Seventh Circuit Roundup

April 2026 Roundup: Two Opinions Every Civil Litigator Should Read

Summary In this episode, Kian and Mark explore two recent Seventh Circuit cases on insurance law, standing, and appellate strategy, including a detailed analysis of the Havens Realty doctrine and its implications for litigators.

February Roundup: A Botched Beneficiary Change, and a Discrimination Claim That Didn't Make It Past the Pleadings

Show Notes: Hosts Kian Hudson and Mark Crandley examine two recent Seventh Circuit decisions that clarify critical pleading and compliance standards. Cases Discussed: Packing Corporation of America Thrift Plan v. Dina Langdon  When a divorced employee sends a fax requesting a beneficiary change but dies before submitting the proper forms, who gets the retirement benefits—the ex-wife or the estate? The court addresses whether the "substantial compliance" doctrine survives recent Supreme Court precedent and draws a bright line: good intentions aren't enough if you don't follow the plan's procedures. Miao v. United Airlines  After being removed from a flight following a dispute over overhead bin space, a passenger alleges racial discrimination. The court tackles a fundamental question: when is differential treatment enough to get past a motion to dismiss? The answer reveals the high bar discrimination plaintiffs face at the pleading stage, even when they identify a comparator.

January 2026 Roundup: What Recent Decisions Reveal About Pleading, Intent, and Immunity

Episode Summary In this episode of Seventh Circuit Roundup, hosts Kian Hudson and Mark Crandley break down two recent and consequential Seventh Circuit decisions addressing Fair Housing Act pleading standards and constitutional limits on prosecutorial immunity. The discussion highlights practical litigation takeaways for practitioners navigating motions to dismiss, discrimination claims, and public-employment disputes.

November 2025 Decisions Address Implied Rights of Action, Personal Jurisdiction, and Section 1983

This episode covers three important decisions that the Seventh Circuit issued in November 2025: Chicago Teachers Union v. Educators for Excellence (a case addressing whether there is a private cause of action to enforce the federal ban on employer advocacy of candidates for union offices), Schoeps v. Sompo Holdings (a case brought by heirs of a German Jewish art collector to recover a Van Gogh painting now owned by a Japanese insurance company), and Bostic v. Murray (a Section 1983 case arising from a probation officer’s assault of a female probationer). Kian kicks off the episode with Chicago Teachers Union, which involves a union’s attempt to enforce a provision of the Labor Management Reporting and Disclosure Act (LMRDA) that prohibits unions and employers from spending money to promote candidates in union elections. The Seventh Circuit panel held that the union lacked an implied cause of action, explaining that this provision has an alternative method of enforcement (submitting complaints to the Department of Labor) and that a different LMRDA provision does have an express private cause of action. Next, Lara brings her considerable art-history expertise to bear in discussing Schoeps, a case about a German family’s attempt to recover a painting (one of Van Gogh’s Sunflowers) that was misappropriated during the Holocaust and that was purchased many years later by a Japanese insurance company (which now displays the painting in Tokyo). The family sued in Illinois federal court, because an affiliate of the Japanese company sells insurance in Illinois and because the painting was briefly displayed at a Chicago art museum in 2001. In doing so, the family invoked the Holocaust Expropriated Art Recovery Act of 2016, which preempts state-law statutes of limitations—but which does not create its own cause of action. The Seventh Circuit held that neither federal common law nor federal equitable principles gave the family a federal cause of action. And the Seventh Circuit rejected the family’s state-law claims on personal-jurisdiction grounds, holding that the insurance company’s contacts with Illinois were insufficient to establish “purposeful availment.” Mark wraps up the episode with Bostic, a case that raises an important question under Section 1983—if a supervisor is personally involved in a constitutional violation committed by one of their subordinates, what state of mind must the supervisor have to be liable? The Seventh Circuit held that  the answer depends upon the constitutional provision at issue, including the state of mind required to establish the underlying constitutional violation. Because the plaintiff in Bostic pursued a substantive due process theory, the Court held that the applicable standard was deliberate indifference—and it held that the plaintiff failed to meet that standard at summary judgment because the information the defendants possessed was insufficient to put them “on actual notice of the risk that [the probation officer] would eventually grope and assault [the plaintiff].”

Autumnal Decisions on Guns, Standing, Qualified Immunity, and the Takings Clause

As autumn settles in, the Seventh Circuit remains anything but quiet. In this episode of Seventh Circuit Roundup, hosts Kian Hudson, Mark Crandley, and Lara Langeneckert break down three decisions from late summer and early fall that each touch on a different corner of constitutional and civil-rights law: Schoenthal v. Raoul (a Second Amendment case that, in addition to the merits, raised a difficult standing issue), Neita v. City of Chicago (a Section 1983 wrongful-arrest case arising from an Illinois animal-neglect prosecution), and Hadley v. City of South Bend (a Takings Clause case involving the destructive search of an innocent woman’s house). They begin with Schoenthal v. Raoul, a challenge to Illinois’s ban on carrying loaded firearms on public transportation. The episode overviews the Court’s merits decision (the panel unanimously upheld the law) and then explains how the panel addressed the defendants’ argument that the plaintiffs lacked standing because they would not be able to carry guns on trains even if the Illinois law were invalidated (because the train operator separately bans carrying guns).. Writing for the majority, Judge Kolar concluded that the plaintiffs’ sought-for relief would redress their claimed injury—facing prosecution under the Illinois statute. Judge St. Eve’s concurrence likewise addressed the standing issue and highlighted the difficult questions that arise where a plaintiff defines her injury as the inability to engage in protected activity, rather than the threat of prosecution under the challenged law. The episode then moves to Neita v. City of Chicago, a case brought by a man who claimed that Chicago police officers lacked even arguable probable cause to arrest him for neglecting his pet dog. The panel’s majority opinion (written by Judge Jackson-Akiwumi) agreed with the man, rejecting the officers’ qualified-immunity defense because a jury could conclude that the officers lacked a sufficient basis to believe the man had violated Illinois’s animal-neglect statute. Finally, in Hadley v. City of South Bend, the Seventh Circuit addressed whether property damage caused during the execution of a lawful search warrant can amount to a compensable taking. The court reaffirmed its existing rule — aligned with several other circuits — that such damage generally falls outside the Takings Clause. Adopting a broader theory, the panel noted, would require courts to assess “innocence” and draw difficult lines about when police-caused damage amounts to a “taking.”