7th Circuit Case Commentaries

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....

Magistrate-Conducted Revocation Hearings and “On-the-Papers” Adoption: No Second Allocution Hearing Absent Rule 59 Objections

Date: Apr 9, 2026

Magistrate-Conducted Revocation Hearings and “On-the-Papers” Adoption: No Second Allocution Hearing Absent Rule 59 Objections 1. Introduction In United States v. Erik Zahursky (7th Cir. Apr. 8, 2026)...

Title VII in the Seventh Circuit: Failure-to-Promote Requires Evidence of Qualification and a Non-White Comparator; Temporary Housing and Undesirable Assignments Are Not “Materially Adverse” Retaliation

Date: Apr 9, 2026

Title VII in the Seventh Circuit: Failure-to-Promote Requires Evidence of Qualification and a Non-White Comparator; Temporary Housing and Undesirable Assignments Are Not “Materially Adverse”...

Second-or-Successive Bar for SVP Commitment Challenges Targeting the Original Order; Delay-Driven Bypass of Exhaustion Under § 2254(b)(1)(B)(ii)

Date: Apr 8, 2026

Second-or-Successive Bar for SVP Commitment Challenges Targeting the Original Order; Delay-Driven Bypass of Exhaustion Under § 2254(b)(1)(B)(ii) I. Introduction Case: William Walls v. Erin Posey,...

Redacted-Exhibit Pleading Rule: Courts May Consider an Unredacted “Complete” Version Under Incorporation-by-Reference Without Rule 12(d) Conversion

Date: Apr 4, 2026

Redacted-Exhibit Pleading Rule: Courts May Consider an Unredacted “Complete” Version Under Incorporation-by-Reference Without Rule 12(d) Conversion Case: Mohamed Muthana v. Markwayne Mullin, No....

Implementation Plans in Prison Consent Decrees Are Enforceable Only Upon PLRA § 3626(a)(1)(A) Findings; Limited Interlocutory Review Under § 1292(a)(1)

Date: Apr 4, 2026

Implementation Plans in Prison Consent Decrees Are Enforceable Only Upon PLRA § 3626(a)(1)(A) Findings; Limited Interlocutory Review Under § 1292(a)(1) I. Introduction Case: Don Lippert v. Latoya...

PLRA-Gated Enforcement of Implementation Plans Incorporated into Prison Consent Decrees (and Narrow § 1292(a)(1) Jurisdiction)

Date: Apr 4, 2026

PLRA-Gated Enforcement of Implementation Plans Incorporated into Prison Consent Decrees (and Narrow § 1292(a)(1) Jurisdiction) I. Introduction Don Lippert, et al. v. Latoya Hughes, et al. is a...

MCA Exemption Applies to Intrastate Shuttle Legs Between Off-Site Storage Lots and Final Assembly Plant Destination

Date: Apr 4, 2026

MCA Exemption Applies to Intrastate Shuttle Legs Between Off-Site Storage Lots and Final Assembly Plant Destination Introduction In Renee Stingley, et al. v. L ACI Transport Inc., et al. and...

Motor Carrier Act Exemption Applies to Intrastate Shuttle Runs Between Off-Site Staging Lots and the Final Facility When the Goods Remain in a Continuous Interstate Journey

Date: Apr 4, 2026

Motor Carrier Act Exemption Applies to Intrastate Shuttle Runs Between Off-Site Staging Lots and the Final Facility When the Goods Remain in a Continuous Interstate Journey 1. Introduction In Renee...

When § 1442 Is Invoked, Appellate Review Reaches the Entire Remand Order—But § 1442(d) Still Limits Removal to the Ancillary Subpoena Proceeding

Date: Apr 4, 2026

When § 1442 Is Invoked, Appellate Review Reaches the Entire Remand Order—But § 1442(d) Still Limits Removal to the Ancillary Subpoena Proceeding I. Introduction Robert Barker v. Edward Boettcher (7th...

Anti-Stacking in Illinois UIM Coverage Caps Recovery at the Highest Single-Policy Limit, Even for Multiple Insureds in One Accident

Date: Apr 4, 2026

Anti-Stacking in Illinois UIM Coverage Caps Recovery at the Highest Single-Policy Limit, Even for Multiple Insureds in One Accident Introduction Thomas Polk v. Progressive Northern Insurance Company...

Seventh Circuit Recognizes “Dangerous-Felony” As-Applied Validity of § 922(g)(1) Under Bruen/Rahimi

Date: Apr 4, 2026

Seventh Circuit Recognizes “Dangerous-Felony” As-Applied Validity of § 922(g)(1) Under Bruen/Rahimi 1. Introduction United States v. Edlando Watson (7th Cir. Apr. 2, 2026) addresses two recurring...

BIPA Section 20 (2024) Damages Amendment Is Retroactive: Per-Person (Not Per-Scan) Recovery as a Remedial, Procedural Change

Date: Apr 4, 2026

BIPA Section 20 (2024) Damages Amendment Is Retroactive: Per-Person (Not Per-Scan) Recovery as a Remedial, Procedural Change I. Introduction In a consolidated set of interlocutory appeals—Reginald...