Injunctive Relief and Damage Awards

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7^th Circuit Court of Appeals

Case Name: Johnathan Lacy, et al. v. Cook County, Illinois and Thomas J. Dart

Case No.: 17-2141

Officials: RIPPLE, MANION, and KANNE, Circuit Judges.

Focus: Injunctive Relief and Damage Awards

Five wheelchair-using detainees brought this lawsuit against Cook County, Illinois, and the Sheriff, alleging violations of the Americans with Disabilities Act (“ADA”) and the Rehabilitation Act (“RHA”). Their claims are based on purportedly inaccessible ramps and bathroom facilities at six county courthouses. The district court certified a class for purposes of injunctive relief, and the named plaintiffs also sought damages individually for the same alleged violations.

The district court held an evidentiary hearing on the equitable claims first. The parties then filed cross motions for summary judgment on their individual damage claims. The court entered a permanent injunction based on its factual findings and legal conclusion that the defendants had violated the ADA. Then, relying largely on these findings, the court granted partial summary judgment to the plaintiffs on liability in their personal damage actions. The court then submitted the question of individual damage awards to a jury. Meanwhile, it granted a supplemental permanent injunction to the class.

We hold that the district court improperly relied on its own findings of fact when it granted partial summary judgment to the plaintiffs on their damage claims. When equitable and legal claims are joined in a single suit, common questions of fact should be tried first to a jury absent extraordinary circumstances or an unequivocal waiver by all parties of their jury trial rights. The record before us does not reflect any such waiver by the defendants. We therefore vacate the grant of partial summary judgment and remand for a jury trial on the question of liability. As a result, we also vacate the court’s grant of permanent injunctive relief and vacate the jury’s determinations of damage awards. We leave undisturbed the district court’s decisions to certify the class and to grant supplemental injunctive relief to the class. This latter injunction is not related to the questions that should have been submitted to the jury. Accordingly, we affirm in part, vacate in part, and remand for further proceedings.

Affirmed in part. Vacated in part.

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