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  • Commentaries
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7th Circuit Case Commentaries

Oral Colloquy Cannot Implicitly Amend a Binding Rule 11(c)(1)(C) Plea Agreement: Commentary on United States v. Sherman Threets (7th Cir. 2025)

Oral Colloquy Cannot Implicitly Amend a Binding Rule 11(c)(1)(C) Plea Agreement: Commentary on United States v. Sherman Threets (7th Cir. 2025)

Date: Jun 18, 2025
Oral Colloquy Cannot Implicitly Amend a Binding Rule 11(c)(1)(C) Plea Agreement: Commentary on United States v. Sherman Threets (7th Cir. 2025) Introduction The Seventh Circuit’s decision in United...
United States v. Russell & Williams: The Seventh Circuit Demands Precision in “Third-Party-Risk” Supervised-Release Conditions and Clarifies Competency-to-Stand-Trial Assessments

United States v. Russell & Williams: The Seventh Circuit Demands Precision in “Third-Party-Risk” Supervised-Release Conditions and Clarifies Competency-to-Stand-Trial Assessments

Date: Jun 18, 2025
United States v. Russell & Williams: The Seventh Circuit Demands Precision in “Third-Party-Risk” Supervised-Release Conditions and Clarifies Competency-to-Stand-Trial Assessments Introduction On...
Petersen v. Pedersen: Circumstantial Probable Cause and the Scope of Qualified Immunity in OWI Arrests

Petersen v. Pedersen: Circumstantial Probable Cause and the Scope of Qualified Immunity in OWI Arrests

Date: Jun 11, 2025
Petersen v. Pedersen: Circumstantial Probable Cause and the Scope of Qualified Immunity in OWI Arrests 1. Introduction The Seventh Circuit’s decision in Mark Petersen v. Stefanie Pedersen, No....
No Predicate, No Conspiracy: Seventh Circuit Clarifies § 371 Liability and Jury-Instruction Standards in United States v. Clark

No Predicate, No Conspiracy: Seventh Circuit Clarifies § 371 Liability and Jury-Instruction Standards in United States v. Clark

Date: Jun 11, 2025
No Predicate, No Conspiracy: Seventh Circuit Clarifies § 371 Liability and Jury-Instruction Standards in United States v. Clark Introduction The Seventh Circuit’s decision in United States v. Derrick...
United States v. Clark & Mesner: Seventh Circuit Demands a Live Predicate for § 371 Conspiracy and Clarifies Use-of-Document Liability under § 1001(a)(3)

United States v. Clark & Mesner: Seventh Circuit Demands a Live Predicate for § 371 Conspiracy and Clarifies Use-of-Document Liability under § 1001(a)(3)

Date: Jun 11, 2025
United States v. Clark & Mesner: Seventh Circuit Demands a Live Predicate for § 371 Conspiracy and Clarifies Use-of-Document Liability under § 1001(a)(3) Introduction The Seventh Circuit’s opinion in...

        Seventh Circuit Tightens “Nexus” Showing for Gang-Recruitment Asylum Claims: 
        De Paz-Peraza v. Bondi (2025)

Seventh Circuit Tightens “Nexus” Showing for Gang-Recruitment Asylum Claims: De Paz-Peraza v. Bondi (2025)

Date: Jun 11, 2025
Seventh Circuit Tightens “Nexus” Showing for Gang-Recruitment Asylum Claims: De Paz-Peraza v. Bondi (2025) Introduction Carlos Antonio de Paz-Peraza, a 17-year-old Salvadoran targeted by the violent...
Forfeiture, Futility, and Exhaustion: The Seventh Circuit’s Clarification of Litigation Duties in Anderson v. United Airlines (2025)

Forfeiture, Futility, and Exhaustion: The Seventh Circuit’s Clarification of Litigation Duties in Anderson v. United Airlines (2025)

Date: Jun 11, 2025
Forfeiture, Futility, and Exhaustion: The Seventh Circuit’s Clarification of Litigation Duties in Anderson v. United Airlines (2025) 1. Introduction Case name: Thomas Anderson, et al. v. United...
“Full-Record Review” Standard Solidified: Minimal Oral Explanation Can Sustain Above-Guideline Sentences on Revocation of Supervised Release

“Full-Record Review” Standard Solidified: Minimal Oral Explanation Can Sustain Above-Guideline Sentences on Revocation of Supervised Release

Date: Jun 11, 2025
“Full-Record Review” Standard Solidified: Minimal Oral Explanation Can Sustain Above-Guideline Sentences on Revocation of Supervised Release 1. Introduction In United States v. Roger Snake,...
Discretion and Limits in Recruiting Pro Bono Counsel Under §1915(e) in Civil Rights Litigation

Discretion and Limits in Recruiting Pro Bono Counsel Under §1915(e) in Civil Rights Litigation

Date: Jun 10, 2025
Discretion and Limits in Recruiting Pro Bono Counsel Under §1915(e) in Civil Rights Litigation 1. Introduction Lazerek Austin v. Cheryl Hansen is a Seventh Circuit decision addressing for the first...
Categorical Exclusion of Attempted Hobbs Act Robbery from “Crime of Violence” Under 18 U.S.C. § 924(c)

Categorical Exclusion of Attempted Hobbs Act Robbery from “Crime of Violence” Under 18 U.S.C. § 924(c)

Date: Jun 10, 2025
Categorical Exclusion of Attempted Hobbs Act Robbery from “Crime of Violence” Under 18 U.S.C. § 924(c) Introduction This commentary examines the Seventh Circuit’s decision in United States v. Deaunta...
Permissible Inferences from Silence and Nationality Neutrality in Sentencing: United States v. Paul Williams Anti

Permissible Inferences from Silence and Nationality Neutrality in Sentencing: United States v. Paul Williams Anti

Date: Jun 10, 2025
Permissible Inferences from Silence and Nationality Neutrality in Sentencing: United States v. Paul Williams Anti Introduction United States v. Paul Williams Anti is a Seventh Circuit decision issued...
Limitation on District Court’s Authority to Reduce Federal Mandatory Minimum for Discharged State Sentences

Limitation on District Court’s Authority to Reduce Federal Mandatory Minimum for Discharged State Sentences

Date: Jun 10, 2025
Limitation on District Court’s Authority to Reduce Federal Mandatory Minimum for Discharged State Sentences Introduction United States v. Dion Bell, decided on June 3, 2025, by the Seventh Circuit,...
Strict Adherence to 21 U.S.C. § 851: Predicate‐Conviction Notice Rule and Its Mandatory Enforcement

Strict Adherence to 21 U.S.C. § 851: Predicate‐Conviction Notice Rule and Its Mandatory Enforcement

Date: Jun 3, 2025
Strict Adherence to 21 U.S.C. § 851: Predicate-Conviction Notice Rule and Its Mandatory Enforcement 1. Introduction United States v. Thomas Wilkinson, IV is a Seventh Circuit decision clarifying the...
Presumption of Verity in Plea Colloquies and Deference to District Courts in §2255 Ineffective‐Assistance Claims

Presumption of Verity in Plea Colloquies and Deference to District Courts in §2255 Ineffective‐Assistance Claims

Date: Jun 3, 2025
Presumption of Verity in Plea Colloquies and Deference to District Courts in §2255 Ineffective‐Assistance Claims Introduction This commentary examines the Seventh Circuit’s decision in Helen Caldwell...
Clarifying Section 1292(a)(1): Limits on Interlocutory Appeals of Injunction Denials

Clarifying Section 1292(a)(1): Limits on Interlocutory Appeals of Injunction Denials

Date: Jun 3, 2025
Clarifying Section 1292(a)(1): Limits on Interlocutory Appeals of Injunction Denials Introduction This commentary examines the Seventh Circuit’s decision in Union Pacific Railroad Company v. Illinois...
Preservation of Potentially Exculpatory Evidence: Bad-Faith Requirement and Procedural Exhaustion in Federal Habeas Review

Preservation of Potentially Exculpatory Evidence: Bad-Faith Requirement and Procedural Exhaustion in Federal Habeas Review

Date: May 31, 2025
Preservation of Potentially Exculpatory Evidence: Bad-Faith Requirement and Procedural Exhaustion in Federal Habeas Review Introduction This case arises from Mark Johnson’s federal habeas corpus...
Eighth Amendment Protections Against Medical Hazards and Environmental Deprivation: From Pepper Spray to Frigid Cells

Eighth Amendment Protections Against Medical Hazards and Environmental Deprivation: From Pepper Spray to Frigid Cells

Date: May 31, 2025
Eighth Amendment Protections Against Medical Hazards and Environmental Deprivation: From Pepper Spray to Frigid Cells Introduction In Antonio Smith v. John Kind, the Seventh Circuit addressed the...
Propensity-Free Chain Reasoning for Intent Under Fed. R. Evid. 404(b) Affirmed in United States v. Johnson

Propensity-Free Chain Reasoning for Intent Under Fed. R. Evid. 404(b) Affirmed in United States v. Johnson

Date: May 31, 2025
Propensity-Free Chain Reasoning for Intent Under Fed. R. Evid. 404(b) Affirmed in United States v. Johnson Introduction The Court of Appeals for the Seventh Circuit’s decision in United States v....
Inordinate Delay as a Trigger for § 2254 Exhaustion Exception: Lindsey v. Neal

Inordinate Delay as a Trigger for § 2254 Exhaustion Exception: Lindsey v. Neal

Date: May 31, 2025
Inordinate Delay as a Trigger for § 2254 Exhaustion Exception: Lindsey v. Neal Introduction In Steven Lindsey v. Ron Neal, 7th Cir. No. 23-2789 (May 30, 2025), the United States Court of Appeals for...
Enforcing Diligence in Civil Litigation: Upholding Dismissal for Want of Prosecution and Rigorous Standards for Excusable Neglect

Enforcing Diligence in Civil Litigation: Upholding Dismissal for Want of Prosecution and Rigorous Standards for Excusable Neglect

Date: May 30, 2025
Enforcing Diligence in Civil Litigation: Upholding Dismissal for Want of Prosecution and Rigorous Standards for Excusable Neglect 1. Introduction Terri Griffiths v. Lorin Eggemeyer (7th Cir. May 29,...
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