The case involves T.S., a minor with autism enrolled in his parent's self-funded employer health plan sponsored by Heart of CarDon, LLC, a healthcare provider that receives Medicare and Medicaid funds. T.S. sued under section 1557 of the Affordable Care Act, alleging that the plan's exclusion of coverage for autism treatment constituted disability discrimination. The district court denied CarDon's motion for judgment on the pleadings, which argued that T.S. fell outside the statute's zone of interests because he was not an intended beneficiary of the federal funding received by CarDon. On interlocutory appeal, the Seventh Circuit affirmed, holding that section 1557's text and purpose, incorporating enforcement mechanisms from the Rehabilitation Act, protect plaintiffs like T.S. and that any narrower intended-beneficiary limitation from prior precedent had been abrogated by the Civil Rights Restoration Act's expansion of covered programs and activities.
The case involved claims under 42 U.S.C. § 1983 by the estate of Roger Gonzalez, a pretrial detainee with serious medical conditions including obesity, hepatitis C, renal failure, and heart failure, who was held in McHenry County jail, experienced multiple medical incidents and hospitalizations, and later died in state prison custody. The plaintiff alleged that the jail maintained an unwritten policy of accepting all pretrial detainees regardless of its ability to meet their medical needs and that the sheriffs knew of but ignored these conditions. The Seventh Circuit affirmed the district court's dismissal of the claims against the county and the current and former sheriffs. The court reasoned that the complaint did not plausibly allege objectively unreasonable conduct in response to the detainee's needs, that sheriffs have no authority to release court-committed detainees on their own initiative, and that there was no personal involvement by the former sheriff or underlying constitutional violation to support Monell liability.
The case involved Marvin Thomas, a pretrial detainee at Cook County Jail who was assaulted by another inmate in 2016 and later sued Sheriff Thomas Dart, Cook County, and various jail personnel under 42 U.S.C. § 1983 and other federal statutes, alleging failure to protect him from harm. Years into the litigation, after multiple amendments and discovery, Thomas moved to file a third amended complaint adding two new defendants—the intake clerks who screened him—and new claims that they deliberately altered forms to conceal his reported PTSD, which allegedly contributed to his placement in a unit where he was assaulted. The district court denied the motion to amend, and Thomas appealed, also claiming judicial bias based on adverse rulings. The Seventh Circuit affirmed, holding that the proposed amendment was futile because the allegations did not plausibly show the clerks knew of and disregarded a substantial risk of assault to Thomas, and that the district court's rulings provided no reasonable basis to infer bias under 28 U.S.C. § 455(a).
In United States v. Michael Sarno, a federal inmate serving a 25-year sentence for racketeering conspiracy and operating an illegal gambling business moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A), citing severe physical disabilities including osteoarthritis that left him unable to walk or care for himself. The district court assumed his medical condition presented an extraordinary and compelling reason for release but denied the motion after determining that the sentencing factors in 18 U.S.C. § 3553(a), including the seriousness of the offense, respect for the law, criminal history, and danger to the public, weighed strongly against it. On appeal, the Seventh Circuit reviewed for abuse of discretion and affirmed, holding that the district court properly weighed the factors, addressed the evidence, and that any errors regarding certain government assertions were harmless because they would not have changed the outcome. The court noted that even one valid reason under § 3553(a) suffices to deny relief.
AFM Mattress Company sued its insurer Motorists Commercial Mutual Insurance Company for a declaratory judgment of coverage under a commercial policy for business income losses, extra expenses, and civil authority losses after government orders closed its stores due to the COVID-19 pandemic. The district court dismissed the amended complaint with prejudice. The Seventh Circuit affirmed, holding that the policy's Virus Exclusion—which states the insurer will not pay for loss or damage caused by any virus capable of inducing illness—unambiguously applies because the coronavirus directly caused the government orders that led to the losses. The exclusion explicitly extends to all coverage forms, including those for business income, extra expense, and civil authority actions, and the policy defines covered causes of loss to exclude virus-related damage.
This case involved a dispute between Legend’s Creek Homeowners Association and its insurer, Travelers Indemnity Company of America, over coverage for hail and wind damage to condominium buildings that occurred in May 2016. Legend’s Creek filed suit in July 2018 alleging breach of contract and bad faith after Travelers denied a request to replace all sides of the buildings rather than just the damaged north-facing sides. The district court granted summary judgment to Travelers and invalidated an appraisal award, and the Seventh Circuit affirmed. The court held that the policy’s two-year contractual deadline for bringing any legal action was enforceable under Indiana law, that Legend’s Creek’s suit and motion to compel appraisal fell outside that window, and that no exceptions such as ambiguity, inducement, or equitable tolling applied because the insured could have complied with policy terms within the period and the insurer did not engage in conduct that prevented timely filing.
