The case concerned whether Renee Everett, a non-signatory to a franchise agreement between Paul Davis Restoration, Inc. (PDRI) and her husband’s company EAGB, could be compelled to arbitrate disputes under the agreement’s terms. PDRI terminated the franchise for cause and sought to enforce a non-compete provision and other obligations through arbitration; Everett sued for a declaratory judgment that she was not bound because she had not signed the contract. The district court found insufficient direct benefits to apply estoppel and vacated aspects of the arbitration award, but the Seventh Circuit reversed, holding that Everett’s 50% ownership, active operation of the franchise business, and post-termination continuation of the same operations under a new name using PDRI’s goodwill constituted direct benefits from the agreement. The court therefore enforced the arbitration award against her under the doctrine of direct benefits estoppel and rejected claims of panel bias or overreach.
This case involved Willie Diggs, who pleaded guilty to drug trafficking offenses and received a below-guidelines sentence of 282 months; after a retroactive amendment lowered the crack cocaine guidelines, he moved for a sentence reduction under 18 U.S.C. § 3582(c)(2) that would have applied the same downward variance to the new range. The district court denied the motion pursuant to USSG § 1B1.10, which bars reductions below the amended guideline minimum except in cases of substantial assistance. The Seventh Circuit affirmed, ruling that the policy statement did not violate the Ex Post Facto Clause because § 3582(c)(2) proceedings can only reduce sentences and defendants have no constitutional entitlement to retroactive guideline relief. The court further held that the Sentencing Commission acted within its statutory authority under 28 U.S.C. § 994(u) when it limited the retroactive application of the amendment.
This case involves the Central States Pension Fund seeking to collect withdrawal liability from General Warehouse, Inc. and affiliated entities after the company ceased contributing to the fund in 2005. The court affirmed the district court's summary judgment for the Fund, holding that the defendant entities were under common control with General Warehouse and thus jointly and severally liable for the $1.26 million liability. The core reasoning focused on George Cibula's acquisition of at least 80% voting control over GEOBEO through stock redemption and assignment agreements, which satisfied the regulatory definition of common control under 29 U.S.C. § 1301(b)(1) and related IRS regulations. The court also upheld the characterization of the defendants as trades or businesses based on their management activities, tax filings, and other operational factors, and confirmed there is no right to a jury trial in MPPAA withdrawal liability actions.
The case involved Norman Breedlove, who had pleaded guilty to drug trafficking and firearms offenses but was found incompetent for sentencing due to paranoid schizophrenia. The district court authorized the Bureau of Prisons to involuntarily administer antipsychotic medication to restore his competency, applying the framework from Sell v. United States. On appeal, the Seventh Circuit affirmed, holding that the district court made adequate findings on each of the four Sell factors, including that the medication was substantially likely to restore competency, was medically appropriate, and was necessary given the government's interest in sentencing. The court also rejected arguments that the treatment plan lacked sufficient detail on dosage and that competency should be reexamined shortly after the hearing.
This case concerned the allocation of costs for new high-voltage 500-kV transmission lines built in the eastern part of the PJM regional electrical grid among all member utilities. Midwestern utilities and the Illinois Commerce Commission petitioned for review of a FERC order, issued after an earlier remand, that required western members to contribute to the costs of lines from which they receive limited direct benefits under a DFAX-based methodology. The Seventh Circuit reviewed whether FERC had adequately shown that the cost shares assigned to western utilities were roughly commensurate with the benefits they would obtain. The court concluded that FERC's justification was insufficient because the evidence did not establish meaningful benefits to the western utilities from the eastern lines.
This case involved Matthew Whitfield, an African-American electrician applicant, suing Navistar (formerly International Truck and Engine Corp.) under Title VII and 42 U.S.C. § 1981 for failure to hire based on race. Whitfield applied in 1996, met the experience requirements by 1998 with an IBEW card, but was never hired despite the company filling multiple electrician positions with white applicants during the relevant period; he alleged verification issues and unstated qualifications masked discrimination. The district court ruled against him after a bench trial, excluding evidence from a related class-action trial showing extreme racial hostility at the plant. The Seventh Circuit affirmed in part but reversed in part, holding that the district court abused its discretion by excluding the class-action evidence, which was relevant to proving circumstantial discrimination and had been inconsistently treated in the proceedings, and remanded for further consideration.
