William Donald Stiehl

The plaintiff, proceeding pro se, sued the Illinois State Board of Elections, the State of Illinois, a school district, and several private businesses after his unsuccessful bid to qualify as a Republican candidate for the 2010 U.S. Senate primary. He alleged that the state's minimum signature requirement under the Election Code violated various constitutional provisions, including Article IV and the Fourteenth Amendment, and that the other defendants violated his First Amendment rights by barring him from circulating nomination petitions on their property. The court granted all defendants' motions to dismiss, ruling that sovereign immunity barred claims against the state entities, that the election-related claims were moot after the primary date, and that the remaining allegations failed to state a claim upon which relief could be granted under Rule 12(b)(6).

electionsfree speechcivil rights

In this case, plaintiff Kyle Corrington, an employee of Shred-it, sued the United States under the Federal Tort Claims Act after being stuck by used syringe needles on two occasions while shredding items at the Harry S. Truman Memorial Veterans Hospital in Columbia, Missouri. He claimed the hospital negligently disposed of the needles, leading to physical injury and emotional distress from fear of contracting diseases such as HIV or hepatitis, including the need for testing and mental anguish. The court applied Missouri law, which governs FTCA claims arising in that state, and held that recovery for emotional distress requires proof of actual exposure to the virus through a scientifically accepted method of transmission. Because the plaintiff offered no evidence of such actual exposure, the court found his fear unreasonable as a matter of law and granted the defendant's motion for summary judgment, entering judgment in favor of the United States on all claims.

torts & liabilityfederal power

This case involves a former DCFS employee who alleged race discrimination, hostile work environment, disability discrimination under the ADA, FMLA interference, retaliation, and intentional infliction of emotional distress by her supervisors and the agency, stemming from her assignment to cases, disciplinary actions, denial of accommodations for an auditory processing impairment, and her eventual termination for falsifying records in a child abuse investigation. The court addressed multiple cross-motions for summary judgment and to strike evidence. It granted DCFS's motion for summary judgment on the retaliation claim in Count V, entering judgment for the defendant, because collateral estoppel from a prior Civil Service Commission administrative decision barred relitigation of the falsification charges that justified her firing. The court denied the plaintiff's motion for summary judgment on that count, denied the motions to strike, and allowed the remaining claims in Counts I-IV to proceed against DCFS.

civil rightslabor & employment

This case concerned pro-life protesters who sued the City of Granite City, its mayor, police chief, and officers after a 2005 Christmas parade incident, alleging violations of their First, Fourth, and Fourteenth Amendment rights when police allegedly failed to protect them from hecklers and threatened assault charges while they displayed signs with graphic images of aborted fetuses. The court had previously ruled that City Ordinance 7878, which restricted the size and placement of signs near parades, was unconstitutional because it was not narrowly tailored and created a heckler's veto. After a bench trial on the remaining claims of inadequate protection and threats to prosecute, the court found in favor of the individual defendants, determining that the officers' actions were reasonable and did not violate the plaintiffs' rights, but awarded the plaintiffs $300 in minimal damages against the City solely for the effects of the invalid ordinance.

free speechcivil rightsreligious liberty

The case involved a court reporter suing the United States under the Federal Tort Claims Act for negligence after an inmate at USP Marion exposed himself to her during a deposition, claiming staff failed to properly supervise the inmate despite knowing his dangerous tendencies. The government moved to dismiss, asserting that the discretionary function exception to the FTCA preserved sovereign immunity because prison staff exercised judgment in supervising inmate visits without specific local procedures dictating their actions. The court granted the motion and dismissed the complaint for lack of subject matter jurisdiction, reasoning that the officers' decisions on how to conduct supervision were discretionary and grounded in policy considerations, even if negligently performed.

criminal lawfederal powertorts & liability

This ERISA case involved a former employee who received disability retirement benefits under an employer-sponsored plan from 1990 until 2006, when benefits were terminated after medical evaluations concluded she was only partially disabled rather than totally and permanently disabled as required by the plan. The plaintiff challenged the termination, arguing that continued benefit payments after an initial independent medical exam created an estoppel preventing the plan from denying ongoing eligibility. The court reviewed the plan administrator's decision under the arbitrary and capricious standard due to the plan's grant of discretionary authority and granted the defendant's motion for judgment on the administrative record while denying the plaintiff's cross-motion. It held that the jointly selected third doctor's binding opinion on partial disability controlled under the plan's terms and that prior payments alone could not override the written plan requirements or support an estoppel claim.

labor & employment

This case involved a products liability and negligence lawsuit brought by parents Jim Brand and Deena Perkins, individually and on behalf of their minor child Kayla Brand, against The Holmes Group, Inc., the manufacturer of a warm mist humidifier. The plaintiffs alleged that the humidifier was defective and unreasonably dangerous, and that the defendant failed to provide adequate warnings, after 15-month-old Kayla suffered burns when the unit tipped over in her room, spilling hot water on her. The court granted the defendant's motion for summary judgment on all counts. It reasoned that the humidifier was not defective or unreasonably dangerous under Illinois law because the risk of hot water and steam is an inherent and obvious property of a steam-producing humidifier that ordinary consumers would expect, the product functioned as designed, and the provided warnings were adequate.

torts & liability

The case involved pro-life protesters who regularly demonstrated in Granite City challenging Ordinance 7878, which restricted signs larger than 8.5 by 11 inches within 25 feet of four annual parade routes while exempting permanent structures and yard signs. Plaintiffs sought a declaration that the ordinance was facially unconstitutional under the First Amendment as overbroad and an impermissible heckler's veto. The court granted partial summary judgment to the plaintiffs, holding the ordinance unconstitutional. The decision rested on prior findings that the ordinance, though content-neutral, was not narrowly tailored to the city's stated interests in pedestrian flow, unobstructed views, and public safety, and the defendants offered no new justification to alter that conclusion.

free speechcivil rightsabortion

In Nichols v. Lowe's Home Center, Inc., the plaintiff sued after a wild bird flew into her head while she shopped in the outdoor gardening section of a Lowe's store, alleging the retailer provided food and water for birds and failed to warn or protect customers. She asserted claims for negligence and strict liability under Illinois’s Animal Control Act. The district court granted the defendant's motion for summary judgment, finding no genuine issues of material fact. On the negligence claim, the court held that the injury was not reasonably foreseeable, as birds do not commonly pose a danger, there were no prior incidents at the store, and a duty to guard against such events would impose an excessive burden on retailers. On the strict liability claim, the court ruled that the store was not a harborer of the bird under the Act because it did nothing more than passively allow the wild bird on its property without exercising care, custody, or control.

torts & liabilityprocedure

This case is a medical malpractice action in which plaintiffs allege that defendants Washington University Medical Center and Barnes-Jewish Hospital were negligent in performing a blood patch procedure on Catherine Deist and in failing to diagnose and treat a resulting infection. The action was filed in Illinois state court, removed to the Southern District of Illinois, and the defendants moved to transfer venue to the Eastern District of Missouri under 28 U.S.C. § 1404(a). The court granted the motions and transferred the case, finding that all relevant medical treatment occurred in Missouri, the medical records and witnesses are located there, Missouri law would likely apply, and the convenience of the parties and witnesses along with the interests of justice therefore favored transfer. Although plaintiffs' choice of forum is normally given weight, it received less deference here because the events did not occur in Illinois and the defendants are Missouri entities.

proceduretorts & liability

The case involved a seaman who sued his employer under the Jones Act and general maritime law after injuring his lower back, claiming the injury resulted from replacing a kinked face wire on a vessel. The defendant moved for summary judgment, arguing that remedying a known dangerous condition could not support a negligence or unseaworthiness claim and that causation was not established. The court granted summary judgment on the unseaworthiness claim, reasoning that injury sustained while correcting a reported defect does not render the vessel unseaworthy. It denied summary judgment on the Jones Act claim and causation, finding a genuine issue of material fact because the plaintiff's physician indicated the wire replacement could have caused the injury and the Jones Act imposes only a featherweight causation burden.

labor & employmenttorts & liability

This case concerned the government's request for criminal forfeiture of assets under Count 23 of the Superseding Indictment after the defendant was convicted by jury on Counts 1-22, which charged money laundering, monetary transactions involving proceeds of unlawful activity, and conspiracy, all arising from the operation of massage parlors that promoted prostitution in violation of Illinois law. The court determined that the defendant was guilty on the forfeiture count and ordered forfeiture of a $4,407,592 personal monetary judgment against him as well as specific real estate parcels comprising the Fantasyland complex. The core reasoning was that a preponderance of the evidence established the forfeited funds and properties were involved in or derived from the prostitution proceeds, which had been laundered through the defendant's businesses and used to finance construction and loan payoffs, making the entire complex subject to forfeiture under 18 U.S.C. § 982.

criminal lawproperty

Sunrise Healthcare Corp., which operates a nursing facility in Illinois, challenged the Secretary of Health and Human Services' decision to terminate its participation in Medicare and Medicaid programs after state inspectors found repeated deficiencies in compliance with federal requirements. The Secretary moved to dismiss the suit for lack of jurisdiction, arguing that the claims arose under the Medicare Act and required exhaustion of administrative remedies under 42 U.S.C. § 405(g) before federal court review. Sunrise contended that its challenge to the Secretary's authority to terminate participation without a finding of immediate jeopardy was collateral to any benefits claim and thus exempt from the exhaustion rule. The court granted the motion to dismiss, holding that the claims were not entirely collateral but were inextricably intertwined with the facility's desire to continue receiving federal payments, and therefore subject to the administrative channeling requirement of the Medicare Act. The court denied Sunrise's cross-motion for summary judgment as moot.

healthcareprocedurefederal power

The case arose from a 1993 car accident in Yellowstone National Park in which plaintiff Laina Eskew was injured when an RV rented from Cruise America, Inc., driven by British citizen Brian Young, turned left across oncoming traffic after Young misinterpreted a headlight flash as a yield signal, contrary to U.S. custom. Eskew sued Cruise America for negligent entrustment, alleging the company breached a duty by failing to instruct Young on American driving customs because it knew he was a foreign citizen. The court granted Cruise America’s motion for summary judgment, holding that the company owed no such duty absent actual knowledge that Young was an incompetent driver and that his British citizenship alone was insufficient to trigger any obligation to educate him on informal U.S. driving practices. The court further rejected arguments that the rental contract expanded Cruise America’s liability to cover Young’s negligence, noting the plaintiff was not a party to or third-party beneficiary of that contract.

torts & liabilityprocedure

This case involved an insurance coverage dispute in which Grinnell Mutual Reinsurance Co. sought a declaratory judgment that it had no duty to defend or indemnify Philip Shierk in a state-court negligence action brought by his wife, Stephanie Lord, after Shierk shot her in the face. Shierk had been convicted by court-martial of aggravated assault with a dangerous weapon, though he claimed the shooting was accidental. Grinnell had issued a homeowner’s policy containing exclusions for bodily injury resulting from violent crimes or acts that a reasonable person would expect to cause injury, and it had defended Shierk under a reservation of rights. The court granted Grinnell’s motion for summary judgment under Illinois law, holding that the policy exclusions applied due to the conviction and conduct, that no coverage existed, and that Grinnell was entitled to reimbursement of defense costs already paid. The decision rested on the policy language, the binding effect of the military conviction, and precedents allowing reimbursement when an insurer reserves its rights and the insured accepts the defense.

criminal lawbusiness & regulatoryproceduretorts & liability

This case involved a male employee's Title VII claims against his employer for same-sex hostile work environment sexual harassment by a male coworker, along with retaliation and disparate treatment. The court granted summary judgment to the defendant on the retaliation and disparate treatment claims but denied it on the hostile work environment claim, while barring recovery for any acts occurring before May 25, 1994. The core reasoning was that the plaintiff had long perceived the coworker's repeated gestures and conduct as sexually harassing, as shown by his multiple complaints to supervisors, and thus could not rely on incidents outside the 300-day limitations period under Galloway v. General Motors. The court allowed evidence of an initial non-harassing date request but found the ongoing pattern of offensive behavior was actionable only within the timely window.

labor & employmentcivil rights

The case involved the United States seeking to recover federal income tax refunds paid to Zeigler Coal Holding Co. for investment tax credits claimed on personal property acquired in 1986 and 1987, which the company asserted qualified as transition property under pre-1986 coal supply contracts. The court denied the government's motion for summary judgment, finding that the United States had not met its burden to show that the claimed property was not readily identifiable from the contracts or related documents such as capital expenditure summaries. On reconsideration, the court again denied summary judgment, noting that certain contracts listed specific products that aligned with the company's records and that the government must demonstrate which items failed to meet the transition rule criteria. The decision turned on the absence of a genuine issue of material fact being outcome-determinative given the government's evidentiary burden in erroneous-refund suits.

taxesbusiness & regulatory

The case involved a plaintiff suing her ERISA-qualified HMO for state-law medical malpractice on a vicarious liability theory after an ear irrigation procedure by HMO staff punctured her eardrum. The HMO moved for summary judgment, contending that ERISA preempted the claim because the plan fell under the federal statute. The court denied the motion, holding that the claim did not relate to the ERISA plan because it concerned the quality of medical treatment rather than plan administration or benefits decisions. The decision rested on the view that ERISA preemption reaches only state laws with a sufficient connection to employee benefit plans, leaving traditional malpractice actions outside its scope.

healthcarefederal powertorts & liability

This case involves a federal habeas corpus petition under 28 U.S.C. § 2254 filed by Andre Jones, who was convicted in Illinois state court of three murders and sentenced to death after pleading guilty in 1979. The petition challenged the validity of the guilty plea, the effectiveness of trial counsel, the admission of a confession to unrelated crimes at sentencing, the use of hearsay in the presentence report, and other aspects of the sentencing process. The district court reviewed the extensive state court record and denied the petition in full, dismissing all claims. The court reasoned that state court factual findings were presumed correct where supported by the record, that the petitioner failed to demonstrate any constitutional violations or that unreliable information was relied upon in sentencing, and that no evidentiary hearing was required.

criminal lawprocedure

This case involves an insurance coverage dispute arising from flood damage to property in Missouri. After the insurer filed a state court action seeking a declaratory judgment that the policy was void due to alleged misrepresentations by the insured, Hoodco, Inc. filed a federal diversity action claiming breach of the insurance contract and vexatious refusal to pay. The district court construed the insurer's motion to dismiss as a request for a stay under the Colorado River abstention doctrine. The court found the state and federal proceedings parallel because they involved substantially the same parties and issues regarding the validity of the same policy. After weighing the ten relevant factors, including the desirability of avoiding piecemeal litigation, the source of governing law, and the availability of removal, the court granted the stay.

business & regulatoryprocedure