7th Circuit Case Commentaries

United States v. Melega: Coordination-and-Concealment Supports Sophisticated-Means and Manager Enhancements; Co-Defendant Disparity May Rest on Accountability and Uncharged Similar Misconduct

Date: Apr 26, 2026

United States v. Melega: Coordination-and-Concealment Supports Sophisticated-Means and Manager Enhancements; Co-Defendant Disparity May Rest on Accountability and Uncharged Similar Misconduct 1....

Strict PLRA Exhaustion in Illinois: Missing ARB Attachments and Untimely Grievances Defeat Eighth Amendment Medical-Policy Claims

Date: Apr 26, 2026

Strict PLRA Exhaustion in Illinois: Missing ARB Attachments and Untimely Grievances Defeat Eighth Amendment Medical-Policy Claims Introduction In Paul Blake v. Wexford Health Sources, Inc. (7th Cir....

Egan Is Nonjurisdictional: Security-Clearance Deference Requires Merits Dismissal, Not Rule 12(b)(1)

Date: Apr 25, 2026

Egan Is Nonjurisdictional: Security-Clearance Deference Requires Merits Dismissal, Not Rule 12(b)(1) 1. Introduction In Dored Shiba v. Markwayne Mullin (7th Cir. Apr. 23, 2026), the Seventh Circuit...

Lincoln v. Bisignano: Substantial-Evidence Deference for RFC Findings on Intermittent Cane Use, Fatigue, and “Supportability/Consistency” Medical-Opinion Review

Date: Apr 24, 2026

Lincoln v. Bisignano: Substantial-Evidence Deference for RFC Findings on Intermittent Cane Use, Fatigue, and “Supportability/Consistency” Medical-Opinion Review I. Introduction In Michael Lincoln v....

Claim-of-Right Must Be Addressed Independently of Trust-Fund Doctrine; “Other Property” in Treas. Reg. § 1.451-4 Not Limited to Tangibles

Date: Apr 24, 2026

Claim-of-Right Must Be Addressed Independently of Trust-Fund Doctrine; “Other Property” in Treas. Reg. § 1.451-4 Not Limited to Tangibles Introduction In Hyatt Hotels Corporation & Subsidiaries v....

Rehabilitation Act § 504 Imposes a “Solely by Reason of” Causation Requirement (Not ADA But-For)

Date: Apr 24, 2026

Rehabilitation Act § 504 Imposes a “Solely by Reason of” Causation Requirement (Not ADA But-For) Introduction In Keisha Lewis v. Indiana Department of Transportation (7th Cir. Apr. 22, 2026), the...

No Severance Prejudice Where Other-Act Evidence Is Cross-Admissible and Lay Identification by an Intimate Partner Is Proper Under Rule 701 (Seventh Circuit Anders Dismissal)

Date: Apr 24, 2026

No Severance Prejudice Where Other-Act Evidence Is Cross-Admissible and Lay Identification by an Intimate Partner Is Proper Under Rule 701 (Seventh Circuit Anders Dismissal) Introduction In United...

States May Condition ENDS Sales on FDA Premarket Authorization Without TCA/FDCA Preemption

Date: Apr 23, 2026

States May Condition ENDS Sales on FDA Premarket Authorization Without TCA/FDCA Preemption I. Introduction Case: Wisconsinites for Alternatives to Smoking v. David Casey (7th Cir. Apr. 21, 2026)....

Facial Challenges to Pre‑K–3 Curriculum Limits Fail Where “Instruction on Human Sexuality” Has a Discernable Core and Largely Regulates Unprotected Official‑Duties Speech

Date: Apr 23, 2026

Facial Challenges to Pre‑K–3 Curriculum Limits Fail Where “Instruction on Human Sexuality” Has a Discernable Core and Largely Regulates Unprotected Official‑Duties Speech Introduction Kayla Smiley v....

Waiver of Rule 14 Severance Without Renewal at Close of Evidence; Proper Joinder of Similar Bank Robberies and Identity Proof by Modus Operandi

Date: Apr 21, 2026

Waiver of Rule 14 Severance Without Renewal at Close of Evidence; Proper Joinder of Similar Bank Robberies and Identity Proof by Modus Operandi 1. Introduction In United States v. Christopher Porter...

Experience-Based Reliability Under Rule 702 (Including Photoshop-Adjusted Fingerprint Images) and Enforceable Circuit Rule 30 Certifications

Date: Apr 20, 2026

Experience-Based Reliability Under Rule 702 (Including Photoshop-Adjusted Fingerprint Images) and Enforceable Circuit Rule 30 Certifications I. Introduction United States v. Omari Andrews, Jr. (7th...

Economic Detriment Alone Cannot Satisfy “Exceptional and Extremely Unusual Hardship,” and Reopening Requires Previously Unavailable, Material Evidence Tied to Qualifying Relatives

Date: Apr 20, 2026

Economic Detriment Alone Cannot Satisfy “Exceptional and Extremely Unusual Hardship,” and Reopening Requires Previously Unavailable, Material Evidence Tied to Qualifying Relatives I. Introduction...

Economic Hardship Alone Does Not Meet the “Exceptional and Extremely Unusual Hardship” Standard, and Motions to Reopen Require Previously Unavailable, Material Evidence

Date: Apr 17, 2026

Economic Hardship Alone Does Not Meet the “Exceptional and Extremely Unusual Hardship” Standard, and Motions to Reopen Require Previously Unavailable, Material Evidence I. Introduction Bato Petrov v....

No New Substantive Due Process Privacy Right for Police Evidence-Sharing with Untrained Auxiliary Personnel in Child-Image Investigations

Date: Apr 17, 2026

No New Substantive Due Process Privacy Right for Police Evidence-Sharing with Untrained Auxiliary Personnel in Child-Image Investigations Introduction Jane Doe 1, et al. v. Steven V. Sloan, et al....

No New Substantive Due Process “Privacy” Right Against Investigatory Sharing of Child-Exploitation Images Without a Glucksberg/Dobbs Historical Showing

Date: Apr 17, 2026

No New Substantive Due Process “Privacy” Right Against Investigatory Sharing of Child-Exploitation Images Without a Glucksberg/Dobbs Historical Showing Introduction Jane Doe 1, et al. v. Steven V....

No New Substantive Due Process “Privacy” Right for Investigative Sharing of Illicit Images Without Historical Grounding

Date: Apr 17, 2026

No New Substantive Due Process “Privacy” Right for Investigative Sharing of Illicit Images Without Historical Grounding 1. Introduction Jane Doe 1, et al. v. Steven V. Sloan, et al. is a Seventh...

Qualified Immunity Appeals: A “Without Prejudice” Denial that Postpones Merits Decision Is Not Immediately Appealable

Date: Apr 17, 2026

Qualified Immunity Appeals: A “Without Prejudice” Denial that Postpones Merits Decision Is Not Immediately Appealable Case: Marwan Mahajni v. Vu Do (No. 24-3175) — Court: Seventh Circuit — Date:...

Title IX Pseudonym Rule: Mental-Health Risk Alone Does Not Overcome the Presumption of Open Courts; Merits Are Irrelevant to Doe Status

Date: Apr 16, 2026

Title IX Pseudonym Rule: Mental-Health Risk Alone Does Not Overcome the Presumption of Open Courts; Merits Are Irrelevant to Doe Status 1. Introduction John Doe v. University of Southern Indiana (7th...

No “Faretta-lite” Duty: Midtrial Requests to Reappoint Counsel May Be Denied After a Valid Waiver and Serial Counsel Breakdowns

Date: Apr 16, 2026

No “Faretta-lite” Duty: Midtrial Requests to Reappoint Counsel May Be Denied After a Valid Waiver and Serial Counsel Breakdowns Case: United States v. Lennie Perry (7th Cir. Apr. 13, 2026) Court:...

Magistrate-Conducted Supervised-Release Revocation Hearings: No Automatic Second District-Judge Allocution Absent Rule 59 Objections

Date: Apr 10, 2026

Magistrate-Conducted Supervised-Release Revocation Hearings: No Automatic Second District-Judge Allocution Absent Rule 59 Objections I. Introduction In United States v. Erik D. Zahursky (7th Cir....