November 2025 Seventh Circuit Roundup: Key Decisions On Implied Rights, Personal Jurisdiction, And Section 1983 (Podcast)

The Seventh Circuit issued several noteworthy opinions in November 2025, including cases that provide guidance on implied causes of action, personal jurisdiction, and civil rights enforcement. The latest episode of 7th Circuit Roundup discusses three cases that stand out for their impact and broader implications: Chicago Teachers Union v. Educators for Excellence, Schoeps v. Sompo Holdings, and Bostic v. Murray.

Chicago Teachers Union v. Educators for Excellence: Limits on Implied Causes of Action

Chicago Teachers Union addresses whether a union could enforce a provision of the Labor Management Reporting and Disclosure Act (LMRDA) that prohibits employers from spending money to promote candidates in union elections.

The Seventh Circuit held that the union lacked an implied cause of action, noting that the LMRDA already provides a mechanism for enforcement through the Department of Labor. The Court also contrasted the provision at issue with a different LMRDA provision that explicitly allows private enforcement. The decision underscores the Court's cautious approach to recognizing new causes of action, highlighting that alternative remedies often play a critical role.

Schoeps v. Sompo Holdings: Art Recovery and Personal Jurisdiction

Schoeps involved the heirs of a German Jewish art collector seeking to recover a Van Gogh Sunflowers painting misappropriated during the Holocaust and later acquired by a Japanese insurance company. The family sued in Illinois federal court under the Holocaust Expropriated Art Recovery Act of 2016 (HEAR Act), which preempts state statutes of limitations but does not create a federal cause of action.

The Seventh Circuit found that neither federal common law nor equitable principles provided a federal cause of action. The Court also rejected the state-law claims based on personal jurisdiction, holding that the insurance company's limited contacts with Illinois—through a brief museum display and a related insurance business—were insufficient to establish "purposeful availment."

This ruling highlights the challenges of pursuing international art recovery claims in U.S. courts and reinforces the strict standards for establishing personal jurisdiction over foreign defendants.

Bostic v. Murray: Section 1983 Supervisory Liability

Bostic addressed supervisory liability under Section 1983 arising from the sexual assault of a probationer by her probation officer. The central question was what level of knowledge or involvement a supervisor must have to be liable for a subordinate's constitutional violation.

The Seventh Circuit clarified that the state-of-mind standard depends on the constitutional provision at issue. For substantive due process claims, the relevant threshold is deliberate indifference. Applying this standard, the Court found that the plaintiff failed to demonstrate that the supervisors had "actual notice" of the risk, affirming summary judgment for the defendants.

This case provides important guidance for public employers and supervisors, emphasizing the careful standards courts apply when evaluating potential liability under Section 1983.

Listen to the Full Episode

For a deeper dive into these decisions and their practical implications, listen to the full episode.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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