Ioan Lela v. Thomas J. Dart

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Submitted July 9, 2025*
Decided July 9, 2025
Before
THOMAS L. KIRSCH II, Circuit Judge
JOHN Z. LEE, Circuit Judge
JOSHUA P. KOLAR, Circuit Judge
No. 24-2544
IOAN LELA,
Plaintiff-Appellant,
v.
THOMAS J. DART, et al.,
Defendants-Appellees.
Appeal from the United States District
Court for the Northern District of
Illinois, Eastern Division.
No. 18 C 4058
Matthew F. Kennelly,
Judge.
O R D E R
Ioan Lela, a pretrial detainee, appeals the district court’s summary judgment
rejecting his claims that jail officials subjected him to unconstitutional conditions of
confinement by maintaining an inadequate air-ventilation system in his housing unit.
* We have agreed to decide the case without oral argument because the briefs and
record adequately present the facts and legal arguments, and oral argument would not
significantly aid the court. F ED. R. A PP . P. 34(a)(2)(C).
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with F ED. R. APP . P. 32.1

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No. 24-2544 Page 2
See 42 U.S.C. § 1983. Because Lela has not presented any evidence from which a
reasonable jury could find that the jail officials acted unreasonably, we affirm.
Lela was detained at Cook County Jail from 2015 to 2021. He maintains that,
during this time, inadequate air ventilation in his housing unit triggered or exacerbated
multiple ailments, including mild sporadic allergic rhinitis, upper respiratory infection,
and headaches. In 2018, he filed an internal grievance complaining that the
air-ventilation system in his housing unit was not adequately cleaned. He complained
that one to two inches of “human dead skin” and “dust mite particles” accumulated on
the air-conditioning covers. Within two weeks, an employee at the jail responded to the
grievance by cleaning the air vents in Lela’s housing unit.
Lela then sued several jail officials, alleging that they maintained an inadequate
air-ventilation system in his housing unit, in violation of his Fourteenth Amendment
rights. Further proceedings ensued, and the district court eventually granted summary
judgment for the jail officials. The court concluded that Lela failed to offer evidence
from which a reasonable jury could infer that the officials’ actions were objectively
unreasonable.
Lela moved to vacate the judgment under Rule 60(b) of the Federal Rules of Civil
Procedure, contending that the court ignored evidence showing that the jail’s
inadequate air-ventilation system caused his medical ailments. He also moved to
disqualify the judge based on the allegedly selective manner in which the judge
credited certain evidence. The court denied both motions. Regarding the Rule 60(b)
motion, the court concluded that Lela rehashed the arguments that it had rejected in its
order entering summary judgment for the officials. As for the motion to disqualify, the
court explained that adverse rulings were not grounds for disqualification.
On appeal, Lela first contests the summary judgment decision, arguing that the
district court overlooked evidence supporting his claim that the defendants subjected
him to unconstitutional conditions of confinement. He points to grievances filed by
other detainees at the jail, a 2010 consent decree, and a 2017 district court order—all of
which, in his view, show that the defendants maintained objectively unreasonable
conditions of confinement and knew that these conditions were unconstitutional.
To get past summary judgment, however, Lela needed to—but did not—furnish
evidence that the defendants purposefully, knowingly, or recklessly created conditions
that were objectively unreasonable. See Kemp v. Fulton Cnty., 27 F.4th 491, 495 (7th Cir.

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No. 24-2544 Page 3
2022) (citations omitted); Hardeman v. Curran, 933 F.3d 816, 823 (7th Cir. 2019). The
documents he cites say nothing about his conditions of confinement, let alone that the
defendants responded or failed to respond in a manner that was objectively
unreasonable. Indeed, the uncontroverted evidence reflects that jail officials took
reasonable steps to maintain an adequate air-ventilation system and reasonably
responded to Lela’s grievance about the air-ventilation system by cleaning the air vents
in his housing unit. The court’s entry of summary judgment was proper.
Lela next argues that the district court erred in excluding his proposed expert
witness—a retired trial lawyer—as not qualified. The court explained that a lawyer’s
experience litigating matters on a particular subject did not render him a specialist on
that subject. The admissibility of expert testimony is governed by Rule 702 of the
Federal Rules of Evidence and Daubert v. Merrell Dow Pharmaceuticals, 509 U.S. 579
(1993). Such testimony is permitted if the witness is “an expert by knowledge, skill,
experience, training, or education” and his opinion is “the product of reliable principles
and methods” that have been applied to the facts of the case. F ED. R. EVID. 702. We agree
with the district court that Lela’s proposed witness did not satisfy these standards. The
trial lawyer’s experience in litigating prison conditions of confinement did not qualify
him to opine on causal relationships between air ventilation and medical ailments.
See, e.g., Goodwin v. MTD Prods., Inc., 232 F.3d 600, 609 (7th Cir. 2000) (an individual
with a degree in mechanical engineering does not make him qualified to give expert
opinion on the causation of an injury).
Lastly, Lela rehashes his argument that the district judge was biased against
him and should have disqualified himself. He says that the court ignored certain
documents when ruling against him at summary judgment. But adverse judicial rulings
generally do not constitute a valid basis for disqualification, especially as here where
there is no suggestion of “deep-seated favoritism or antagonism” that makes fair
judgment impossible. Liteky v. United States, 510 U.S. 540, 555 (1994).
AFFIRMED

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