Richard Henry Mills

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.

labor & employmentbusiness & regulatory

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.

civil rightsfederal powerfamily lawprocedure

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.

criminal law

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.

criminal lawprocedure

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.

torts & liabilityprocedure

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.

civil rightslabor & employmentprocedure

The case involved claims by the plaintiff against Abbott Laboratories for strict products liability and wrongful death, alleging that the drug Humira's label failed to adequately warn about risks of histoplasmosis, particularly when combined with other treatments, leading to the death of Jolee Mohr after she participated in a related clinical experiment. Abbott removed the case from state court to federal court and moved to dismiss based on pleading standards, the learned intermediary doctrine, and delayed service of process. The court denied the motion to dismiss, finding the claims sufficiently pleaded and that the warnings might not have been adequate, and granted the motion to remand the case back to state court in Christian County, Illinois.

torts & liabilityhealthcareprocedure

This case involved campers who held subleases on sites at a recreational campground operated by the Otter Lake Water Commission, a public entity, and who had made various improvements to those sites under prior concessionaire agreements. The plaintiffs brought a federal civil rights claim under 42 U.S.C. § 1983 alleging a deprivation of property without due process when the Commission required removal of non-conforming structures upon expiration of the concessionaire lease, along with a state-law inverse condemnation claim. The court granted the defendant's motion for summary judgment on the § 1983 claim, holding that it was not ripe because the plaintiffs had not first pursued compensation through available Illinois inverse condemnation procedures. The court then declined to exercise supplemental jurisdiction over the state claim and remanded the case to Illinois circuit court.

civil rightspropertyprocedure

This case involved former Illinois Department of Corrections Captains suing state officials and AFSCME union officials under 42 U.S.C. § 1983, alleging that their First Amendment rights were violated when the Captain position was eliminated in 2003 as retaliation for organizing efforts with a rival union, purportedly in exchange for campaign contributions to Governor Blagojevich. After more than four years of litigation and exhaustive discovery, the court found no evidence of any corrupt conspiracy or improper involvement by AFSCME officials in the elimination decision. The court granted summary judgment to the defendants, determining that the position was eliminated pursuant to the governor's pre-existing campaign promises and budget directives to streamline state government, with AFSCME having no role in the decision and the state officials prevailing in related arbitration over seniority issues.

civil rightsfree speechlabor & employment

This case involves product liability claims by plaintiff Kimberly Wallis against defendant Townsend Vision, Inc. for strict liability and negligence after she was injured operating a Townsend 7600 Skinning Machine at her workplace with Cargill Meat Solutions. The district court addressed multiple motions in limine, including one seeking to bar evidence or argument that Cargill's conduct or that of its employees contributed to the accident. The court denied the motion in part, ruling that Townsend could introduce such evidence on issues of causation and lack of product defect because Townsend had denied liability from the outset and alternative causes remain relevant even if Cargill is not named on the verdict form. The court also issued rulings on other evidentiary issues, such as allowing limited evidence from a prior sexual harassment suit against Cargill and excluding certain statistical opinions and unrelated verdict references.

torts & liabilityprocedure

The Illinois Attorney General sued two California companies and their officers under the Illinois Consumer Fraud and Deceptive Business Practices Act, alleging false or misleading statements in debt settlement services offered to Illinois consumers and seeking an injunction, civil penalties, and restitution. Defendants removed the case from state court to federal court based on diversity jurisdiction. The court granted the State's motion to remand, holding that Illinois is the real party in interest because it asserts a quasi-sovereign interest in maintaining an honest marketplace and seeks civil penalties that benefit the state treasury, meaning complete diversity is lacking under 28 U.S.C. § 1332. The decision followed the court's prior ruling in a similar case and awarded costs and fees to the State.

procedurebusiness & regulatory

This case involves a dispute between Jano Justice Systems, Inc., a provider of court management software, and its former 50% shareholder Sam Burton along with his new competing company SCB Systems, Inc. Jano sought a preliminary injunction based on claims of breach of fiduciary duty, violations of the Illinois Trade Secrets Act regarding the Clericus Magnus program, and tortious interference with business relations. The court granted the motion in part and denied it in part, issuing an order that bars the defendants from servicing, modifying, or disclosing information about Clericus Magnus or competing in the relevant market segment, but permits them to maintain existing installations with county customers. The core reasoning centered on Jano's high likelihood of success on the fiduciary duty and trade secret claims under Illinois law applicable to closely held corporations, weighed against the need to avoid undue harm to public court operations.

business & regulatorytorts & liability

In Myers v. Brunsvold, six former Site Superintendents with the Illinois Department of Natural Resources sued various state officials, claiming their layoffs violated the First Amendment by being motivated by political affiliation and deprived them of due process under the Fourteenth Amendment. The defendants moved for summary judgment, arguing the positions were eliminated solely for budgetary reasons, with no evidence of political motivation, limited personal involvement by many defendants, and adequate procedural safeguards. The court granted the motion, finding the plaintiffs failed to show political affiliation was a motivating factor or that the budgetary explanation was pretextual, while also noting defenses such as qualified immunity and lack of personal involvement applied. The opinion concluded there was no genuine issue of material fact supporting the claims in either count.

civil rightslabor & employmentfree speech

In Mutter v. Sanders, plaintiffs Gene Mutter and Mark Rice, who had been acquitted in state court of charges related to the illegal killing of a protected all-white deer in Illinois, sued conservation officers under 42 U.S.C. § 1983 and state law for alleged unlawful interrogation, detention, arrest, deprivation of property, false arrest, and malicious prosecution. The district court granted the defendants' motion for summary judgment on all claims. The court reasoned that the officers had probable cause to arrest based on witness descriptions, vehicle observations, and inconsistencies in the plaintiffs' statements about their route; the plaintiffs failed to identify clearly established law violated by the interrogation; qualified immunity applied; and the state claims failed for lack of evidence that the prosecution was without probable cause or motivated by malice.

criminal lawcivil rights

Angela Young sued her employer, the Illinois Department of Revenue, claiming her layoff was due to sex discrimination by a supervisor. A jury found in her favor and awarded $325,000 in damages. The court granted the Department's motion for judgment as a matter of law, concluding the evidence was insufficient to hold the employer liable. The core reasoning was that an independent review of the layoff recommendation by a higher official, based on the organizational chart confirming a stacked management layer, prevented imputation of any discriminatory animus to the Department.

labor & employmentcivil rights

The case involves plaintiff Lonnie Lynch, a certified Atlasprofilax Practitioner, who was investigated and arrested by state officials for practicing medicine without a license under Illinois law. While facing pending criminal charges, Lynch filed a pro se federal lawsuit under 42 U.S.C. §§ 1981 and 1983 alleging violations of the First, Fourth, and Fifth Amendments and seeking damages plus an injunction against further involvement in his prosecution. The court stayed the federal action, holding that Younger abstention applies because the suit would interfere with an ongoing state criminal proceeding and no bad faith or harassment exception was shown. The court further explained that Heck v. Humphrey does not yet bar the claims since Lynch has not been convicted, but a stay preserves the possibility of applying Heck if a conviction results.

criminal lawcivil rights

The case involved union-administered multiemployer benefit funds seeking to recover fringe benefit contributions allegedly owed by employer J.P. Phillips, Inc. for plastering work at a construction project. The employer denied any obligation, citing prior arbitrations under the National Plan for jurisdictional disputes and a project labor agreement that had resolved the work assignment in favor of employees affiliated with a competing union, and it filed a third-party breach of contract claim against the union. The court granted summary judgment to the employer on both the funds' claims and the third-party complaint, holding that the binding arbitration awards established that the union had no right to the work and that the funds could not enforce contribution provisions while disregarding the arbitration outcomes made applicable by the governing agreements.

labor & employment

Gerald Covell sued several commissioners of the Illinois Deaf and Hard of Hearing Commission under 42 U.S.C. § 1983, claiming that his termination as Director violated his Fourteenth Amendment due process rights by depriving him of a property interest in his employment without a hearing and by damaging his liberty interests through stigmatizing information. The court denied Covell's motion for partial summary judgment and granted summary judgment to the defendants on all claims. The court reasoned that Covell lacked a protected property interest in his position because the bylaws and governing act indicated he served at the pleasure of the Commission, and his liberty interest claims failed due to the absence of evidence that any defendant publicly disseminated stigmatizing statements about him.

labor & employmentcivil rights

Julie Long sued the Teachers’ Retirement System of the State of Illinois (TRS) under the Family and Medical Leave Act’s anti-retaliation provision, claiming her termination was in response to taking FMLA leave. The district court granted TRS’s motion for summary judgment after striking several paragraphs from Long’s affidavit that conflicted with her prior deposition testimony on issues such as performance counseling and the reasons for specific absences. The court found no evidence of retaliation because Long’s documented performance problems, including excessive absenteeism unrelated to FMLA, began before any protected leave, her work record was not uniformly positive, and TRS’s stated reasons for termination were supported by member complaints and other records. The court also rejected any inference of pretext based on timing or the decision-maker’s knowledge.

labor & employment

This case involved the Governor of Illinois challenging the federal government's plan under the 2005 Base Closure and Realignment (BRAC) process to move F-16 aircraft from the Capital Airport Air Guard Station and the 183rd Fighter Wing of the Illinois Air National Guard to other states. The Governor argued that statutes like 32 U.S.C. § 104(c) and 10 U.S.C. § 18238 required his consent before such changes to National Guard units or aircraft could occur. The court denied the Governor's motion for summary judgment and granted the defendants' motion to dismiss, holding that it lacked subject matter jurisdiction because Congress intended to preclude judicial review of BRAC realignment challenges. Alternatively, the court found that the cited statutes did not apply, as the BRAC Act operates under separate authority and the recommendation involved only aircraft transfers rather than relocation of a unit itself.

federal powerprocedure