Tag Archives: Seventh Circuit

Concurring Seventh Circuit Judge Urges Reconsideration of Plain-Error Review Under Fed. R. Crim. P. 29

In United States v. Robinson, No. 24-2310 (7th Cir. Dec. 15, 2025), the Seventh Circuit reverses in part a conviction for bank fraud on sufficiency-of-the-evidence grounds, while a concurring judge argues that a change in Fed. R. Crim. P. 29 warrants reconsideration of the plain-error standard to challenges raised for the first time on appeal.Continue reading “Concurring Seventh Circuit Judge Urges Reconsideration of Plain-Error Review Under Fed. R. Crim. P. 29”

Co-Guarantors to Contracts May Not Be Indispensable Parties Under Fed. R. Civ. P. 19(b), Holds Seventh Circuit

In CCP Golden/7470 LLC v. Breslin, No. 24-2731 (7th Cir. Dec. 3, 2025), the Seventh Circuit rejects an effort to defeat diversity jurisdiction, holding (contrary to prior dicta on the subject) that co-parties to a contract who are jointly and severally liable need not always be deemed indispensable parties for purposes of Fed. R. Civ.Continue reading “Co-Guarantors to Contracts May Not Be Indispensable Parties Under Fed. R. Civ. P. 19(b), Holds Seventh Circuit”

Exhibition of Van Gogh Painting in Illinois Did Not Establish Personal Jurisdiction Over Ownership Dispute There, Holds Seventh Circuit

In Schoeps v Sompo Holdings, Inc., No. 25-1405 (7th Cir. Nov. 21, 2025), the Seventh Circuit holds that the happenstance of an artwork, Van Gogh’s Sunflowers (1888), having once been exhibited at the Art Institute of Chicago did not create personal jurisdiction to sue over the painting’s ownership in Illinois. The heirs (Schoeps) of “PaulContinue reading “Exhibition of Van Gogh Painting in Illinois Did Not Establish Personal Jurisdiction Over Ownership Dispute There, Holds Seventh Circuit”

In Yet Another Case Involving an Exploding Lithium Battery, Seventh Circuit Joins Ninth Circuit and Splits with Fifth Circuit in Finding No Specific Personal Jurisdiction Over Manufacturer

There is a split between the Fifth and Ninth Circuits about whether a foreign manufacturer of a lithium battery falls within the specific personal jurisdiction of a state when its product is sold without authorization by a third party. Compare Ethridge v. Samsung SDI Co., 137 F.4th 309 (5th Cir. 2025) (yes), with Yamashita v.Continue reading “In Yet Another Case Involving an Exploding Lithium Battery, Seventh Circuit Joins Ninth Circuit and Splits with Fifth Circuit in Finding No Specific Personal Jurisdiction Over Manufacturer”

Deep Into the Standard-of-Appellate-Review Weeds, Seventh Circuit Holds That Abuse-of-Discretion Review Applies to a District Court’s Finding About Whether Grounds Were Properly Preserved in a Fed. R. Civ. P. 50(a) Motion

In Ziccarelli v. Dart, No. 24-2377 (7th Cir. June 30, 2025), addressing an issue of first impression for the circuit, the Seventh Circuit holds that a district court’s finding whether or not a party preserved grounds in a pre-verdict Fed. R. Civ. P. 50(a) motion – thus permitting a post-trial Rule 50(b) motion – is subjectContinue reading “Deep Into the Standard-of-Appellate-Review Weeds, Seventh Circuit Holds That Abuse-of-Discretion Review Applies to a District Court’s Finding About Whether Grounds Were Properly Preserved in a Fed. R. Civ. P. 50(a) Motion”

Seventh Circuit Contemplates How Little Is Too Little Briefing to Compel Dismissal Under Fed. R. App. P. 28

In Sullers v Int’l Union Elevator Constructors, Local #2, No. 24-1719 (7th Cir. June 27, 2025), a litigant in the Seventh Circuit barely avoids having their appeal dismissed on the grounds of inadequate briefing under Fed. R. Civ. P. 28. The case involved an allegation of breach of the duty of fair representation against theContinue reading “Seventh Circuit Contemplates How Little Is Too Little Briefing to Compel Dismissal Under Fed. R. App. P. 28”

Seventh Circuit Becomes the First to Hold That an EU “Societas Europaea” (SE) Is a “Corporation” for Diversity Jurisdiction Purposes

In Starstone Ins SE v City of Chicago, No. 23-2712 (7th Cir. Apr. 2, 2025), the Seventh Circuit holds that the plaintiff – a “Societas Europaea” (SE) organized under the rules of the European Union – is a citizen of a foreign state under the federal diversity statute, 28 U.S.C. § 1332(c)(1). Under section 1332(a)(2),Continue reading “Seventh Circuit Becomes the First to Hold That an EU “Societas Europaea” (SE) Is a “Corporation” for Diversity Jurisdiction Purposes”

Concurring Judge Suggests That Seventh Circuit Reconsider De Novo Review of Orders Denying Arbitration

In Al-Nahhas v 777 Partners LLC, No. 23-2723 (7th Cir. Feb. 19, 2025), the Seventh Circuit affirms a district court order denying arbitration on account of waiver. One concurring judge, though, suggests that the de novo standard of review of such orders – the law of the circuit for over three decades – may beContinue reading “Concurring Judge Suggests That Seventh Circuit Reconsider De Novo Review of Orders Denying Arbitration”

Federal Agencies Do Not Have An “Unfettered Right to Litigate in Federal Court” Under 28 U.S.C. § 1442, Holds Seventh Circuit

In Thompson v. Army and Air Force Exchange Service, No. 23-2447 (7th Cir. Jan. 8, 2025), the Seventh Circuit holds that a federal agency that removes an action from state court under 28 U.S.C. § 1442 is not entitled to dismissal in federal court on a finding that the federal court lacks subject-matter jurisdiction, andContinue reading “Federal Agencies Do Not Have An “Unfettered Right to Litigate in Federal Court” Under 28 U.S.C. § 1442, Holds Seventh Circuit”

Not Clicking “NEXT” in ECF Tanks A Lawsuit on Limitations Grounds, Holds the Seventh Circuit

In Dent v. Charles Schwab & Co., Inc., No. 24-1480 (7th Cir. Nov. 22, 2024) (per curiam), the Seventh Circuit affirms dismissal of a Title VII action on limitations grounds, holding that the action was not timely filed because counsel failed to click through to the last screen in the Electronic Case Filing System (ECF)Continue reading “Not Clicking “NEXT” in ECF Tanks A Lawsuit on Limitations Grounds, Holds the Seventh Circuit”