7th Circuit Case Commentaries

“No Court Shall Have Jurisdiction” Means No Review of § 1182(a)(9)(B)(v) Waiver Decisions—including Eligibility Determinations

Date: Apr 3, 2026

“No Court Shall Have Jurisdiction” Means No Review of § 1182(a)(9)(B)(v) Waiver Decisions—including Eligibility Determinations Case: Danuta Dec v. Markwayne Mullin Court: Seventh Circuit Date: March...

AEDPA Deference Applies When State Court Treats Excluded Defense Evidence as Cumulative (No Constitutional Error), and Conceded Attorney Mistakes Still Require Strickland Prejudice

Date: Apr 3, 2026

AEDPA Deference Applies When State Court Treats Excluded Defense Evidence as Cumulative (No Constitutional Error), and Conceded Attorney Mistakes Still Require Strickland Prejudice Case: Maurice Holt...

26 U.S.C. § 6201(a)(4)(A) Authorizes IRS Assessment and Immediate Civil Collection of Criminal Tax Restitution for Title 18 Offenses, Unconstrained by Sentencing Payment Schedules

Date: Apr 3, 2026

26 U.S.C. § 6201(a)(4)(A) Authorizes IRS Assessment and Immediate Civil Collection of Criminal Tax Restitution for Title 18 Offenses, Unconstrained by Sentencing Payment Schedules Case: Paul M....

AEDPA Deference: No Federal Habeas Relief for Evidence-Suppression/Destruction Misconduct Absent a Clearly Established Supreme Court Rule Requiring a Different Remedy

Date: Mar 26, 2026

AEDPA Deference: No Federal Habeas Relief for Evidence-Suppression/Destruction Misconduct Absent a Clearly Established Supreme Court Rule Requiring a Different Remedy Case: Chong Lee v. Bradley...

Steinhoff v. Malovrh: Fact Disputes Over Alleged Rifle-Strike Deadly Force Defeat Summary Judgment, While Drug-Raid Takedown Receives Qualified Immunity Absent Fact-Specific Clearly Established Law

Date: Mar 26, 2026

Steinhoff v. Malovrh: Fact Disputes Over Alleged Rifle-Strike Deadly Force Defeat Summary Judgment, While Drug-Raid Takedown Receives Qualified Immunity Absent Fact-Specific Clearly Established Law...

Reaffirming the “Strategic Placement” Nexus Under 18 U.S.C. § 924(c): An Unloaded Firearm in a Closet Can Further Drug Trafficking When Kept Adjacent to a Drug Workstation

Date: Mar 26, 2026

Reaffirming the “Strategic Placement” Nexus Under 18 U.S.C. § 924(c): An Unloaded Firearm in a Closet Can Further Drug Trafficking When Kept Adjacent to a Drug Workstation Introduction In United...

§ 1983 False-Arrest Claims: “Any Crime” Probable Cause and Flexible Jury Instructions on Illinois Obstruction/Resistance

Date: Mar 26, 2026

§ 1983 False-Arrest Claims: “Any Crime” Probable Cause and Flexible Jury Instructions on Illinois Obstruction/Resistance Introduction In Marion Thomas v. Daniel McAuliffe (7th Cir. Mar. 23, 2026),...

Waiver of New Factual Theories on Appeal in U.S.S.G. § 2D1.1(b)(1) Firearm-Enhancement Litigation

Date: Mar 26, 2026

Waiver of New Factual Theories on Appeal in U.S.S.G. § 2D1.1(b)(1) Firearm-Enhancement Litigation I. Introduction In United States v. Tommie L. Haney (7th Cir. Mar. 23, 2026) (nonprecedential), the...

United States v. Adam Power — No Plain-Error Relief for Rule 11 Factual-Basis Claims Without a Showing of Prejudice; Below-Guidelines “De Facto Life” and Disparity Challenges Fail Absent a Developed District-Court Record

Date: Mar 25, 2026

No Plain-Error Relief for Rule 11(b)(3) Factual-Basis Defects Absent Concrete Prejudice; Below-Guidelines “De Facto Life” and Disparity Challenges Are Unavailing Without Record Support Introduction...

Minimal-Articulation Deference: ALJs May Discount Treating Psychologists When Inconsistent, Poorly Supported, and Not Required to Address Every Regulatory Factor Explicitly

Date: Mar 24, 2026

Minimal-Articulation Deference: ALJs May Discount Treating Psychologists When Inconsistent, Poorly Supported, and Not Required to Address Every Regulatory Factor Explicitly Case: Laurie Yokosh v....

Ignoring an Express Contractual Post-Award Punitive-Damages Review Exceeds Arbitral Authority Under FAA § 10(a)(4)

Date: Mar 24, 2026

Ignoring an Express Contractual Post-Award Punitive-Damages Review Exceeds Arbitral Authority Under FAA § 10(a)(4) I. Introduction In USAA Savings Bank v. Michael Goff, the Seventh Circuit addressed...

Seventh Circuit Maintains “Informal, Non-Adversarial” Due Process as Sufficient for Disciplinary Segregation Transfers (Post-Torres)

Date: Mar 20, 2026

Seventh Circuit Maintains “Informal, Non-Adversarial” Due Process as Sufficient for Disciplinary Segregation Transfers (Post-Torres) Case: Norberto Torres v. Kent Brookman (with Jason Hart) Court:...

Revocation Sentencing: Serious Violations May Justify Statutory-Maximum Reimprisonment Despite Chapter 7 Range

Date: Mar 20, 2026

Revocation Sentencing: Serious Violations May Justify Statutory-Maximum Reimprisonment Despite Chapter 7 Range Introduction In United States v. Steven Bradford (7th Cir. Mar. 18, 2026), the Seventh...

PLRA Exhaustion: A Single Grievance Suffices for Continuing Dental-Care Denials and Need Not Name Every Staff Member if It Provides Identifying Detail

Date: Mar 19, 2026

PLRA Exhaustion: A Single Grievance Suffices for Continuing Dental-Care Denials and Need Not Name Every Staff Member if It Provides Identifying Detail Case: Anthony Boyce v. Ashley Cox Court: Court...

General Country-Conditions Evidence Cannot Establish Nexus in Gang-Extortion Asylum Claims; Perceived Wealth Is Not a Protected Ground

Date: Mar 19, 2026

General Country-Conditions Evidence Cannot Establish Nexus in Gang-Extortion Asylum Claims; Perceived Wealth Is Not a Protected Ground 1. Introduction In Norma Santos-Menjivar v. Pamela J. Bondi (7th...

Overbroad Single-Family Warrants in Multi-Unit Buildings: Reasonable Pre-Issuance Inquiry, Target-Limited Execution, and Exigent-Entry Backstops

Date: Mar 19, 2026

Overbroad Single-Family Warrants in Multi-Unit Buildings: Reasonable Pre-Issuance Inquiry, Target-Limited Execution, and Exigent-Entry Backstops 1. Introduction In United States v. Floyd Suggs (7th...

Habeas “Amended” Briefs that Incorporate the Original Petition Do Not Supersede It; Prison-Discipline Proportionality Remains Governed by the Seventh Circuit’s Madyun/Chapman Framework

Date: Mar 18, 2026

Habeas “Amended” Briefs that Incorporate the Original Petition Do Not Supersede It; Prison-Discipline Proportionality Remains Governed by the Seventh Circuit’s Madyun/Chapman Framework Introduction...

Certification of Kentucky “Reason to Believe” Mens Rea Question for Categorical Aggravated-Felony Analysis (K.R.S. § 514.110)

Date: Mar 18, 2026

Certification of Kentucky “Reason to Believe” Mens Rea Question for Categorical Aggravated-Felony Analysis (K.R.S. § 514.110) 1. Introduction In Mohamed Ibrahim Hassan v. Pamela J. Bondi (7th Cir....

Alternative Plan of Care Clauses Do Not “Provide” Home-Health Benefits Under Illinois § 2012.70(a)(2) Absent an Express Home-Care Benefit

Date: Mar 18, 2026

Alternative Plan of Care Clauses Do Not “Provide” Home-Health Benefits Under Illinois § 2012.70(a)(2) Absent an Express Home-Care Benefit I. Introduction Patrick M. Hartnett and Daniel J. Hartnett,...

State-Interview Lies as Federal Witness Tampering: Routine Federal–State Collaboration and a Materialized FBI Investigation Satisfy Fowler’s “Reasonable Likelihood”

Date: Mar 18, 2026

State-Interview Lies as Federal Witness Tampering: Routine Federal–State Collaboration and a Materialized FBI Investigation Satisfy Fowler’s “Reasonable Likelihood” Introduction In United States v....