacated Procedural Dismissals & Damages-Only Suits: Seventh Circuit Clarifies “Law-of-the-Case” and Rooker-Feldman in Williams v. City of Aurora

Date: Jul 30, 2025

Vacated Procedural Dismissals & Damages-Only Suits: Seventh Circuit Clarifies “Law-of-the-Case” and Rooker-Feldman in Williams v. City of Aurora Introduction In Andy Williams, Jr. v. City of Aurora,...

Schroeder v. Progressive: Seventh Circuit Rejects a Stand-Alone “Methodological Duty” in Actual-Cash-Value Calculations and Re-affirms Individualized Proof Requirement for Class Certification

Date: Jul 30, 2025

Schroeder v. Progressive: Seventh Circuit Rejects a Stand-Alone “Methodological Duty” in Actual-Cash-Value Calculations and Re-affirms Individualized Proof Requirement for Class Certification 1....

“Prescription Alone Is Not Enough” – Howard v. Meli and the Knowledge Requirement for Deliberate-Indifference Claims

Date: Jul 30, 2025

“Prescription Alone Is Not Enough” – Howard v. Meli and the Knowledge Requirement for Deliberate-Indifference Claims 1. Introduction In Joshua Howard v. Anthony Meli, No. 24-3162 (7th Cir. July 24,...

No Private § 1983 Right of Action for Area Agencies Under the Older Americans Act – Commentary on Northwestern Illinois Area Agency on Aging v. Paula Basta

Date: Jul 24, 2025

No Private § 1983 Right of Action for Area Agencies Under the Older Americans Act: A Commentary on Northwestern Illinois Area Agency on Aging v. Paula Basta, 7th Cir. (2025) Introduction The Seventh...

“Non-Renewal Is Not Impairment” – Seventh Circuit Clarifies Evidence Threshold for Contracts Clause and Tort-Interference Claims

Date: Jul 23, 2025

“Non-Renewal Is Not Impairment” – Seventh Circuit Clarifies Evidence Threshold for Contracts Clause and Tort-Interference Claims 1. Introduction Alarm Detection Systems, Inc., Illinois Alarm Service,...

Impossibility Counts: Seventh Circuit Mandates Consideration of Restatement § 766A Tortious-Interference Theory and Affirms Comity to Foreign Administrative Decisions

Date: Jul 23, 2025

Impossibility Counts: Seventh Circuit Mandates Consideration of Restatement § 766A Tortious-Interference Theory and Affirms Comity to Foreign Administrative Decisions Introduction Avanzalia Solar,...

“Solely-By-Reason” and “Otherwise-Qualified” in Academic Programs – The Legacy of Royan v. Chicago State University

Date: Jul 23, 2025

“Solely-By-Reason” and “Otherwise-Qualified” in Academic Programs – The Legacy of Royan v. Chicago State University 1. Introduction On 22 July 2025 the United States Court of Appeals for the Seventh...

Function-over-Form in Abstention: Seventh Circuit Bars Immediate Appeals from Non-Dispositive Colorado River Stays

Date: Jul 22, 2025

Function-over-Form in Abstention: Seventh Circuit Bars Immediate Appeals from Non-Dispositive Colorado River Stays 1. Introduction East Gate-Logistics Park Chicago, LLC and its related developer...