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Decision levers
AI-measured from their own opinions — each lever cites its cases
PurposivismTextualism
In Arnaout sentencing and Brown, the court applied statutory text and remedial schemes strictly, declining to expand the terrorism guideline retroactively or permit § 1983 actions for IDEA violations. United States v. Arnaout ↗ Brown v. District 299-Chicago Pu… ↗
The court routinely grants dispositive motions and adheres to procedural limits, as in denying class-fee windfalls in Oshana and affirming strict claim-filing deadlines in Griffin Trading. Oshana v. Coca-Cola Co. ↗ In Re Griffin Trading Co. ↗
The case involved Sírvante Brown, a student with a learning disability whose education was governed by an IEP, who challenged the Chicago Public Schools' implementation of the IEP after receiving poor grades and after a due process hearing that provided only partial relief in the form of tutoring. Brown sued under the IDEA (dismissed as untimely filed more than 120 days after the hearing), § 1983, and the ADA, alleging denial of a free appropriate public education. The court addressed the school board's summary judgment motion on the § 1983 and ADA claims, analyzing whether § 1983 could remedy statutory IDEA violations in light of Supreme Court precedent in Smith v. Robinson and congressional amendments in 20 U.S.C. § 1415(i), as well as circuit splits on the issue, and whether any ADA violation occurred from IEP noncompliance. The opinion concludes that the § 1983 claim is unavailable for IDEA violations under the comprehensive remedial scheme and that the ADA claim fails for lack of evidence of discrimination.
In this qui tam action, relator Sean Mason, a former Medline employee, alleged that the medical supply company violated the False Claims Act by providing kickbacks and bribes to healthcare providers participating in Medicare and Medicaid; these providers then submitted cost reports falsely certifying compliance with anti-kickback laws, resulting in improper government payments. Medline moved to dismiss the second amended complaint under Rules 9(b) and 12(b)(6), arguing insufficient particularity and failure to plead the required intent that the government rely on the false statements. The court denied the motion, holding that the allegations adequately linked the kickbacks to specific false claims and statements, satisfied the heightened pleading standards, and met the FCA's intent requirements under Allison Engine by showing that inducing government payment was the natural consequence of the conduct.
The case involved plaintiffs suing the Illinois State Toll Highway Authority and its officials for alleged violations of procedural due process under federal law, the Illinois Toll Highway Act, and breach of contract, stemming from difficulties in contesting erroneous toll violation notices due to system errors and inadequate contact methods. The court granted the defendants' motion to dismiss, finding that the plaintiffs lacked standing under Article III because they failed to allege a cognizable injury in fact or a probable threat of future injury. Specifically, the inconvenience experienced by the plaintiffs did not constitute a legally sufficient harm, and any potential future violations were deemed speculative.
In Oshana v. Coca-Cola Co., the plaintiff sued Coca-Cola alleging unjust enrichment and violations of the Illinois Consumer Fraud and Deceptive Business Practices Act based on nondisclosure of saccharin in fountain diet Coke, seeking damages and disgorgement on behalf of herself and a putative class. After the court denied class certification, limited the claims, and the case was removed to federal court, Coca-Cola made a Rule 68 offer of judgment for $650 plus fees and costs, which Oshana accepted, resulting in a judgment that explicitly disclaimed any admission of liability. Oshana then moved for over $1.1 million in attorneys' fees and expenses, but the magistrate judge recommended denial, and the district court adopted that recommendation in full. The court reasoned that although Oshana was technically a prevailing party, her minimal individual recovery rendered any fee award unwarranted, and the requested amount was disproportionate to the result obtained.
This case involves a patent infringement lawsuit brought by Goss International Americas, Inc. against K & M Newspaper Services, Inc. under 35 U.S.C. § 271, with K & M filing counterclaims seeking declaratory judgments of non-infringement and invalidity. The dispute centers on U.S. Patent No. 6,082,724, which covers a variable-speed inserter machine for placing advertising sheets into newspapers, consisting of article feeders and a conveyor assembly controlled by a main controller to synchronize speeds and reduce misfeeds. The court conducted claim construction for eleven disputed terms, primarily means-plus-function elements under 35 U.S.C. § 112, ¶ 6, relying on the patent specification, intrinsic evidence, and Federal Circuit precedents like Phillips v. AWH Corp. The court construed the 'article feeder means' and 'control means' elements consistent with Goss's proposals, the 'means for providing signals' element consistent with K & M's proposal, and adopted the parties' agreed constructions for all undisputed terms.
This case involves a fire that destroyed a rail bridge in Riverdale, Illinois, during reconstruction work under a contract between Metra (the commuter railroad) and Kiewit (the contractor). Metra sued Kiewit on claims including negligence, breach of contract, indemnification, strict liability, and failure to procure insurance, while Kiewit counterclaimed for breach of contract, quantum meruit, and estoppel. On summary judgment, the court granted Metra's motion on Kiewit's breach of contract counterclaim but denied it on the quantum meruit and estoppel counts, and granted Kiewit's motion on Metra's strict liability claim but denied it on the breach of contract count. The core reasoning relied on the contract's allocation of risk of loss to Kiewit prior to final acceptance, and the determination under Illinois law that welding and torch cutting do not qualify as ultrahazardous activities supporting strict liability.