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7th and 8th Circuits Split on Removal Requirements of Federal Question Cases Involving Multiple Defendants


Justin A. Reinhardt

Civil defendants in state court have the option to remove a case to federal court, and one basis for removal is when the case presents a “federal question.”  Federal question cases arise under the Constitution or laws of the United States. See 28 U.S.C. § 1441 (2011). But when there are multiple defendants in a case and removal is based solely on a federal question, “all defendants” must “join in or consent to the removal of the action.” 28 U.S.C. § 1446 (b)(2)(A) (2011) (emphasis added). This is known as the “unanimity requirement.” The US Court of Appeals for the

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Illinois Court’s Groundbreaking Decision Extends Title VII Protections to LGBT Community


Kurowski Shultz LLC

On Tuesday, a federal court in Illinois ruled that Title VII of the Civil Rights Act of 1964 protects employees from discrimination based on sexual orientation.[1] In an 8-3 decision, the U.S. Court of Appeals for the Seventh Circuit became the first appellate court in the nation to extend protections of workplace discrimination to the LGBT community. The court ruled in favor of plaintiff Kimberly Hively, who claimed she was fired from her position as a part-time instructor at Ivy Tech Community College in South Bend, Indiana, because she is a lesbian. Hively’s sexual orientation became an issue in 2009,

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  • Editor


    Candice Kusmer enjoys working with several of Kurowski Shultz’s major clients, oversees the firm’s asbestos docket in Central Illinois and handles high-level matters in Madison County. An accomplished writer, she has a passion for writing and leads the firm’s Appellate Practice.

  • Contributors


    Mr. Dibler has been with Kurowski Shultz since 2002 and is responsible for the firm's substantial St. Louis City and Cook County (Chicago) asbestos dockets. He is one of few defense counsel who have taken verdicts in the challenging defense environment of St. Louis City.


    Justin Reinhardt joined Kurowski Shultz in July 2015. He concentrates his practice in complex civil litigation and toxic tort defense. He is licensed to practice law in the state of Missouri. He is a member of the Missouri Bar, the Bar Association of Metropolitan St. Louis, the Illinois State Bar Association, and the American Bar Association.


    Kyler Stevens has been with Kurowski Shultz since October 2012 and has focused his practice on complex civil litigation, protecting the interests of large and small businesses alike. Mr. Stevens is also active in the defense of schools and municipal corporations in various civil matters.

  • Alexander J. Baker

    Alexander J. Baker joined Kurowski Shultz in 2012. His practice area concentrates on complex civil litigation including the defense of toxic tort and personal injury lawsuits. Mr. Baker also recently tried to verdict a Southern District of Illinois pro bono case regarding First Amendment rights and violations of the Fourteenth Amendment right to equal protection under the US Constitution. He is an active member of the St. Clair County and the Illinois State Bar Association.

  • Joshua N. Severit

    Joshua N. Severit, joined Kurowski Shultz in July 2016. Mr. Severit specializes in toxic tort and personal injury. He is a member of the Illinois State and Madison County Bar Associations and is licensed to practice law in Illinois.