In Derek Hundley v. Dee Dee Brookhart, three correctional officers sued the Illinois Department of Corrections and related officials after being fired for using force on a wheelchair-bound inmate who refused to surrender his handcuffs—by entering his cell with a team, dragging him, and deploying pepper spray—before exhausting alternatives, and for inaccurately describing the incident in their reports as an “escort.” The officers claimed the Department’s “force only as a last resort” rule and truthfulness requirements were unconstitutionally vague, violating their Fourteenth Amendment due process rights. The district court granted summary judgment to the defendants, and the Seventh Circuit affirmed. The court held that the rules were not vague as applied, because “last resort” plainly requires attempting other reasonable options first—such as contacting a supervisor or activating a tactical team—before force, and the officers had time and awareness of those options with no imminent threat; the reporting rules likewise give clear notice that false statements can result in termination. The court noted that prison employers receive additional latitude in such regulations.
The case concerned Souleymane Nimaga, a Malian citizen, who petitioned for review of a Board of Immigration Appeals order upholding an immigration judge’s denial of his motion to reopen removal proceedings and rescind an in absentia removal order. Nimaga had failed to appear at his October 1, 2019 hearing in Chicago after a burglary left him without funds for transportation, his arranged ride fell through, and his attempts to secure alternate travel or legal help were unsuccessful. The Seventh Circuit denied the petition, holding that the immigration judge and Board did not abuse their discretion in finding that Nimaga’s circumstances were not sufficiently exceptional. The court reasoned that, although his financial hardship and lack of transportation were beyond his control and he had conceded removability while pursuing a U visa, he had the ability to contact the immigration court in advance to report his predicament yet failed to do so, despite being on notice of the risk of in absentia removal.
The case involved class-action lawsuits by current and former shuttle truck drivers who transport auto parts and empty containers solely within Illinois, between off-site storage lots and a Ford assembly plant in Chicago. The drivers sued their employers for unpaid overtime under the FLSA and related Illinois and Chicago wage laws, claiming their local routes did not qualify for the FLSA’s motor-carrier exemption. The district court granted summary judgment to the defendants, and the Seventh Circuit affirmed. The court held that the drivers’ work was part of ongoing interstate shipments because the parts originated out of state, were only temporarily staged at the lots before final delivery to the plant, and the empty custom containers were returned via interstate carriers for reuse; the storage lots were not the intended final destination, so the transportation remained interstate in character.
The case involved class actions by current and former shuttle truck drivers who transported auto parts and empty containers on routes entirely within Illinois, between off-site storage lots and a Ford assembly plant in Chicago. The drivers sued their employers, including Bosman Trucking, alleging violations of the FLSA's overtime requirements (along with parallel Illinois and Chicago wage laws), claiming their work was purely intrastate. The district court granted summary judgment to the defendants, and the Seventh Circuit affirmed. The court held that the drivers' hauls were part of ongoing interstate shipments because the parts originated from out-of-state manufacturers, were only temporarily staged at the distinct storage lots pending need at the plant, and continued on public roads to their final destination, with empty containers likewise returned interstate for reuse; therefore, the Motor Carrier Act exemption applied and no overtime was required under the FLSA.
Christopher Raddant sued Douglas County, Wisconsin, and several police officers, alleging that they used excessive force in violation of his civil rights while searching him at a jail booking counter and moving him to a cell after his arrest for suspected bail violations. A jury ruled for the defendants on the sole claim that reached trial regarding force at the booking counter, while the district court granted the defendants summary judgment on all other claims before trial and excluded Raddant’s expert witnesses. On appeal, the Seventh Circuit affirmed, holding that video evidence from multiple angles showed the officers used only minimal, reasonable force in response to Raddant’s physical resistance and threats, with no material factual disputes requiring a trial. The court further concluded that challenges to the exclusion of expert testimony were moot because Raddant did not appeal the jury’s verdict on the tried claim.
Christopher Raddant sued Douglas County, Wisconsin, and several police officers, alleging that they used excessive force in violation of his civil rights while searching him at a jail booking counter and moving him to a cell after his arrest for suspected bail violations. A jury ruled for the defendants on the sole claim that reached trial regarding force at the booking counter, while the district court granted the defendants summary judgment on all other claims before trial and excluded Raddant’s expert witnesses. On appeal, the Seventh Circuit affirmed, holding that video evidence from multiple angles showed the officers used only minimal, reasonable force in response to Raddant’s physical resistance and threats, with no material factual disputes requiring a trial. The court further concluded that challenges to the exclusion of expert testimony were moot because Raddant did not appeal the jury’s verdict on the tried claim.
civil rightsprocedure
Affiliations
Court of Appeals for the Seventh Circuit — appointed by George H.W. Bush
District Court, N.D. Illinois — appointed by Ronald Reagan