Clayton Creason sued his former employer, Elanco US Inc., under Indiana’s Wage Payment Statute after participating in its voluntary “vacation buy” program, which allowed employees with under four years of service to reduce their salary by roughly one week’s pay in exchange for a fourth week of paid leave; he claimed the arrangement was an invalid wage assignment lacking required written notice of rescission rights, and he also sought pay for unused COVID-era vacation rollover hours when he quit in 2021. The Seventh Circuit affirmed the district court’s judgment for Elanco. It first held that the home-state exception to CAFA jurisdiction applied but that Creason’s remand motion, filed nearly a year after removal and after substantial federal proceedings, was untimely. On the merits, the court ruled there was no “assignment” of wages because Elanco simply paid the lower base salary Creason had agreed to accept, with no deduction placed in escrow or sent to a third party, a conclusion supported by his tax records showing the reduced amount was not treated as income; it further held that Indiana law did not require payout of the unused rollover hours, which Elanco’s policy had expressly made non-compensable. Class certification was not moot but unnecessary given the outcome on the merits.
Jacqueline Stevens sued ICE under FOIA after the agency failed to timely respond to her requests for files on three immigration detainees. The district court found the agency's searches inadequate and its Vaughn index flawed, including unsupported exemption claims and errors suggesting bad faith by agency staff, and ordered full release of more than 2,000 pages without redactions as a sanction while the case continued. On appeal, the Seventh Circuit vacated the injunction, holding that it failed to describe the required actions with the specificity demanded by Federal Rule of Civil Procedure 65(d). The court reasoned that although the agency's performance was deficient, ordering blanket disclosure bypassed statutory exemptions and risked exposing confidential information of third parties—such as Social Security numbers and law-enforcement data—without the judge reviewing the documents or considering alternatives like referral to a magistrate. The case was remanded for the district court to reassess the sanction and limit any required releases to information the agency could properly waive.
Jacqueline Stevens filed a FOIA lawsuit against ICE after the agency failed to timely respond to her requests for files on three immigration detainees. The district court, frustrated with the agency's inadequate searches, flawed Vaughn index, and repeated errors in asserting exemptions, sanctioned ICE by ordering the unredacted release of over 2,000 pages of documents without reviewing them for valid statutory exemptions. On appeal, the Seventh Circuit vacated the injunction and remanded the case, holding that the order was too vague to satisfy Federal Rule of Civil Procedure 65 and that the blanket disclosure sanction was an abuse of discretion because it exposed third parties' confidential information, such as Social Security numbers and law-enforcement data, to potential harm without justification. The court reasoned that agency mismanagement, even if sanctionable, does not permit bypassing exemptions that protect non-parties and that the district judge should have considered alternatives like review by a magistrate judge.
The case involved a dispute between a Chicago hotel and a union over the firing of an employee who displayed a knife at work, prompting a co-worker to feel threatened. After the union grieved the termination under the collective bargaining agreement, an arbitrator selected by random.org from a contractually designated list found that the conduct warranted only a ten-day unpaid suspension, not discharge, and ordered reinstatement with partial back pay. The hotel refused to participate in that arbitration or comply with the award, leading the district court to compel arbitration and later confirm the award. The Seventh Circuit affirmed, holding that the agreement’s specified random-selection method had to be followed under 9 U.S.C. §5 with no qualifying “lapse,” that courts cannot overturn an arbitrator’s factual findings, and that Illinois public policy against workplace violence does not bar enforcement because it does not dictate how employers must respond to such incidents.
In David Watts v. Kevin Jones, an inmate at a Wisconsin prison sued two detectives under 42 U.S.C. §1983, alleging they violated his constitutional rights by approaching his cell during a murder investigation in a manner that could have led other inmates to suspect he was cooperating with law enforcement, thereby exposing him to risk of harm (though he suffered only alleged harassment and no physical injury). The district court denied the defendants’ motion for summary judgment on qualified immunity grounds, but the Seventh Circuit reversed, holding that the defendants were entitled to summary judgment. The court reasoned that qualified immunity applied because no clearly established law at the time showed that prison officials or detectives could be liable in damages for creating a risk of harm to an inmate that never materialized into physical injury, distinguishing precedents like Farmer v. Brennan (which involved actual harm) and Monfils v. Taylor (which involved a resulting death after a confidentiality breach). The opinion also noted that 42 U.S.C. §1997e(e) limits recovery for emotional injuries absent physical harm and that the mere exposure to risk does not violate the Constitution.
Sarah Hinkes sued her employer, Sunera Technologies, and two coworkers for federal employment discrimination, but the district court stayed the case for arbitration. After the arbitrator ruled for the defendants, Hinkes sought to vacate the award, the district court confirmed it, and she appealed. The Seventh Circuit first addressed jurisdiction, holding that federal-question jurisdiction under 28 U.S.C. §1331 existed because the original suit arose under federal law and continued to support confirmation proceedings. On the merits, the court affirmed confirmation, ruling that 9 U.S.C. §10(a)(3) permits vacatur only for arbitrator misconduct such as refusing to hear pertinent evidence, not for admitting hearsay, undisclosed evidence, or otherwise departing from court-like procedures, which arbitration is not required to follow.