Mazen Agha v. Uber Technologies, Inc.
Headline: Arbitration Clause Validates Uber's Driver Data Collection Under BIPA
Citation:
Brief at a Glance
Drivers suing Uber over privacy violations must arbitrate their claims individually because their contract's arbitration clause is enforceable, barring class-action lawsuits.
- Arbitration clauses in independent contractor agreements are generally enforceable, even for statutory privacy claims.
- Class-action lawsuits for BIPA violations can be barred if an enforceable arbitration agreement exists.
- Reviewing the scope and validity of arbitration clauses is crucial for both individuals and companies.
Case Summary
Mazen Agha v. Uber Technologies, Inc., decided by Seventh Circuit on August 26, 2025, resulted in a defendant win outcome. The Seventh Circuit affirmed the district court's dismissal of a class-action lawsuit alleging Uber violated the Illinois Biometric Information Privacy Act (BIPA) by collecting drivers' biometric data without consent. The court held that the arbitration clause in Uber's independent contractor agreement was enforceable, compelling arbitration of the claims and thus barring the class action in court. Because the arbitration agreement was valid and encompassed the BIPA claims, the district court correctly dismissed the case. The court held: The court held that the arbitration clause in Uber's independent contractor agreement was valid and enforceable because the driver had sufficient notice and opportunity to review the agreement.. The court found that the arbitration clause clearly encompassed the plaintiff's claims under the Illinois Biometric Information Privacy Act (BIPA), as the claims arose from the driver's relationship with Uber and the use of its services.. The court determined that the arbitration agreement did not unconscionably prevent the plaintiff from vindicating their statutory rights under BIPA, as it allowed for individual arbitration.. The court rejected the argument that the class action waiver within the arbitration agreement was unenforceable, citing precedent that such waivers are permissible.. Consequently, the court affirmed the district court's dismissal of the class action, as the valid arbitration agreement mandated that the claims be resolved through individual arbitration, not a class action in court.. This decision reinforces the broad enforceability of arbitration agreements, including class action waivers, under the Federal Arbitration Act, even when dealing with novel privacy statutes like BIPA. It signals that companies can effectively steer disputes with their contractors into individual arbitration, limiting class-wide litigation for statutory claims.
AI-generated summary for informational purposes only. Not legal advice. May contain errors. Consult a licensed attorney for legal advice.
Case Analysis — Multiple Perspectives
Plain English (For Everyone)
Imagine you signed up for a service and agreed to a long contract, even if you didn't read it all. This case says that if that contract has a clause forcing you to settle disputes through arbitration instead of suing in a big group (a class action), then you have to follow that. Even if your complaint is about something serious like privacy, like Uber collecting your fingerprint data without proper consent, the arbitration clause can stop you from joining a class-action lawsuit in court.
For Legal Practitioners
The Seventh Circuit affirmed dismissal, holding that the arbitration clause in Uber's independent contractor agreement was enforceable and encompassed the plaintiff's BIPA claims. This decision reinforces the broad enforceability of arbitration agreements, even for statutory claims like those under BIPA, and underscores the importance of carefully reviewing arbitration provisions for scope and clarity. Practitioners should anticipate that such clauses will likely be upheld, effectively channeling BIPA class actions into individual arbitration.
For Law Students
This case tests the enforceability of arbitration agreements in the context of statutory claims, specifically BIPA. The court applied the Federal Arbitration Act (FAA) to find the arbitration clause valid and encompassing the BIPA claims, thereby barring a class action. This aligns with the general trend favoring arbitration and highlights the potential for arbitration clauses to preempt class-wide litigation for statutory violations, even those concerning privacy rights.
Newsroom Summary
A federal appeals court ruled that Uber drivers cannot sue the company in a class-action lawsuit over privacy violations related to biometric data collection. The court found that the drivers had agreed to arbitration, meaning individual disputes must be settled privately rather than in court.
Key Holdings
The court established the following key holdings in this case:
- The court held that the arbitration clause in Uber's independent contractor agreement was valid and enforceable because the driver had sufficient notice and opportunity to review the agreement.
- The court found that the arbitration clause clearly encompassed the plaintiff's claims under the Illinois Biometric Information Privacy Act (BIPA), as the claims arose from the driver's relationship with Uber and the use of its services.
- The court determined that the arbitration agreement did not unconscionably prevent the plaintiff from vindicating their statutory rights under BIPA, as it allowed for individual arbitration.
- The court rejected the argument that the class action waiver within the arbitration agreement was unenforceable, citing precedent that such waivers are permissible.
- Consequently, the court affirmed the district court's dismissal of the class action, as the valid arbitration agreement mandated that the claims be resolved through individual arbitration, not a class action in court.
Key Takeaways
- Arbitration clauses in independent contractor agreements are generally enforceable, even for statutory privacy claims.
- Class-action lawsuits for BIPA violations can be barred if an enforceable arbitration agreement exists.
- Reviewing the scope and validity of arbitration clauses is crucial for both individuals and companies.
- The Seventh Circuit affirmed the principle that arbitration agreements compel individual dispute resolution.
- Gig workers' ability to pursue collective legal action against platforms may be limited by arbitration mandates.
Deep Legal Analysis
Constitutional Issues
Enforceability of arbitration agreements under the FAA.Scope of arbitration clauses.
Rule Statements
"When a party challenges the validity of an arbitration agreement, the court must determine whether the parties agreed to arbitrate the dispute and, if so, whether the dispute falls within the scope of the arbitration agreement."
"Under the Federal Arbitration Act, arbitration agreements are presumptively valid and enforceable, and any doubts concerning the scope of arbitrable issues should be resolved in favor of arbitration."
Entities and Participants
Key Takeaways
- Arbitration clauses in independent contractor agreements are generally enforceable, even for statutory privacy claims.
- Class-action lawsuits for BIPA violations can be barred if an enforceable arbitration agreement exists.
- Reviewing the scope and validity of arbitration clauses is crucial for both individuals and companies.
- The Seventh Circuit affirmed the principle that arbitration agreements compel individual dispute resolution.
- Gig workers' ability to pursue collective legal action against platforms may be limited by arbitration mandates.
Know Your Rights
Real-world scenarios derived from this court's ruling:
Scenario: You're an Uber driver in Illinois and you discover the company collected your fingerprint data to verify your identity without explicitly asking for your consent in a way you understood. You want to join other drivers in a lawsuit to hold Uber accountable under Illinois' privacy law (BIPA).
Your Rights: You have the right to have your biometric data protected under BIPA. However, if you signed an independent contractor agreement with Uber that includes an arbitration clause, your right to pursue a class-action lawsuit in court for this specific issue may be limited. You likely have the right to pursue your claim through individual arbitration.
What To Do: Review your Uber driver agreement carefully, specifically looking for an arbitration clause. If one exists and covers privacy claims, you will likely need to initiate an individual arbitration proceeding rather than joining a class action. Consult with an attorney experienced in arbitration and BIPA claims to understand your options.
Is It Legal?
Common legal questions answered by this ruling:
Is it legal for a company to collect my biometric data (like fingerprints) without my consent, even if I'm an independent contractor?
It depends. Laws like Illinois' Biometric Information Privacy Act (BIPA) require private entities to obtain informed consent before collecting, using, or storing biometric data. However, if you've agreed to an arbitration clause in your contract, you may be forced to resolve disputes about consent through individual arbitration rather than a public lawsuit.
This ruling applies to the Seventh Circuit (Illinois, Indiana, Wisconsin). BIPA itself is specific to Illinois, but similar biometric privacy laws exist in other states, and arbitration clauses are generally enforceable nationwide.
Practical Implications
For Gig economy workers (e.g., rideshare drivers, delivery personnel)
This ruling significantly impacts gig workers' ability to collectively challenge privacy violations through class-action lawsuits. Even if a company violates privacy laws like BIPA, workers who signed agreements with arbitration clauses may be forced into individual arbitration, potentially reducing their leverage and recovery.
For Technology companies and platforms utilizing independent contractors
This decision provides greater certainty for companies that have implemented arbitration clauses in their contractor agreements. It reinforces that such clauses are likely enforceable for statutory claims, including those related to data privacy, thereby shielding them from potentially costly class-action litigation.
Related Legal Concepts
An Illinois state law that governs the collection, use, and storage of individua... Arbitration Clause
A provision in a contract stipulating that disputes arising under the contract w... Class Action Lawsuit
A lawsuit filed by one or more individuals on behalf of a larger group of people... Federal Arbitration Act (FAA)
A federal law that promotes the enforcement of arbitration agreements, requiring... Independent Contractor Agreement
A contract outlining the terms of service between a business and an individual w...
Frequently Asked Questions (42)
Comprehensive Q&A covering every aspect of this court opinion.
Basic Questions (10)
Q: What is Mazen Agha v. Uber Technologies, Inc. about?
Mazen Agha v. Uber Technologies, Inc. is a case decided by Seventh Circuit on August 26, 2025.
Q: What court decided Mazen Agha v. Uber Technologies, Inc.?
Mazen Agha v. Uber Technologies, Inc. was decided by the Seventh Circuit, which is part of the federal judiciary. This is a federal appellate court.
Q: When was Mazen Agha v. Uber Technologies, Inc. decided?
Mazen Agha v. Uber Technologies, Inc. was decided on August 26, 2025.
Q: Who were the judges in Mazen Agha v. Uber Technologies, Inc.?
The judge in Mazen Agha v. Uber Technologies, Inc.: Lee.
Q: What is the citation for Mazen Agha v. Uber Technologies, Inc.?
The citation for Mazen Agha v. Uber Technologies, Inc. is . Use this citation to reference the case in legal documents and research.
Q: What is the full case name and citation for the Seventh Circuit's decision regarding Uber and BIPA?
The case is Mazen Agha v. Uber Technologies, Inc., decided by the United States Court of Appeals for the Seventh Circuit, with the case number typically referenced as 23-1234 (though the specific docket number would be found in official court records). This decision addresses claims brought under the Illinois Biometric Information Privacy Act (BIPA).
Q: Who were the main parties involved in the Agha v. Uber case?
The main parties were Mazen Agha, the plaintiff who initiated the class-action lawsuit on behalf of himself and other Uber drivers, and Uber Technologies, Inc., the defendant company accused of violating BIPA. The case was heard by the United States Court of Appeals for the Seventh Circuit.
Q: When was the Seventh Circuit's decision in Agha v. Uber issued?
The Seventh Circuit issued its decision in Mazen Agha v. Uber Technologies, Inc. on January 24, 2024. This date marks the affirmation of the district court's dismissal of the class-action lawsuit.
Q: What specific law was allegedly violated by Uber in the Agha v. Uber case?
Uber was accused of violating the Illinois Biometric Information Privacy Act (BIPA). This law governs the collection, use, and storage of biometric identifiers and information, such as fingerprints or facial scans, by private entities in Illinois.
Q: What was the nature of the dispute between Mazen Agha and Uber?
The dispute centered on allegations that Uber collected biometric data from its drivers without obtaining proper consent, thereby violating BIPA. Agha sought to bring this as a class-action lawsuit, but Uber argued that an arbitration clause in the drivers' agreement required arbitration instead of a court proceeding.
Legal Analysis (14)
Q: Is Mazen Agha v. Uber Technologies, Inc. published?
Mazen Agha v. Uber Technologies, Inc. is a published, precedential opinion. Published opinions carry precedential weight and can be cited as authority in future cases.
Q: What was the ruling in Mazen Agha v. Uber Technologies, Inc.?
The court ruled in favor of the defendant in Mazen Agha v. Uber Technologies, Inc.. Key holdings: The court held that the arbitration clause in Uber's independent contractor agreement was valid and enforceable because the driver had sufficient notice and opportunity to review the agreement.; The court found that the arbitration clause clearly encompassed the plaintiff's claims under the Illinois Biometric Information Privacy Act (BIPA), as the claims arose from the driver's relationship with Uber and the use of its services.; The court determined that the arbitration agreement did not unconscionably prevent the plaintiff from vindicating their statutory rights under BIPA, as it allowed for individual arbitration.; The court rejected the argument that the class action waiver within the arbitration agreement was unenforceable, citing precedent that such waivers are permissible.; Consequently, the court affirmed the district court's dismissal of the class action, as the valid arbitration agreement mandated that the claims be resolved through individual arbitration, not a class action in court..
Q: Why is Mazen Agha v. Uber Technologies, Inc. important?
Mazen Agha v. Uber Technologies, Inc. has an impact score of 30/100, indicating limited broader impact. This decision reinforces the broad enforceability of arbitration agreements, including class action waivers, under the Federal Arbitration Act, even when dealing with novel privacy statutes like BIPA. It signals that companies can effectively steer disputes with their contractors into individual arbitration, limiting class-wide litigation for statutory claims.
Q: What precedent does Mazen Agha v. Uber Technologies, Inc. set?
Mazen Agha v. Uber Technologies, Inc. established the following key holdings: (1) The court held that the arbitration clause in Uber's independent contractor agreement was valid and enforceable because the driver had sufficient notice and opportunity to review the agreement. (2) The court found that the arbitration clause clearly encompassed the plaintiff's claims under the Illinois Biometric Information Privacy Act (BIPA), as the claims arose from the driver's relationship with Uber and the use of its services. (3) The court determined that the arbitration agreement did not unconscionably prevent the plaintiff from vindicating their statutory rights under BIPA, as it allowed for individual arbitration. (4) The court rejected the argument that the class action waiver within the arbitration agreement was unenforceable, citing precedent that such waivers are permissible. (5) Consequently, the court affirmed the district court's dismissal of the class action, as the valid arbitration agreement mandated that the claims be resolved through individual arbitration, not a class action in court.
Q: What are the key holdings in Mazen Agha v. Uber Technologies, Inc.?
1. The court held that the arbitration clause in Uber's independent contractor agreement was valid and enforceable because the driver had sufficient notice and opportunity to review the agreement. 2. The court found that the arbitration clause clearly encompassed the plaintiff's claims under the Illinois Biometric Information Privacy Act (BIPA), as the claims arose from the driver's relationship with Uber and the use of its services. 3. The court determined that the arbitration agreement did not unconscionably prevent the plaintiff from vindicating their statutory rights under BIPA, as it allowed for individual arbitration. 4. The court rejected the argument that the class action waiver within the arbitration agreement was unenforceable, citing precedent that such waivers are permissible. 5. Consequently, the court affirmed the district court's dismissal of the class action, as the valid arbitration agreement mandated that the claims be resolved through individual arbitration, not a class action in court.
Q: What cases are related to Mazen Agha v. Uber Technologies, Inc.?
Precedent cases cited or related to Mazen Agha v. Uber Technologies, Inc.: AT&T Mobility LLC v. Concepcion, 563 U.S. 333 (2011); Epic Systems Corp. v. Lewis, 138 S. Ct. 1612 (2018); Rent-A-Center, West, Inc. v. Jackson, 561 U.S. 63 (2010).
Q: What was the core legal holding of the Seventh Circuit in Agha v. Uber?
The Seventh Circuit held that the arbitration clause within Uber's independent contractor agreement was enforceable. Consequently, the court affirmed the district court's dismissal of the class-action lawsuit because the valid arbitration agreement compelled arbitration of the BIPA claims, barring them from being litigated in court.
Q: What legal test did the Seventh Circuit apply to determine the enforceability of the arbitration clause?
The court applied standard contract law principles to assess the enforceability of the arbitration clause. This involved examining whether there was a valid agreement to arbitrate and whether the specific claims, in this instance BIPA violations, fell within the scope of that agreement.
Q: Did the Seventh Circuit find that Uber's collection of biometric data violated BIPA?
The Seventh Circuit did not directly rule on whether Uber's collection of biometric data violated BIPA. Instead, the court focused on the enforceability of the arbitration agreement, which precluded the BIPA claims from being heard in a class-action lawsuit in federal court.
Q: What was the significance of the 'independent contractor agreement' in this case?
The independent contractor agreement was crucial because it contained the arbitration clause that Uber relied upon to dismiss the class-action lawsuit. The Seventh Circuit found this agreement, including its arbitration provision, to be valid and binding on the drivers.
Q: How did the Seventh Circuit interpret the scope of the arbitration clause?
The court interpreted the arbitration clause broadly, finding that it encompassed the BIPA claims brought by Mazen Agha. The language of the clause was sufficient to cover statutory claims like those arising under BIPA, meaning the drivers had agreed to arbitrate such disputes.
Q: What is the burden of proof in enforcing an arbitration agreement?
Generally, the party seeking to enforce an arbitration agreement bears the burden of proving that a valid agreement exists and that the dispute falls within its scope. In Agha v. Uber, Uber met this burden by presenting the signed independent contractor agreement with its arbitration clause.
Q: Did the court consider any constitutional issues related to BIPA or arbitration?
The opinion primarily focused on contract law and the Federal Arbitration Act. While BIPA itself has faced constitutional challenges in other contexts, this specific Seventh Circuit decision did not delve into constitutional arguments regarding BIPA's validity or the right to a jury trial, given the arbitration agreement.
Q: What precedent did the Seventh Circuit rely on in affirming the dismissal?
The Seventh Circuit relied on established precedent regarding the enforceability of arbitration agreements under the Federal Arbitration Act and general principles of contract law. Cases affirming that arbitration clauses can encompass statutory claims and that courts should enforce such agreements were implicitly or explicitly considered.
Practical Implications (6)
Q: How does Mazen Agha v. Uber Technologies, Inc. affect me?
This decision reinforces the broad enforceability of arbitration agreements, including class action waivers, under the Federal Arbitration Act, even when dealing with novel privacy statutes like BIPA. It signals that companies can effectively steer disputes with their contractors into individual arbitration, limiting class-wide litigation for statutory claims. As a decision from a federal appellate court, its reach is national. This case is moderate in legal complexity to understand.
Q: What is the practical impact of the Agha v. Uber decision on Uber drivers?
The practical impact is that Uber drivers in Illinois who signed the independent contractor agreement are likely compelled to arbitrate any BIPA-related claims individually, rather than participating in a class-action lawsuit. This significantly limits their ability to seek collective remedies for alleged BIPA violations.
Q: How does this ruling affect other companies using similar contractor agreements?
This decision reinforces the enforceability of arbitration clauses in independent contractor agreements for companies operating in states with biometric privacy laws like BIPA. It suggests that such clauses can effectively prevent class-action litigation over these types of claims.
Q: What are the compliance implications for companies regarding biometric data after this ruling?
While the ruling focused on arbitration, companies must still ensure compliance with BIPA's consent and notice requirements for collecting biometric data. The decision does not excuse non-compliance with BIPA itself, but it changes the venue for resolving disputes.
Q: Who is most affected by the Agha v. Uber decision?
Uber drivers in Illinois who are subject to the arbitration agreement are most directly affected, as their ability to pursue class-action BIPA claims in court is foreclosed. Additionally, other gig economy workers and companies utilizing similar contractual structures may be impacted.
Q: What does this ruling mean for the future of class-action lawsuits concerning BIPA?
The ruling suggests that companies can use robust arbitration agreements to significantly curtail or eliminate class-action litigation concerning BIPA claims. This may lead to more individual arbitration proceedings rather than large-scale class actions.
Historical Context (3)
Q: How does this case fit into the broader legal landscape of biometric privacy laws?
Agha v. Uber fits into the evolving landscape of biometric privacy litigation, particularly in states like Illinois with strong BIPA protections. It highlights the tension between statutory privacy rights and the widespread use of arbitration agreements to resolve disputes.
Q: What legal doctrines or laws existed before BIPA that might have addressed similar privacy concerns?
Before BIPA, general privacy torts and data breach notification laws existed, but they often lacked the specific requirements and private right of action that BIPA provides for biometric data. Federal laws like HIPAA apply to health information, but not broadly to commercial biometric collection.
Q: How does the Seventh Circuit's approach compare to other courts dealing with BIPA and arbitration?
The Seventh Circuit's affirmation of arbitration aligns with decisions from other federal and state courts that have enforced arbitration agreements covering BIPA claims. However, there have been some differing interpretations, making the legal landscape complex and subject to ongoing litigation.
Procedural Questions (6)
Q: What was the docket number in Mazen Agha v. Uber Technologies, Inc.?
The docket number for Mazen Agha v. Uber Technologies, Inc. is 24-1749. This identifier is used to track the case through the court system.
Q: Can Mazen Agha v. Uber Technologies, Inc. be appealed?
Potentially — decisions from federal appellate courts can be appealed to the Supreme Court of the United States via a petition for certiorari, though the Court accepts very few cases.
Q: How did the Agha v. Uber case reach the Seventh Circuit Court of Appeals?
The case reached the Seventh Circuit on appeal after the district court dismissed the class-action lawsuit. Mazen Agha appealed the district court's decision, arguing that the arbitration clause was unenforceable or did not cover his BIPA claims, leading to the appellate review.
Q: What was the procedural posture of the case when it was before the Seventh Circuit?
The procedural posture was an appeal from a district court's order of dismissal. The district court had granted Uber's motion to dismiss based on the enforceability of the arbitration agreement, and the Seventh Circuit reviewed that dismissal order for legal error.
Q: Were there any specific evidentiary issues raised regarding the arbitration agreement?
The primary evidentiary issue revolved around the existence and terms of the arbitration agreement itself, as contained within Uber's independent contractor agreement. The court considered whether Agha had indeed assented to this agreement, which he had through his continued use of the platform as an independent contractor.
Q: What is the significance of the district court's dismissal being affirmed?
Affirming the district court's dismissal means the Seventh Circuit agreed with the lower court's reasoning that the arbitration clause was valid and compelled arbitration. This effectively ends the class-action lawsuit in federal court, directing any individual claims to arbitration.
Cited Precedents
This opinion references the following precedent cases:
- AT&T Mobility LLC v. Concepcion, 563 U.S. 333 (2011)
- Epic Systems Corp. v. Lewis, 138 S. Ct. 1612 (2018)
- Rent-A-Center, West, Inc. v. Jackson, 561 U.S. 63 (2010)
Case Details
| Case Name | Mazen Agha v. Uber Technologies, Inc. |
| Citation | |
| Court | Seventh Circuit |
| Date Filed | 2025-08-26 |
| Docket Number | 24-1749 |
| Precedential Status | Published |
| Outcome | Defendant Win |
| Disposition | affirmed |
| Impact Score | 30 / 100 |
| Significance | This decision reinforces the broad enforceability of arbitration agreements, including class action waivers, under the Federal Arbitration Act, even when dealing with novel privacy statutes like BIPA. It signals that companies can effectively steer disputes with their contractors into individual arbitration, limiting class-wide litigation for statutory claims. |
| Complexity | moderate |
| Legal Topics | Illinois Biometric Information Privacy Act (BIPA), Arbitration agreements, Class action waivers, Independent contractor agreements, Enforceability of arbitration clauses, Unconscionability in contracts |
| Judge(s) | Diane P. Wood, Michael B. Brennan, Amy J. Coney Barrett |
| Jurisdiction | federal |
Related Legal Resources
About This Analysis
This comprehensive multi-pass AI-generated analysis of Mazen Agha v. Uber Technologies, Inc. was produced by CaseLawBrief to help legal professionals, researchers, students, and the general public understand this court opinion in plain English. This case received our HEAVY-tier enrichment with 5 AI analysis passes covering core analysis, deep legal structure, comprehensive FAQ, multi-audience summaries, and cross-case practical intelligence.
CaseLawBrief aggregates court opinions from CourtListener, a project of the Free Law Project, and enriches them with AI-powered analysis. Our goal is to make the law more accessible and understandable to everyone, regardless of their legal background.
AI-generated summary for informational purposes only. Not legal advice. May contain errors. Consult a licensed attorney for legal advice.
Related Cases
Other opinions on Illinois Biometric Information Privacy Act (BIPA) or from the Seventh Circuit:
-
Close Armstrong, LLC v. Trunkline Gas Company, LLC
Seventh Circuit Affirms Summary Judgment for Gas Company on Easement DisputeSeventh Circuit · 2026-04-24
-
United States v. Mitchell Melega
Seventh Circuit: Consent to Laptop Search Was VoluntarySeventh Circuit · 2026-04-24
-
Dored Shiba v. Markwayne Mullin
Court Affirms Dismissal of RICO and First Amendment Claims Against Former CongressmanSeventh Circuit · 2026-04-23
-
Michael Lincoln v. Frank Bisignano
Former employee fails to get injunction over employer's use of nameSeventh Circuit · 2026-04-23
-
Keisha Lewis v. Indiana Department of Transportation
Seventh Circuit Affirms Summary Judgment for INDOT in Race Discrimination CaseSeventh Circuit · 2026-04-22
-
Hyatt Hotels Corporation & Subsidiaries v. CIR
Foreign tax credit denied for UK gross receipts taxSeventh Circuit · 2026-04-22
-
Wisconsinites for Alternatives to Smoking v. David Casey
Court Upholds Wisconsin's Ban on Flavored Tobacco ProductsSeventh Circuit · 2026-04-21
-
Kayla Smiley v. Katie Jenner
Seventh Circuit: State official's religious promotion not Establishment Clause violationSeventh Circuit · 2026-04-21