Spike Body Werks, Inc. v. Byline Bank

CourtDistrict Court, N.D. Illinois
DecidedMarch 20, 2025
Docket1:20-cv-04771
StatusUnknown

This text of Spike Body Werks, Inc. v. Byline Bank (Spike Body Werks, Inc. v. Byline Bank) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Spike Body Werks, Inc. v. Byline Bank, (N.D. Ill. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

SPIKE BODY WERKS, INC., et al., ) ) Plaintiffs, ) No. 20-cv-4771 ) v. ) Judge Jeffrey I. Cummings ) BYLINE BANK, et al., ) ) Defendants. )

MEMORANDUM OPINION AND ORDER

Plaintiffs Spike Body Werks, Inc., Geneva Repair Shop, Inc., Nicnat LLC, and Pasquale Roppo (collectively, “plaintiffs”) bring this action against defendants Byline Bank and Byline Bankcorp Inc., (collectively, “Byline” or “defendants”) alleging discrimination based on race and national origin in violation of the Equal Credit Opportunity Act (“ECOA”), 15 U.S.C. §1691, et seq. Defendants have filed a motion for summary judgment, arguing that plaintiffs have: (1) failed to present sufficient evidence to show that Byline acted with discriminatory intent in violation of the ECOA; and (2) failed to present sufficient evidence of damages. For the reasons set forth below, the Court agrees that plaintiffs have failed to present sufficient evidence to create a triable issue of fact on their ECOA claim and defendants’ motion for summary judgment, (Dckt. #72), is therefore granted. I. LEGAL STANDARD

A. Standard for Summary Judgment Summary judgment is appropriate when the moving party shows “that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 247 (1986). “A genuine dispute is present if a reasonable jury could return a verdict for the nonmoving party, and a fact is material if it might bear on the outcome of the case.” Wayland v. OSF Healthcare Sys., 94 F.4th 654, 657 (7th Cir. 2024); FKFJ, Inc. v. Village of Worth, 11 F.4th 574, 584 (7th Cir. 2021) (the existence of a factual dispute between the parties will not preclude summary judgment unless it is a genuine dispute as to a material fact).

When the moving party has met that burden, the non-moving party cannot rely on mere conclusions and allegations to concoct factual issues. Balderston v. Fairbanks Morse Engine Div. of Coltec Indus., 328 F.3d 309, 320 (7th Cir. 2003). Instead, it must “marshal and present the court with the evidence [it] contends will prove [its] case.” Goodman v. Nat. Sec. Agency, Inc., 621 F.3d 651, 654 (7th Cir. 2010); Lewis v. CITGO Petroleum Corp., 561 F.3d 698, 704 (7th Cir. 2009). Thus, a mere “scintilla of evidence” supporting the non-movant’s position does not suffice; there must be evidence on which the jury could reasonably find for the non-moving party. Anderson, 477 U.S. at 248. Of course, “[i]t is not the duty of the court to scour the record in search of evidence to defeat a motion for summary judgment; rather, the nonmoving party

bears the responsibility of identifying the evidence upon which he relies.” Harney v. Speedway SuperAmerica, LLC, 526 F.3d 1099, 1104 (7th Cir. 2008). In determining whether a genuine issue of material fact exists, all facts and reasonable inferences must be drawn in the light most favorable to the non-moving party. King v. Hendricks Cnty. Commissioners, 954 F.3d 981, 984 (7th Cir. 2020). Yet, the nonmovant “is not entitled to the benefit of inferences that are supported only by speculation or conjecture.” Boss v. Castro, 816 F.3d 910, 916 (7th Cir. 2016). Ultimately, summary judgment is granted only if “no reasonable trier of fact could find in favor of the non-moving party.” Hoppe v. Lewis Univ., 692 F.3d 833, 838 (7th Cir. 2012) (cleaned up). B. Requirements of Local Rule 56.1 Northern District of Illinois Local Rule 56.1 governs the procedures for filing and responding to motions for summary judgment in this District. The rule is intended “to aid the district court, ‘which does not have the advantage of the parties’ familiarity with the record and often cannot afford to spend the time combing the record to locate the relevant information,’ in

determining whether a trial is necessary.” Delapaz v. Richardson, 634 F.3d 895, 899 (7th Cir. 2011) (cleaned up). To this end, Local Rule 56.1(a) requires the moving party to provide a statement of material facts that complies with Local Rule 56.1(d). LR 56.1(a)(2). In turn, Local Rule 56.1(d) requires that “[e]ach asserted fact must be supported by citation to the specific evidentiary material, including the specific page number, that supports it. The court may disregard any asserted fact that is not supported with such a citation.” LR 56.1(d)(2). The non-moving party must then respond to the movant’s statement of material facts. Schrott v. Bristol-Myers Squibb Co., 403 F.3d 940, 944 (7th Cir. 2005); LR 56.1(e). The response must consist of numbered paragraphs corresponding to the numbered paragraphs in the

moving party’s Local Rule 56.1 statement, and each response “must admit the asserted fact, dispute the asserted fact, or admit in part and dispute in part the asserted fact.” LR 56.1(e)(1)- (2). “A response may not set forth any new facts, meaning facts that are not fairly responsive to the asserted fact to which the response is made.” LR 56.1(e)(2). Instead, if the opposing party wishes to assert facts not set forth in the moving party’s LR 56.1 statement, it may submit a statement of additional material facts, which also must comply with LR 56.1(d). If a party fails to respond to the Rule 56.1 statement of material facts, those facts may be deemed admitted to the extent they are supported by the evidence in the record. Keeton v. Morningstar, Inc., 667 F.3d 877, 880 (7th Cir. 2012); Parra v. Neal, 614 F.3d 635, 636 (7th Cir. 2010); LR 56.1(e)(3). In this case, Byline filed a Local Rule 56.1 statement of material facts with its motion for summary judgment, which included proper citations to the evidentiary material supporting each fact. (Dckt. #74 (“DSOF”)). In response, plaintiffs filed what they titled “Plaintiffs’ Response to FRCP56(C)(1) and Local Rule 56.1 Statement of Undisputed Facts.” (Dckt. #77 (“DSOF Resp.”). However, as Byline correctly notes, plaintiffs’ purported response does not include

numbered paragraphs that correspond directly to Byline’s statement of facts, nor do plaintiffs admit or dispute (in whole or in part) any of Byline’s asserted facts. Instead, plaintiffs at times repeat verbatim Byline’s facts – without indicating whether they are admitted or disputed – and at other times add their own additional facts. But, as the Seventh Circuit has acknowledged, “it is improper, and a violation of Local Rule 56.1, for the nonmovant to add additional facts to his response; the additional facts belong in a separate statement of additional facts.” Boyd v. City of Chicago, 225 F. Supp. 3d 708, 717 (N.D.Ill. 2016) (citing Ammons v. Aramark Unif. Servs., Inc., 368 F.3d 809, 817 (7th Cir. 2004)). For these reasons, the Court in its discretion deems Byline’s statement of material facts

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Related

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