The case involved four Illinois Medicaid beneficiaries who sued state Medicaid officials after long-term care facilities' electronic admission packets for them were rejected or mishandled by the Department of Healthcare and Family Services. This led to partial or full denial of reimbursement to the facilities, which then sent the plaintiffs bills they were not legally required to pay, with no interruption in their care. The plaintiffs alleged due process and Medicaid Act violations and sought only a permanent injunction to reform the packet-processing system, proposing to represent a class of similarly situated beneficiaries. The district court dismissed the case on the merits after finding standing based on the bills received. The Seventh Circuit affirmed on different grounds, holding that the plaintiffs lacked Article III standing for injunctive relief because they alleged no concrete, imminent future injury traceable to the challenged practices—the bills imposed no legal liability, past harms alone do not establish standing for forward-looking relief, and claims of possible future readmission were too speculative.
Darell Burton, a Black applicant for a deputy sheriff position, sued the Will County Sheriff’s Merit Commission, the Sheriff’s Office, and Will County under Title VII, alleging he was removed from the merit-based certification process due to race after his current employer (a railroad) gave him a negative reference during the background investigation. The district court granted summary judgment for the defendants, and the Seventh Circuit affirmed. The court held that Burton produced no evidence that race motivated the removal and that the negative reference—stating he was undependable, did not work well with others, and would not be recommended or rehired—was a legitimate, nondiscriminatory reason with no support in the record for finding it pretextual. Burton’s other arguments, such as statistical data, a stray remark by a commissioner years later, and claims about the process being handled abnormally, were either waived, irrelevant, or insufficient to create a triable issue.
Dored Shiba, a USCIS immigration officer, took extended medical leave after workplace falls in 2007, received workers’ compensation, and was terminated in 2010 when he could not return; after reinstatement via a Merit Systems Protection Board order, he again took leave and was later fired following an Office of Inspector General investigation into his outside activities representing refugees. He sued the Secretary of Homeland Security under the Rehabilitation Act, claiming failure to accommodate his disability, a hostile work environment, and retaliation. The district court granted summary judgment to the agency on all claims. On appeal, the Seventh Circuit affirmed, holding that the accommodation and hostile-workplace claims were largely unexhausted and failed on the merits because Shiba’s prior statements to the Department of Labor that he was unable to work equitably estopped him from asserting he could perform his job with accommodations, and the agency’s investigative actions and supervisory comments did not constitute severe or pervasive harassment.
Dored Shiba sued the Secretary of Homeland Security after the agency rescinded a tentative job offer for a citizenship and immigration assistant position, claiming the stalled security-clearance investigation was pretext for retaliation under the Rehabilitation Act based on his prior disability-discrimination complaints. The district court dismissed the case for lack of subject-matter jurisdiction under Department of the Navy v. Egan, which holds that courts cannot review security-clearance decisions because they involve discretionary national-security judgments committed to the Executive Branch. On appeal, the Seventh Circuit affirmed the dismissal but modified it to a merits-based ruling for failure to state a claim, explaining that Egan limits judicial review rather than jurisdiction and that resolving Shiba’s pretext allegations would require improperly second-guessing the agency’s security-related reasons. The court rejected Shiba’s arguments for an exception, finding his claim fell squarely within Egan’s bar because it challenged the rescission of the job offer tied to the unresolved clearance.
In United States v. Lennie Perry, the defendant was convicted of sex-trafficking minors after cycling through five court-appointed lawyers, twice waiving his Sixth Amendment right to counsel following full Faretta hearings in which he confirmed his understanding of the risks of self-representation, and then requesting a sixth lawyer on the first day of trial. The district court denied the midtrial request, consistent with its prior warning that no further appointments would be made, and the jury convicted Perry. On appeal, the Seventh Circuit affirmed, holding that a defendant who has validly waived counsel after repeated refusals to cooperate with appointed attorneys has no automatic right to revoke that waiver or demand new counsel once trial begins. The court explained that judges may hold defendants to their knowing and voluntary waivers and are not obligated to reassess motives or potential delays when a defendant has already driven off multiple lawyers, as the Sixth Amendment does not guarantee an endless succession of appointed counsel.
Mohamed Muthana, a U.S. citizen from Yemen, filed an I-130 visa petition in 2002 for his stepdaughter Halimah and later sued the Secretary of Homeland Security and other officials, claiming the INS had sent a notice of intent to deny and a denial letter to the wrong address, violating due process and the APA, and seeking to reopen the long-closed proceedings. The district court granted judgment on the pleadings for the defendants after they submitted an unredacted copy of Muthana’s own I-130 petition listing the address 4737 N. Kildare Avenue in Chicago. On appeal, the Seventh Circuit affirmed, ruling that Muthana had doubly waived any challenge by failing to offer meaningful argument against the unredacted petition in the district court or on appeal. The court further held that it could properly consider the complete document under the incorporation-by-reference doctrine, which conclusively showed Muthana himself had provided the address and thereby defeated the lack-of-notice claims.
