This ERISA case concerned whether an employer, ProCut Concrete Sawing Services, properly withdrew from a multiemployer pension fund by sending a faxed letter to the union complaining of alleged misrepresentations about benefit eligibility. The collective bargaining agreement required notice of withdrawal to be sent by registered or certified mail. The court granted summary judgment to the Railroad Maintenance and Industrial Health & Welfare Fund, holding that the fax did not satisfy the contractual notice requirement. It reasoned that federal common law of contract interpretation requires strict compliance with unambiguous terms in the agreement, so the employer's contributions remained due. Judgment was entered for the Fund in the amount of $75,901.13 plus attorney fees.
The case involved plaintiffs, led by Aaron Wemple on behalf of "American Families," suing all Illinois judicial circuits for over $4 billion in damages, claiming that state courts lack authority to handle domestic relations matters and thereby violate due process because they were not established by Congress under Article III of the Constitution. The district court granted the lead plaintiff's motion to proceed in forma pauperis but dismissed the complaint without prejudice after screening under 28 U.S.C. § 1915(e)(2). The court reasoned that the action was frivolous because Article III governs only federal judicial power, states retain concurrent jurisdiction over domestic relations cases under the Tenth Amendment, and the Eleventh Amendment bars suits for damages against states absent waiver or congressional abrogation.
The case concerned whether the Fair Sentencing Act of 2010, which eliminated mandatory minimum sentences for certain crack cocaine offenses, applied to defendant Holloman, who committed his offense in February 2009 but pled guilty and was sentenced after the Act's August 2010 enactment and the November 2010 Sentencing Guidelines amendments. The court held that the Act applies to all defendants sentenced on or after November 1, 2010. It distinguished Seventh Circuit precedent barring retroactive application, which involved pre-Act sentencing, and reasoned that mandatory minimums are sentencing factors rather than elements of the offense, making application of the current law at the time of sentencing prospective rather than retroactive.
The case involves a federal habeas corpus petition filed by a state prisoner convicted by jury of first-degree murder, aggravated sexual assault, aggravated kidnapping, aggravated vehicular hijacking, and endangering a child's health, for which he received a death sentence later commuted to life imprisonment. After exhausting direct appeals and state post-conviction proceedings, all of which were denied, the petitioner sought habeas relief alleging numerous grounds. The court denied the petition, ruling it untimely under AEDPA's one-year limitations period, which began after direct review concluded and was tolled only during active state collateral review; the filing exceeded the limit even accounting for that tolling, and no statutory exceptions applied. The court also declined to issue a certificate of appealability due to the clear procedural bar.
The case involved an 84-year-old plaintiff who tripped and fell on a floor mat while shopping at a grocery store in Illinois, alleging that the store negligently allowed the mat to buckle and create a hazard; her husband asserted a related loss of consortium claim. The federal district court, exercising diversity jurisdiction and applying Illinois substantive law, granted the defendant's motion for summary judgment. The court examined the claims under both negligence and premises liability theories, concluding that the plaintiffs failed to present sufficient evidence of causation between the mat's condition and the fall, as required to survive summary judgment.
This case involved Linda Goetz, a former City of Springfield utility employee, who sued the city and officials after being placed on administrative leave in 2006 and later laid off, based on an erroneous belief that she had attempted to access managers' computer accounts. Goetz alleged violations including gender discrimination, retaliation, and denial of due process under Section 1983. The court granted summary judgment to the defendants on all claims except the due process claims against Mayor Timothy Davlin and Todd Renfrow, finding insufficient evidence of discriminatory intent or policy-making authority by the mayor but determining that factual issues remained regarding whether Goetz received adequate notice and opportunity to respond before her position was eliminated due to perceived misconduct. The core reasoning centered on the lack of any investigation into the computer allegations, the elimination of her budgeted position as a legitimate business decision unrelated to protected activity, and the mayor's potential involvement in the layoff decision without providing process.
