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  • Commentaries
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7th Circuit Case Commentaries

Principles Governing Dismissal for Want of Prosecution and Rule 60(b) Relief: Griffiths v. Eggemeyer

Principles Governing Dismissal for Want of Prosecution and Rule 60(b) Relief: Griffiths v. Eggemeyer

Date: May 30, 2025
Principles Governing Dismissal for Want of Prosecution and Rule 60(b) Relief Introduction In Terri Griffiths v. Lorin Eggemeyer, 23-3253 & 24-1098 (7th Cir. May 29, 2025), the Seventh Circuit...
Addressing Statutory Safety Valve Relief as a Principal Mitigating Argument

Addressing Statutory Safety Valve Relief as a Principal Mitigating Argument

Date: May 29, 2025
Addressing Statutory Safety Valve Relief as a Principal Mitigating Argument Introduction United States v. Kevin Hodge (7th Cir. 2025) clarifies a sentencing court’s obligation to engage with a...
Permissible Reliance on Specialist Diagnoses in §1983 Deliberate Indifference Claims

Permissible Reliance on Specialist Diagnoses in §1983 Deliberate Indifference Claims

Date: May 28, 2025
Permissible Reliance on Specialist Diagnoses in §1983 Deliberate Indifference Claims Introduction In Matthew Doughty v. Karl Hoffmann, No. 24-2306 (7th Cir. May 27, 2025), the Seventh Circuit...
FOIA Timeliness and Remedies Clarified: Delay Does Not Merit Declaratory Relief, FOIA Bars APA Claims — Libarov v. ICE

FOIA Timeliness and Remedies Clarified: Delay Does Not Merit Declaratory Relief, FOIA Bars APA Claims — Libarov v. ICE

Date: May 28, 2025
FOIA Timeliness and Remedies Clarified: Delay Does Not Merit Declaratory Relief, FOIA Bars APA Claims — Libarov v. ICE Introduction Sotir Libarov v. U.S. Immigration and Customs Enforcement (No....
ALJ’s Discretion in Listing Determination and Substantial Evidence Standard in Disability Claims

ALJ’s Discretion in Listing Determination and Substantial Evidence Standard in Disability Claims

Date: May 28, 2025
ALJ’s Discretion in Listing Determination and Substantial Evidence Standard in Disability Claims Introduction This commentary examines the United States Court of Appeals for the Seventh Circuit’s...
Clarifying the Standard for Nonfrivolous Sentencing Guideline Objections in Anders Appeals

Clarifying the Standard for Nonfrivolous Sentencing Guideline Objections in Anders Appeals

Date: May 21, 2025
Clarifying the Standard for Nonfrivolous Sentencing Guideline Objections in Anders Appeals Introduction United States v. Jamie Sullivan, decided May 20 2025 by the Seventh Circuit, addresses the...
Strict Compliance with PLRA Exhaustion: No “Sue-First, Exhaust-Later” Rule

Strict Compliance with PLRA Exhaustion: No “Sue-First, Exhaust-Later” Rule

Date: May 21, 2025
Strict Compliance with PLRA Exhaustion: No “Sue-First, Exhaust-Later” Rule Introduction Bobby Tatum v. Russell Williams is a decision of the United States Court of Appeals for the Seventh Circuit...
Reaffirming PLRA Exhaustion: Availability Period and Adequate Notice Requirements

Reaffirming PLRA Exhaustion: Availability Period and Adequate Notice Requirements

Date: May 20, 2025
Reaffirming PLRA Exhaustion: Availability Period and Adequate Notice Requirements Introduction The Seventh Circuit’s May 19, 2025 decision in Anthony Martin v. Zarak Thompson addresses the contours...
Clarifying Pleading Standards for §1983, ADA, and FHA Claims Against Housing Authorities

Clarifying Pleading Standards for §1983, ADA, and FHA Claims Against Housing Authorities

Date: May 20, 2025
Clarifying Pleading Standards for §1983, ADA, and FHA Claims Against Housing Authorities Introduction Curtis K. Jackson, Sr. (“Jackson”), a qualified person with disabilities, sued the Chicago...
Waiver of As-Applied Free Exercise Claims in Successive Appeals: Lukaszczyk v. Cook County

Waiver of As-Applied Free Exercise Claims in Successive Appeals: Lukaszczyk v. Cook County

Date: May 20, 2025
Waiver of As-Applied Free Exercise Claims in Successive Appeals: Lukaszczyk v. Cook County Introduction In Barbara Lukaszczyk et al. v. Cook County, Illinois, the Seventh Circuit addressed whether...
Defining “Reasonable Time” For Rule 60(b)(6) Motions in Capital Habeas Cases: Ritchie v. Neal

Defining “Reasonable Time” For Rule 60(b)(6) Motions in Capital Habeas Cases: Ritchie v. Neal

Date: May 19, 2025
Defining “Reasonable Time” For Rule 60(b)(6) Motions in Capital Habeas Cases: Ritchie v. Neal Introduction Benjamin Ritchie v. Ron Neal presents a late-stage attempt by a death-row inmate to reopen...
Reaffirmation of the Pretext Standard and Alignment of McDonnell Douglas and Ortiz Frameworks Under Title VII

Reaffirmation of the Pretext Standard and Alignment of McDonnell Douglas and Ortiz Frameworks Under Title VII

Date: May 17, 2025
Reaffirmation of the Pretext Standard and Alignment of McDonnell Douglas and Ortiz Frameworks Under Title VII Introduction In James Napier v. Orchard School Foundation (7th Cir. No. 23-1659, decided...
Ferrari v. Link: Permissibility of Police‐Escort Requirements in Public Buildings Absent Viewpoint Discrimination

Ferrari v. Link: Permissibility of Police‐Escort Requirements in Public Buildings Absent Viewpoint Discrimination

Date: May 6, 2025
Ferrari v. Link: Permissibility of Police‐Escort Requirements in Public Buildings Absent Viewpoint Discrimination Introduction In Patrick M. Ferrari v. Todd Link, the Seventh Circuit addressed...
Establishing Knowing Possession of Child Pornography Through Cached Thumbnails and Circumstantial Evidence

Establishing Knowing Possession of Child Pornography Through Cached Thumbnails and Circumstantial Evidence

Date: May 6, 2025
Establishing Knowing Possession of Child Pornography Through Cached Thumbnails and Circumstantial Evidence 1. Introduction This commentary examines the Seventh Circuit’s decision in United States v....
Cached Thumbnails as Evidence of Knowing Possession in Child Pornography Prosecutions

Cached Thumbnails as Evidence of Knowing Possession in Child Pornography Prosecutions

Date: May 6, 2025
Cached Thumbnails as Evidence of Knowing Possession in Child Pornography Prosecutions Introduction United States v. Edward C. Brown is a Seventh Circuit decision upholding a conviction for possession...
Consent Threshold for Eighth Amendment Prison Sexual Abuse Claims

Consent Threshold for Eighth Amendment Prison Sexual Abuse Claims

Date: May 3, 2025
Consent Threshold for Eighth Amendment Prison Sexual Abuse Claims Introduction David C.L. Walton, a state prisoner in Wisconsin, sued prison nurse Ashley Nehls under 42 U.S.C. § 1983, alleging that...
Clarifying Attorney Disclosure Obligations and Proximate Cause in Legal Malpractice: Signal Funding v. Sugar Felsenthal

Clarifying Attorney Disclosure Obligations and Proximate Cause in Legal Malpractice: Signal Funding v. Sugar Felsenthal

Date: May 3, 2025
Clarifying Attorney Disclosure Obligations and Proximate Cause in Legal Malpractice: Signal Funding v. Sugar Felsenthal Introduction Signal Funding, LLC (“Signal”) is a pre-settlement...
Clarifying Insurer Duty to Defend BIPA Claims: Access or Disclosure vs. Statutory Violations Exclusions

Clarifying Insurer Duty to Defend BIPA Claims: Access or Disclosure vs. Statutory Violations Exclusions

Date: May 3, 2025
Clarifying Insurer Duty to Defend BIPA Claims: Access or Disclosure vs. Statutory Violations Exclusions Introduction This commentary examines Citizens Insurance Company of America v. Mullins Food...
Signal Funding v. Sugar Felsenthal: Clarifying Fraudulent Concealment and Disclosure Duties in Attorney-Client Relations

Signal Funding v. Sugar Felsenthal: Clarifying Fraudulent Concealment and Disclosure Duties in Attorney-Client Relations

Date: May 3, 2025
Signal Funding v. Sugar Felsenthal: Clarifying Fraudulent Concealment and Disclosure Duties in Attorney-Client Relations Introduction In Signal Funding, LLC v. Sugar Felsenthal Grais & Helsinger LLP,...
Reaffirming Deference to Sentencing Guidelines Commentary under Stinson: Inclusion of Intended Loss in U.S.S.G. §2B1.1 Calculations

Reaffirming Deference to Sentencing Guidelines Commentary under Stinson: Inclusion of Intended Loss in U.S.S.G. §2B1.1 Calculations

Date: May 1, 2025
Reaffirming Deference to Sentencing Guidelines Commentary under Stinson: Inclusion of Intended Loss in U.S.S.G. §2B1.1 Calculations Introduction United States v. Eric Upchurch is a Seventh Circuit...
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