7th Circuit Case Commentaries

Leon Good-Faith Applies Despite Close Probable Cause Where Affidavit Shows Substantial Access (Not Residency) and Alleged Misstatements/Omissions Are at Most Negligent

Date: Jun 13, 2026

Leon Good-Faith Applies Despite Close Probable Cause Where Affidavit Shows Substantial Access (Not Residency) and Alleged Misstatements/Omissions Are at Most Negligent I. Introduction In United...

Seventh Circuit: Rule 11 “Persist” Omission Not Plain Error When Otherwise Conveyed; Completed Hobbs Act Robbery Remains a § 924(c) Crime of Violence Post-Borden

Date: Jun 12, 2026

Seventh Circuit: Rule 11 “Persist” Omission Not Plain Error When Otherwise Conveyed; Completed Hobbs Act Robbery Remains a § 924(c) Crime of Violence Post-Borden Introduction In United States v....

Res Ipsa Loquitur Requires Probable Defendant Responsibility When Vendor Control Is Shared

Date: Jun 12, 2026

Res Ipsa Loquitur Requires Probable Defendant Responsibility When Vendor Control Is Shared Case: Rateb Khouri v. Highland Park CVS, L.L.C. and CVS Pharmacy Inc. Court: United States Court of Appeals...

Threats Against a Prosecutor Do Not Require Disqualification Under 28 U.S.C. § 528 Absent a Qualifying “Personal Relationship” (Anders Dismissal)

Date: Jun 12, 2026

Threats Against a Prosecutor Do Not Require Disqualification Under 28 U.S.C. § 528 Absent a Qualifying “Personal Relationship” (Anders Dismissal) Introduction In United States v. Ademeko...

Seventh Circuit: § 1325(b)(1)(B) Does Not Bar Paying Chapter 13 Debtors’ Attorneys’ Fees During the Commitment Period, and Administrative Fees Need Not Be Paid via Proof of Claim

Date: Jun 12, 2026

Seventh Circuit: § 1325(b)(1)(B) Does Not Bar Paying Chapter 13 Debtors’ Attorneys’ Fees During the Commitment Period, and Administrative Fees Need Not Be Paid via Proof of Claim 1. Introduction In...

Minor Editorial Changes, Verifiable “Anonymous” Submissions, and Non-Retraction Policies Do Not Establish Actual Malice (and Sanctions Require Bad Faith)

Date: Jun 12, 2026

Minor Editorial Changes, Verifiable “Anonymous” Submissions, and Non-Retraction Policies Do Not Establish Actual Malice (and Sanctions Require Bad Faith) Introduction Jewel Sanitary Napkins, LLC v....

Res Judicata Bars Federal Vagueness and Related Constitutional Claims After Illinois Zoning Enforcement, Even Where Rooker-Feldman Leaves Room for Some Damages

Date: Jun 12, 2026

Res Judicata Bars Federal Vagueness and Related Constitutional Claims After Illinois Zoning Enforcement, Even Where Rooker-Feldman Leaves Room for Some Damages 1. Introduction In Clay Wortham v....

Seventh Circuit: A Rote § 3553(a) Recitation—Even at the Bottom of the Guidelines—Is Procedurally Inadequate Without an Individualized Response to Mitigation

Date: Jun 12, 2026

Seventh Circuit: A Rote § 3553(a) Recitation—Even at the Bottom of the Guidelines—Is Procedurally Inadequate Without an Individualized Response to Mitigation 1. Introduction In United States v. Frank...

“Relating To” in § 2252A(b)(2) Is Broad: Indiana Child Molesting (§ 35-42-4-3(b)) Categorically Triggers the Mandatory Minimum

Date: Jun 12, 2026

“Relating To” in § 2252A(b)(2) Is Broad: Indiana Child Molesting (§ 35-42-4-3(b)) Categorically Triggers the Mandatory Minimum I. Introduction United States v. Joshua Schatz (7th Cir. June 9, 2026)...

Unreviewed State Administrative Decisions Do Not Preclude Title VII Claims, But Can Bar § 1983 and State-Law Claims

Date: Jun 12, 2026

Unreviewed State Administrative Decisions Do Not Preclude Title VII Claims, But Can Bar § 1983 and State-Law Claims Introduction Vairrun Strickland v. City of Markham (Seventh Circuit, decided June...

Chapter 13 Plans May Pay Debtors’ Attorneys’ Fees During the Commitment Period Despite a § 1325(b)(1)(B) Objection

Date: Jun 11, 2026

Chapter 13 Plans May Pay Debtors’ Attorneys’ Fees During the Commitment Period Despite a § 1325(b)(1)(B) Objection Introduction In City of Chicago v. Ahmed Alayah (Nos. 25-2878 & 25-2879), the...

Revolinsky v. Bayer: Enforcing MDL Common-Benefit Fee Protocols and Limiting Post-Approval Fee Reallocation Challenges

Date: Jun 11, 2026

Revolinsky v. Bayer: Enforcing MDL Common-Benefit Fee Protocols and Limiting Post-Approval Fee Reallocation Challenges I. Introduction In Laura Revolinsky v. Bayer Corporation, the Seventh Circuit...

Cost-Saving Measures and “Understaffing” Allegations Are Not Enough: Evidence of a Systemic Breakdown Is Required for Monell Liability (and Officers May Rely on Medical Judgment)

Date: Jun 11, 2026

Cost-Saving Measures and “Understaffing” Allegations Are Not Enough: Evidence of a Systemic Breakdown Is Required for Monell Liability (and Officers May Rely on Medical Judgment) Case: Steven...

Substance over Caption in Post-Judgment Motions and “Outside-the-Four-Corners” Loan-Modification Promises as Oral Contracts (Schneider v. Wells Fargo Bank, N.A.)

Date: Jun 11, 2026

Substance over Caption in Post-Judgment Motions and “Outside-the-Four-Corners” Loan-Modification Promises as Oral Contracts Introduction In Amy Schneider v. Wells Fargo Bank, N.A., No. 25-2163 (7th...

Common-Law First Use Defeats Federal Registration; Seventh Circuit Reaffirms Presumptive Prejudgment Interest Under 15 U.S.C. § 1117(a)

Date: Jun 11, 2026

Common-Law First Use Defeats Federal Registration; Seventh Circuit Reaffirms Presumptive Prejudgment Interest Under 15 U.S.C. § 1117(a) 1. Introduction Grunt Style LLC v. TWD, LLC (7th Cir. June 10,...

“Force Only as a Last Resort” Prison Use-of-Force Rules Are Not Unconstitutionally Vague as Applied to Officers

Date: Jun 11, 2026

“Force Only as a Last Resort” Prison Use-of-Force Rules Are Not Unconstitutionally Vague as Applied to Officers I. Introduction In Derek Hundley v. Dee Dee Brookhart, the U.S. Court of Appeals for...

Illinois Minimum Wage Law Overtime: No Portal-to-Portal “Preliminary Activities” Exclusion and No General “Benefit of the Employer” Limitation

Date: Jun 11, 2026

Illinois Minimum Wage Law Overtime: No Portal-to-Portal “Preliminary Activities” Exclusion and No General “Benefit of the Employer” Limitation Case: Lisa Johnson v. Amazon.com Services LLC (7th Cir....

Meaningless Medicaid Bills Do Not Create Article III Standing for Prospective Injunctive Relief

Date: Jun 11, 2026

Meaningless Medicaid Bills Do Not Create Article III Standing for Prospective Injunctive Relief I. Introduction In Salvatore Arcidiacono v. Elizabeth Whitehorn (7th Cir. June 8, 2026), four Illinois...

18 U.S.C. § 1589 Reaches Counties: Civil Immigration Detainee Labor Cannot Be Coerced by Solitary Confinement

Date: Jun 7, 2026

18 U.S.C. § 1589 Reaches Counties: Civil Immigration Detainee Labor Cannot Be Coerced by Solitary Confinement Introduction In Aleksey Ruderman v. Kenosha County, Wisconsin, et al. (7th Cir. June 5,...

Seventh Circuit: No Qualified First Amendment Right for Press or Public to Witness State Executions Absent Historical Openness

Date: Jun 6, 2026

Seventh Circuit: No Qualified First Amendment Right for Press or Public to Witness State Executions Absent Historical Openness I. Introduction Associated Press, et al. v. Ron Neal and Lloyd Arnold...