Ralph Holmes v. Salvador Godinez, 991 F.3d 775

Plaintiffs are deaf and hard-of-hearing Illinois prison inmates who settled a class action with the Illinois Department of Corrections (IDOC) in July 2018; the Settlement (a judicially enforceable consent decree) requires hearing screenings, referral to a licensed audiologist for an audiological evaluation, recordkeeping, and certain post-evaluation care.
For about a year after approval, IDOC admits it improperly referred roughly 700 inmates to licensed hearing instrument dispensers (LHIDs) instead of audiologists; IDOC ceased that practice in July 2019 after an out-of-court resolution.
Plaintiffs moved to enforce the Settlement, seeking (a) attorney fees for investigating/litigating the LHID violations and (b) orders requiring audiological evaluations be completed within a reasonable timeframe (they alleged delays up to eight months) and (c) court-ordered re-evaluation of the 700 affected inmates by a set date.
The district court awarded Plaintiffs about $54,000 in attorney fees, ordered IDOC to ensure evaluations be completed within 90 days of referral, and ordered re-evaluation of the 700 inmates by August 28, 2020.
The Seventh Circuit reviewed the consent decree de novo, affirmed the attorney-fee award (finding the Settlement authorized fees for past substantial non-compliance), but reversed the time-frame and re-evaluation orders because the Settlement obligates only a timely referral—not guaranteeing completion of evaluations within any set period.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether court could award attorney fees for LHID violations	Settlement authorizes fees for investigating/litigating non-compliance; fees cover out-of-court resolution	Meet-and-confer bars fee request; “has been” requires ongoing violation	Affirmed — Settlement authorizes reasonable fees for past substantial non-compliance; “has been” covers past or ongoing violations; fees awarded ($52,357.50 + $1,741.35 costs)
Whether Settlement requires IDOC to ensure audiological evaluations are completed within a set timeframe	An implied reasonable-time obligation exists; 90 days is appropriate given delays	Settlement only requires IDOC to refer inmates (within 30/45 days); IDOC cannot control independent audiologists	Reversed — Settlement requires referral (and best efforts to effect referral) but not guaranteeing evaluations be completed within a specific timeframe
Whether court could order re-evaluation of the 700 LHID-impacted inmates by a set date	Court may issue orders necessary to ensure compliance, including re-evaluations on a deadline	Such an order imposes duties not specified in the Settlement and exceeds court’s remedial authority	Reversed — Mandating re-evaluations by a deadline exceeded Settlement terms and court’s authority

Doe v. Cook County, 798 F.3d 558 (7th Cir. 2015) (treating a judicially enforceable agreement as a consent decree)
In re Trans Union Corp. Privacy Litig., 741 F.3d 811 (7th Cir. 2014) (consent decree interpretation reviewed de novo when defining parties’ substantive rights)
United States v. Alshabkhoun, 277 F.3d 930 (7th Cir. 2002) (a judicially approved consent decree is construed as a contract)
United States v. City of Northlake, 942 F.2d 1164 (7th Cir. 1991) (consent decrees interpreted under contract principles)
Peoples Gas Light & Coke Co. v. Beazer E., Inc., 802 F.3d 876 (7th Cir. 2015) (plain language of contract controls; give effect to parties’ intent)
Abellan v. Lavelo Prop. Mgmt., LLC, 948 F.3d 820 (7th Cir. 2020) (when contract omits a deadline, a reasonable time may be implied)
Local No. 93, Int’l Ass’n of Firefighters v. City of Cleveland, 478 U.S. 501 (1986) (consent decrees are compromises and reflect negotiated trade-offs)